Merchants Ice & Cold Storage Co. - Executive Summary

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Accidental release prevention and emergency response policies at Merchants 
The policy of Merchants Ice & Cold Storage Company, is to develop those programs necessary to protect the health of its employees against on-the-job hazards which may cause sickness or injury now or in the future.  Also, as the operator of a facility at which substances may be used that in uncontrolled situations could cause harm to the public and damage to the environment, we will strive for environmental excellence with a commitment to continual improvement, pollution prevention and compliance with legislative requirements.  The Risk Management Program (RMP) is one of these programs. 
    Each employee in areas where the RMP is applicable will be knowledgeable of the related policies and procedures and the supervisors or a designated person is required to insure that they understand them.  Employees and supervisors are required to comply with our policies and are subject to corrective action in those cases det 
ermined to indicate willful violation. 
   A written plan of action regarding the implementation of employee participation in the program has been developed as a part of our Release Prevention Program as specified by 29 CFR 1910.119.  A compilation of safety information to enable Merchants Ice & Cold Storage Company and the employees involved in the ammonia operations to operate safety has been accumulated.  This process safety information includes information pertaining to the toxicological and physical hazards of the chemical listed.  This plan of action includes information pertaining to the technology of the processes, and information pertaining to any equipment used in the processes. 
A complete hazard analysis and study of the ammonia system's mechanical integrity has been completed on the ammonia receipt, storage, and utilization operations have been completed.  This analysis was completed by safety and health staff, engineering and maintenance personnel, and certain operational per 
sonnel.  This analyses involved a review of each operation of the processes to address steps for each operating phase, operating limits, safety and health considerations, and safety systems and their functions.  The assessment also included information concerning the emergency action plans related to the process; development and implementation of safe work practices regarding the control of entrance and exit of personnel in the process areas; pre-startup safety; mechanical integrity of equipment; inspection and testing, correction of deficiencies in equipment, planned or unexpected changes to the process, equipment, and procedures to the processes. 
A system was developed and is maintained to promptly address the team's findings and recommendations.  The hazard analyses will be updated as needed and at least every five (5) years. 
   Merchants Ice & Cold Storage Company has developed and implemented written operating procedures to provide clear instructions for safely conducting activities 
involved in the processes at each operation by our employees, consistent with the process safety information and to address steps for each handling phase, limitations, safety and health considerations, and safety systems and their functions.  Other written documentation of standard operating procedures as a part of this program is included in the following documents: 
Job Safety Analyses 
Mechanical Integrity Study of Process Equipment 
Preventive Maintenance Program 
Written Emergency Response Plan 
Employee Emergency Action and Evacuation Plan 
   Each employee involved in operations within the processes where the ammonia is received, processed, or used at the facility has been trained in an overview of the processes and in the operating procedures as outlined by OSHA regulations.  Refresher training is required every three years, and more often if necessary.  Training includes: 
   a.  Emphasis on the specific safety and health hazards; 
   b.  Emergency operations in the case of a release inclu 
ding shutdown; and 
   c.  Safe work practices applicable to the employee's job tasks. 
   Designated personnel have specific responsibilities related to the use of contractors who perform maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to areas where the Ammonia is received, stored, or processed in the facility.  These responsibilities include specific requirements in selection of contractors regarding the contractor's safety performance and programs; the provision of information concerning the emergency action plans related to the process; development and implementation of safe work practices regarding the control of entrance and exit of contract employers and contract employees in the process areas, periodic evaluation of the contractor related to safety management at the process; maintenance of certain records related to contractor employee injury and illness; development of written procedures for any new processes, and provision of training to emplo 
yees.   
   Contractors performing work on or adjacent to equipment or processes in which Ammonia is present must have clearance from the Maintenance Supervisor prior to beginning operations.   
   In those cases where contractors will perform work directly to or on the process equipment in which the Ammonia is present, the Safety Coordinator and Maintenance Supervisor will provide an orientation section to them prior to beginning operations.  This orientation will include an introduction to the Merchants Ice & Cold Storage Company Process Safety Management Program, information concerning the toxicological and physical hazards of Ammonia, and the emergency response plan in the case of an incident involving a release.  Upon completion, the contractor will be issued a permit by the Maintenance Supervisor to begin work. 
The Merchants facility and the Ammonia Process 
       Merchants Ice & Cold Storage Company provides employment for 9 workers in Louisville, Kentucky.  This facility is a cold storage 
warehouse owned by Ray C. Glass.   
Site Description: 
   The facility is located in Louisville, Kentucky at 801Logan Street, Louisville, Kentucky 40204.  Its Dun and Bradstreet number is 02-405-9032.  Map Location 38014'30"N; 85044'W. 
Operation Description 
   The site process involves the receipt of commercial food products for cold storage.  No processing takes place at the facility, only storage for maintenance of cold temperature.  Industrial lift trucks, placed into coolers or freezers move the materials. 
   From the time of receipt and throughout the storage period, the materials are maintained at a cool temperature by anhydrous ammonia refrigeration processes. 
   The air cooling process involves the distribution of liquid ammonia through piping (coils) across which air is blown with fans to cool the air.   
Operation (Technology) of the Process 
   Refrigeration is the control of heat.  According to American Heritage Dictionary heat is defined as: 
"The energy associated with the motion of at 
oms or molecules in 
solids, which can be transmitted through solid and fluid media 
by conduction, through fluid media by convection and through empty 
space by radiation." 
   Heat is energy.  The amount of energy or heat available is determined by the amount of motion or excitement of the atoms or molecules.  The more excited the molecules, the more energy or heat available. 
   This energy or heat can be moved or transferred.  This transfer occurs when there is a difference of temperature.  Heat flows from a source of grater energy (higher temperature) to a source of lower energy (lower temperature).  The greater the temperature difference, the more rapid the heat flow. 
   There are three types of heat transfer mechanisms: 
Conduction 
Convection 
Radiation 
   The use of liquid ammonia as a refrigerant is the transferring of heat by conduction and convection.  In conduction heat is transferred by the molecules in a medium coming in contact with each other.  The warm molecules collide with colder m 
olecules giving them some of the energy (heat).  The flow will occur if there is a difference of temperature from one side of the medium to the other.  Metals are very good at transferring heat by conduction. 
   By blowing air or moving a liquid such as water or glycol over a material such as metal that has been cooled heat is transferred by convection.  The heat load in a freezer is moved via convection to the coils where conduction takes place in transferring the heat to the refrigerant.  The refrigeration process does not produce cold.  It simply moves the heat from an area where it is not wanted to a place it can be discharged. 
   The refrigeration systems at Merchant are accomplished by three methods using Anhydrous Ammonia.  These include: 
Air Cooling 
Water Chilling 
 
