McArthur Dairy - Executive Summary |
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May 4, 1999 RMP Reporting Center C/o Computer Based Systems, Inc. Suite 300 4600 North Fairfax Drive Arlington, VA 22203 To Whom It May Concern: RE: U.S. EPA's "Risk Management Program" Rule McArthur Dairy, Miami, FL Anhydrous Ammonia-Refrigeration Process Certification Letter Enclosed is a copy of the Risk Management Plan prepared electronically on disk. This has been prepared using EPA's RMP*SUBMIT. To the best of the undersigned's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete. Signature Title Printed Name Date If you have any questions, please call at your convenience. Sincerely, McArthur Dairy Rhett Flanders Plant Manager Enclosure Certification Letter EXECUTIVE SUMMARY Description of Facility and Regulated Substance Handled: McArthur Dairy, Miami, FL processes milk and juice products. The facility utilizes anhydrous ammonia as a refrigerant to maintain the proper temperature of the milk and jui ce in the facility. Anhydrous ammonia is an effective refrigerant that has been used for many years by most food processing facilities. Ammonia is normally a gas at ambient temperatures but is handled as a gas liquefied under pressure. The refrigeration system consists of a high-pressure receiver, evaporators, compressors, piping, and valves. Accidental Release Prevention and Emergency Response Policies: McArthur Dairy is committed to promoting safety for the plant, its employees and the surrounding area. The facility is complying with OSHA's Process Safety Management Standard (PSM), Title 29 Code of Federal Regulations (CFR) 1910.119, and EPA's Risk Management Program regulations (RMP), Title 40 CFR Part 68. The purpose of these programs is to ensure that the refrigeration system is operated safely in order to prevent releases of ammonia from the system. In addition, these programs serve to develop procedures to minimize releases in the event that they do occur and to outline appropr iate emergency response steps to take in the event of a release. Worst Case Release Scenario: EPA's "Risk Management Program Guidance for Ammonia Refrigeration" (November 1998) and the International Institute of Ammonia Refrigeration's (IIAR) Risk Management Guidelines (1998) were the primary documents used to develop the worst case release scenario. The worst case release is one that is unlikely to occur. The purpose of the worst case release analysis is to support a dialogue with the community on release prevention. It is a conservative analysis and is not to serve as a rational basis for actual emergency response planning. The worst case release scenario (as defined by EPA) is the release of the largest quantity of ammonia from a vessel or process line failure that results in the greatest distance to a toxic endpoint. The worst case release scenario for the refrigeration process is assumed to be a case where the total quantity of ammonia in the largest vessel is released. The releas e scenario was performed assuming that the vessel was filled to 100% capacity, considering administrative controls and the amount that would ever be placed in the vessel. The vessel, however, is normally filled to (50%) normal operating capacity. There were no passive mitigation systems (dikes, berms, drains, sumps or enclosures) considered in the analysis since the vessel is located outdoors. I In addition, Dean Foods has installed a sophisticated system of ammonia sensors that can remotely close certain isolation valves in the event of a small release and thereby limit an accidental release of ammonia. These sensors are capable of detecting releases of ammonia at low levels, and are connected to a computer that will shut certain valves to the system if ammonia is detected. In this way, potential releases of ammonia are minimized. A possible release scenario is one in which a >" pipe ruptures outside. Although there are alarms in the engine room which are close by, it was decided to not include these sensor alarms in the event that the wind was blowing the opposite direction (west). Therefore, the EPA's default response time of ten minutes was used for this scenario. The RMP*Comp software was used to determine the toxic endpoint. The toxic endpoint used for this scenario must be where the ambient concentration of ammonia is 0.14 mg/L or less. Based on EPA's guidance, the alternative release scenario would result in a situation where public receptors would be within the distance to the toxic endpoint. The toxic endpoint used for this scenario must be where the ambient concentration of ammonia is 0.14 mg/L or less. This endpoint is a concentration below which nearly all individuals could be exposed to for one hour without serious health effects. Based on Exhibit 4-4 in EPA's guidance, a release from the largest vessel would result in a situation where public receptors would be within the distance to the toxic endpoint. Alternative Case Release Scenario: The alternative case release scenario selected is one in which a pipe is struck and broken outside. EPA's "Risk Management Program Guidance for Ammonia Refrigeration" (November 1998) and the International Institute of Ammonia Refrigeration's (IIAR) Risk Management Guidelines (1998) were the primary documents used to develop the alternative release scenario. The alternative release scenario is one that is more likely to occur than the worst case release scenario. The alternative release scenario must meet two criteria: 1) Must be more likely to occur than the worst case scenario, and 2) Must reach an endpoint off site, unless no such criteria exist. Accidental Release Prevention Program and Chemical-Specific Prevention Steps: As a part of its PSM Program, McArthur Dairy has established numerous programs that serve to prevent accidental releases of ammonia. These programs include: 7 2 7 Process Safety Information 7 Process Hazard Analysis 7 Operating Procedures 7 Training 7 Mechani cal Integrity 7 Management of Change 7 Pre-Startup Review 7 Compliance Audits 7 Incident Investigations 7 Employee Participation 7 Hot Work Permits Emergency Response Information: As a part of the PSM Program, the facility maintains an Emergency Response Plan that was prepared in order to improve responsiveness to an emergency incident, and to increase the reliability of actions taken during an incident. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations,notification of local emergency response agencies as well as the public. 7 Contractor Safety In the event of an emergency involving the ammonia system, it is the policy of the facility to request assistance as necessary by calling 911 which will notify the Regional Planning Council. In addition, the Regional Planning Council has included McArthur Da iry in its local emergency response planning, and McArthur Dairy has supplied them with an Emergency Action Plan for our facility. Five-Year Accident History: McArthur Dairy has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there have been no off-site impacts due to a release during this period including any impacts to the environment or the surrounding community. Steps to Improve Safety: Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Written SOP's for each piece of equipment in ammonia system, double safety valves at all locations, and the installation of ammonia detectors in the engine room. In addition, the facility will continue to operate and maintain the system in accordance with IIAR Guidance and will continue to implement its OSHA PSM Program in conjunction with the Risk Management Program. DEANS E XECUTIVE SUMMARY |