Anchor West Inc. - Executive Summary |
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RISK MANAGEMENT EXECUTIVE SUMMARY ANCHOR WEST INC., PECOS, TEXAS Accidental release prevention and emergency response policies: In this food processing facility, anhydrous ammonia is handled as adjunct to the manufacturing process to cool and freeze the product. Both the EPA and OSHA consider this chemical hazardous. Anhydrous ammonia is used to alter specific temperature and other related physical properties from ambient air for the efficient preservation of the food product. As this is an existing facility every effort has been taken to adhere to current regulations regarding anhydrous ammonia use and where appropriate upgrade the operation to improve the overall safety of the process. The Pecos facility has completed an exhaustive safety and design review under the OSHA Process Safety Management law, 29 CFR 1910.119. This law requires a complete analysis of the anhydrous ammonia process from a catastrophic release and safety perspective prior to its being put on-line. This document can be reviewed by contacting the Anchor West Inc. offices. It is Anchor West's policy to not only adhere to the Federal and State laws governing the use of this chemical but to extend safety, health, and environmental efforts beyond that of government requirements. In that vein Anchor West and its employees are committed to the safety and health of the employees and the well being of our community. The Pecos facility finds support from the internal corporate safety, health, and environmental staff as well as a number of outside professional consultants. The Anchor West Pecos facility emergency response planning program is based on the OSHA, EPA, and Coast Guard models for Hazardous Waste Operations and Emergency Response guidelines. The Pecos facility has an interactive HAZMAT structure within the facility. The system consists of Anchor West employees working with the Reeves County LEPC and its Emergency Director exclusively and is active twenty-four hours a day to deal with any emergency related to the application of highly hazardous chemicals, namely anhydrous ammonia. The Emergency Response Plan details the procedural aspects of the HAZMAT effort in the facility and the interaction between its members, the employees, local community, and its emergency personnel. The stationary sources and regulated substances handled: The Anchor West Pecos facility uses anhydrous ammonia within the processing and warehouse areas. As stated previously the anhydrous ammonia is utilized as a refrigerant to temper the ambient air before it is introduced into the above areas. The anhydrous ammonia is kept within a closed loop system and is transferred through the system via compressors, pumps etc. The Pecos facility consists of three separate systems. The initial system controls the Blast Cells and Main Storage areas, consisting of 15,000 pounds of anhydrous ammonia. The secondary and tertiary systems control independent Spiral Freezers containing 2,900 pounds of anhydrous ammonia. None of the systems are interconnected or utilize any of the same equipment. The systems can be 'topped off' at year's end to allow for any minor losses within the system. Technical grade or better of anhydrous ammonia is utilized to minimize the introduction of contaminants such as water into the system. Written Standard Operating Procedures are followed for all system operations including the transfer of anhydrous ammonia to the system. System components are accounted for on a dedicated parts inventory system and managed through an in-house maintenance schedule established in cooperation with the component manufacturers. The worst-case and alternate release scenarios: AMMONIA WORST CASE F CLASS: Failure of a single low temperature receiver with a capacity of 2,792 gallons of anhydrous ammonia. Considering an opening 2.8 inches in length and 4 inches in width. This would result in the release of all of the anhydrous ammonia in the low temperature receive r in roughly 10 minutes. The atmospheric conditions are dictated by the Environmental Protection Agency for this case. The wind direction should be considered on a case by case basis. The footprint (see case printouts) has included an outside zone which can be used to derive a safety zone outside the direct area or level of concern area. The maximum threat zone is 2.2 miles down range for the lethal concentration utilizing the F atmospheric class required by the EPA. The estimated threat zone perpendicular to the flow is roughly 30 yards on either side of perpendicular. AMMONIA ALTERNATE CASE F CLASS: The alternate case release scenario consisted of a pressure release from the top of the high pressure receiver through the pressure relief valve at that location. The pressure relief valve has a diameter of 1.0 inch. The release rate of 83.5 pounds per minute accounted for 53 pounds of released ammonia over a 2 minute period. The downrange radial for the threat zone is 715 yards. The perpendicular component is 340 yards. The general accidental release prevention program and the specific prevention steps: The facility complies with the OSHA Process Safety Management Standard for the highly hazardous chemical anhydrous ammonia. As part of the requirements a process hazard analysis (PHA) was performed in the form of a What IF Checklist including a review of mechanical integrity. As a result of this, the process and instrument diagrams (P&ID's) have been reviewed as part of the accident prevention program. All valves, gangs, and headers have been placed on the roof where possible to reduce potential exposure to employees. This also reduces the potential from strike damage. Component parts are also being replaced based upon a specific schedule as established under mechanical integrity. The system is also being evaluated for leaks via a real-time ammonia analyzer. All workers involved with the system have been trained regarding system safety and opera tion. All operations are supported by written operating instructions. Anchor Foods Inc, has also retained an environmental/occupational health consultant, TriStar Associates Inc. This firm is an active participant in a review related to issues regarding the process safety of the ammonia system. Five year accident history: ANHYDROUS AMMONIA: No accident history has been reported for this facility. |