   Liquid ammonia has the ability to absorb very large amounts of heat as it vaporizes.  This ability is the basis for mechanical refrigeration systems.  These mechanical systems utilize both pressure and temperature in th 
e refrigeration cycle.  There are five major components in a mechanical refrigeration system.  These include, 1) Receiver, 2) Metering device/expansion valves, 3) Evaporator, 4) Compressor, and 5) Condenser. 
   The Receiver collects the condensed vapors and stores the excess refrigerant charge that is not circulating through the system.  The receiver is located between the condenser and the expansion valve.  It is also used to store refrigerant when it is necessary to service the system. 
   The liquid ammonia is routed to a metering device (expansion valves).  This device regulates the amount of refrigerant going into the evaporator. 
   As the ammonia flows through the device, there is a pressure drop.  The amount of pressure drop determines the temperature of the refrigerant going to the evaporator.  The refrigerant leaves the metering device in both a liquid and a vapor phase. 
   The two-phase refrigerant then enters the evaporator.  The evaporator removes heat from the area or substance bei 
ng cooled.  The ammonia absorbs heat and vaporizes as it travels through the evaporator.  The ammonia then leaves the evaporator and travels to the compressor. 
   The compressor takes the vapor through the suction line and increases the pressure such that when the heat is removed in the condenser, the vapors change form and become liquid.  Work is required to compress these vapors.  This work is converted into energy and stored in the compressed vapors.  This increase in energy results in an increase in temperature. 
   The compressed vapors then go to a condenser.  The condenser removes a lot of the heat contained in the compressed vapors.  When enough heat is removed, the vapor changes form and become liquid.  This condenser liquid then flows to the receiver. 
   Merchants Ice & Cold Storage Company receives Anhydrous Ammonia by wheeled vehicle.  The receiver has a maximum of 11,000 pounds which is filled to 80% capacity.  The Anhydrous Ammonia is in a liquid form at receipt.  Contract perso 
nnel complete the connection to the tank. 
 
