TLC LLC MILWAUKEE LOGISTIC CENTER - Executive Summary
A. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
The emergency response procedures are detailed in the MLC Emergency and Hazardous Materials Response Plans and Procedures. These manuals were designed to meet the following objectives:
1) To save lives.
2) To minimize and avoid injuries.
3) To protect the environment.
4) To minimize property damage.
The Emergency Response Plan and Procedures provides the reporting and notification procedures, evacuation procedures, and mitigation procedures that may be implemented to ensure operators respond effectively to an emergency situation. All employees are trained in their specific roles when responding to an emergency. The manuals are kept in strategic locations throughout the facilities and are readily available to all employees.
A. STATIONARY SOURCE AND REGULATED SUBSTANCE
The ammonia refrigeration system is a closed system that cycles the
rant, or ammonia, from liquid to gas and back again. The system, consisting of vessels, interconnecting piping, valves, and process equipment, cycles ammonia through various states (high pressure liquid, low pressure liquid, low pressure vapor, high pressure vapor, then back to high pressure liquid) in order to provide refrigeration for product and process equipment.
Changes in pressure are directly related to changes in temperature: lowering the ammonia pressure lowers its temperature. Low-pressure (cold) liquid ammonia provides refrigeration by removing ambient heat. Removal of ambient heat causes the liquid ammonia (contained within the system) to vaporize. Heat is latter removed from the ammonia as it is condensed back into a liquid. Typical operating conditions range from 5" hg on the low side to 150 psig on the high side.
Ammonia is used as the refrigerant in the refrigeration process.
The maximum intended inventory of ammonia is 10,000 pounds.
B. HAZARD ASSESMENT
Worst Case Release Result Summary
Scenario Description: Release of the maximum that can be stored in a vessel (accounting for administrative controls) - 8885 pounds in 10 minutes. Passive mitigation measures were used. The most pessimistic meteorological conditions were used: 1.5 meters per second wind speed, and F stability. The EPA RMP Guidance for Ammonia Refrigeration reference table and equations were used to determine the maximum downwind distance.
Distance to Toxic Endpoint: .1 miles.
C. Alternate Release Result Summary
Scenario Description: A 0.25-inch diameter leak of high-pressure liquid ammonia for one hour. The quantity of ammonia released at this rate is 6,600 pounds. The meteorological conditions used were 3 meters/second wind speed, and D stability. The EPA RMP Guidance for Ammonia Refrigeration reference tables and equations were used.
Distance to toxic endpoint: 0.1 miles.
D. ACCIDENTAL RELEASE PREVENTION PROGRAM
ty operates in accordance with accordance with the International Institute of Ammonia Refrigeration (IIAR) guidelines and standards including the following:
IIAR Bulletin 107, A Suggested Safety and Operating Procedures When Making Ammonia Refrigeration Tie-ins@
IIAR Bulletin 109, Minimum Safety Criteria for a Safe Ammonia Refrigeration System@
IIAR Bulletin 110, "Startup, Inspection, and Maintenance of Ammonia Refrigeration Systems"
IIAR, A Guide to Good Practices for the Operation of an Ammonia Refrigeration System@
In addition the Milwaukee Logistic Center has implemented a Process Safety Management program for compliance with CFR 29, 1910.119. This included an initial Process Hazard Analysis that is revalidated every five years. In addition, the facility has a Mechanical Integrity program that includes an Engineering Checklist for equipment inspections.
E. FIVE YEAR ACCIDENT HISTORY
There have been no reported releases of ammonia at this facility over the l
ast five years (04/05/1994 through 04/05/1999) .
F. EMERGENCY RESPONSE PROGRAM
In the event of a spill, release, near miss, or threatened release involving ammonia, the event will be reported to the supervisor in whose area the incident occurred. The supervisor will in turn report to the Plant Manager and/or Chief Engineer. The Plant Manager and /or Chief Engineer will immediately determine the quantity of the release and, if deemed necessary, notify the appropriate authorities and agencies. They will also determine the sections of the facility requiring evacuation, and notify all members of the Emergency Response Team (ERT), to assist in the evacuation process. They will also determine whether the system requires shut down. If evacuation of the facility is necessary, plant personnel will vacate the facility according to routes outlined in Section 12 of the MLC Emergency Response Plan (ERP). Emergency assembly area locations are identified in the ERP as well. The ERT and area super
visors are the responsible party for ensuring all employees evacuated to the designated rendezvous.
Notification and alarm procedures are outlined in the ERP as well.
In the event of an ammonia release, the Chief Engineer will initiate the Incident Command System and coordinate the containment process. ERT members will assist the Chief Engineer as directed to bring the incident under control.
Emergency response drills involving all facility personnel are performed on an annual basis. This ensures that employees are familiar with evacuation routes from the facility.
G. PLANNED CHANGES TO IMPROVE SAFETY
There were several recommendations resulting from the development of the PSM/RMP document including recommendations from the Process Hazard Analysis and Off-Site Consequence Analysis studies. The teams made several procedural/managerial recommendations to improve safety at the facility. These recommendations are expected to be implemented by December 1999 and are listed as follows:
1) Replace deficient piping, insulation systems.
2) Install ammonia detectors on relief and vent systems
3) Integrate PSM/RMP training with Hazard Communication
4) Implement a PSM/RMP compliance calendar