   Worst-case release scenario and alternative release scenario 
   As a part of the Merchants Ice & Cold Storage Company proactive program concerning the hazards of ammonia to its' workers and the surrounding public, its staff has conducted a thorough hazard assessment. 
   For the hazard assessment and the RMP, populations potentially affected are defined as those within a circle that has as its center the point of release and its radius the distance to the toxic or flammable endpoint.  Owners or operators may use Census data to define this population.  The presence of schools, hospitals, other institutions, public arenas, recreational areas, and large commercial and industrial developments that can be identified on street maps within this circle must be noted.  The presence of environmental receptors within this circle must also be listed.  The EPA has defined environmental receptors as natural areas such as national or state parks, forests, or mon 
uments; officially designated wildlife sanctuaries, preserves, refuges, or areas; and Federal wilderness areas, that can be exposed to an accidental release. 
   The worst case scenario for Anhydrous Ammonia was decided as the complete rapid loss of 1500 pounds of Anhydrous Ammonia during a one minute time frame. The following information was determined using the Automated Resource for Chemical Hazard Incident Evaluation (ARCHIE) model, based on the stability class F , 4.5 mph wind speed, and the level of 200ppm for Anhydrous Ammonia.  This resulted in a release rate of 1,500 lbs/min, and an end point of 2.75 miles from the spill point during summer season at 85 degrees F.   
   The alternate case scenario for Anhydrous Ammonia was decided as the loss of Anhydrous Ammonia resulting from a release through a 1-inch and a 2-inch line break. . The following information was determined using the Automated Resource for Chemical Hazard Incident Evaluation (ARCHIE) model, based on the stability class 
F, 6.5 wind speed, and a level of 3ppm for Anhydrous Ammonia.  This resulted in a release rate of 30bs/min, for a duration of 15 minutes, and an end point of .24 miles from the spill point from a 1-inch line in 2.2 minutes and .35 miles from a 2-inch in 3.2 minutes.   
General accidental release prevention program and chemical-specific prevention steps 
   Prevention of a release is a core component of the Merchants Risk Management Program.  This program is designed to insure proper work practices and an on-going mechanical integrity program.  This program also insures compliance with 29 CFR 1910.38, 1910.120, 1910.1200, 40 CFR, Part 68, Part 112, and Part 260. 
   Merchants Ice & Cold Storage Company has developed and implemented written operating procedures to provide clear instructions for safely conducting activities involved in the processes at each operation by our employees, consistent with the process safety information and to address steps for each handling phase, limitations, safet 
y and health considerations, and safety systems and their functions.  Other written documentation of standard operating procedures as a part of this program is included in the following documents: 
Mechanical Integrity Study of Process Equipment 
Preventive Maintenance Program 
Written Emergency Response Plan 
Employee Emergency Action and Evacuation Plan 
Training 
Each employee involved in operations within the process where Ammonia is received, processed, or used at the facility has been trained in an overview of the process and in the operating procedures as outlined by 29 CFR 1910.119.  Refresher training is provided no less than every three years and more often if necessary.  
Mechanical Integrity 
Also, each maintenance person who has responsibilities to perform maintenance on the process components receives training on an as needed basis, but no less than every three years. 
Emergency Response 
A team of individuals has been trained and is equipped as a HAZMAT team.  The team is equipped 
with Self-Contained Breathing Apparatuses, Level A suits and monitoring equipment to respond in an offensive manner. 
   A record of the training, which contains the identity of the employee, the date of training, and the means, used to verify that the employee understood the training is completed and maintained. 
 
Offensive level HAZMAT emergency response support is provided by the local fire station.  Their response time for emergencies at the facility is approximately five minutes. 
   Contractors. 
   Designated personnel have specific responsibilities related to the use of contractors who perform maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to areas where the Ammonia is received, stored, or processed in the facility.  These responsibilities include specific requirements in selection of contractors regarding the contractor's safety performance and programs; the provision of information concerning the emergency action plans related to the process; dev 
elopment and implementation of safe work practices regarding the control of entrance and exit of contract employers and contract employees in the process areas, periodic evaluation of the contractor related to safety management at the process; maintenance of certain records related to contractor employee injury and illness; development of written procedures for any new processes, and provision of training to employees.   
Five-year accident history 
No incidences of ammonia release have occurred at the facility that resulted in deaths or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. 
Emergency response program 
   Due to the receipt, usage, and storage of Ammonia in large quantities, Merchants Ice & Cold Storage Company takes a proactive approach to the protection of its employees, the public, and the environment.  In consideration of the hazardous effects that Ammonia may have on human heal 
th and the environment the following outlines the facilities prevention and emergency response plans: 
   Written Emergency Response Plan 
   Offensively Trained & Equipped Emergency Action Team in accordance with 29 CFR 1910.120 
   Development of a Written Implementation Plan of Action 
   Conduction of Hazard Analysis on routine and periodic basis 
   Development of and documentation of safe work practices 
   Initial and periodic training of employees 
   Conduction of pre-startup safety reviews 
   Conduction of Compliance Audits 
   Conduction of incident investigations 
   Contractor Program Safety Program 
   Hot Work Permit Program 
   Process Safety Management & Chemical Accidental Release Prevention Committee 
   Mechanical Integrity & Preventive Maintenance Program 
   Determination and planning for Worst-Case and Alternative Case Release Scenarios 
   Continual evaluation for methods to improve facility safety - Safety Committee 
   Meetings with the Local Emergency Planning Committee and Fir Department 
 
Planned changes 
to improve safety 
   In an attempt to insure a continual improvement in the facility worker protection and release prevention programs, training concerning this safety and environmental program and others is conducted for eight hours each month.  This training requires the attendance by all personnel whose job may have any relationship to the ammonia operations.
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