Texas Freezer Company Inc. - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

EXECUTIVE SUMMARY 
 
This report contains the Risk Management Plan (RMP) for the ammonia refrigeration systems located at the Texas Freezer Inc. cold storage facility  in Dallas, TX.   The RMP  was prepared by Primatech in accordance with the requirements of the U.S. Environmental Protection Agency (EPA) Risk Management Program (RM program) regulation (Risk Management Programs for Chemical Accidental Release Prevention, 40 CFR Part 68). 
 
Mr. Ray Rehman, Associate Engineer from Primatech, was the project manager for the preparation of the RMP.  Mr. Greg Hutton, Chief Engineer, coordinated the preparation of the RMP for Texas Freezer Inc. 
 
The information presented in this report reflects the data element requirements and numbering sequence of the final EPA RMP submission format .  Prior to submission to the EPA, the RMP information would need to be converted into a specified electronic format via data entry into a software tool such as RMP*Submit provided by the EPA.  EPA also requires th 
e numerical information in the RMP to be presented in a specified number of significant digits.  This format should be adhered to when specifying numerical values. 
 
 
A.   Accidental Release Prevention and Emergency Response Policies 
 
Texas Freezer recognizes management's responsibility in protecting its employees, equipment, property, and the environment.  The safety and health of all personnel are very important.  The control of accidents has been and will continue to be a basic responsibility of all personnel in the Dallas facility. 
 
To accomplish the company's goal in controlling accidental losses, the facility has established a Plant Safety Program.  The objectives of the Plant Safety Program are to: maximize efficiency and safety performance, reduce losses associated with damage of property, eliminate human suffering and the economic burden resulting from injuries and accidents. 
 
One of the activities associated with the Plant Safety Program has been the development and implementa 
tion of accidental release prevention and emergency response programs which are designed to comply with OSHA's Process Safety Management (PSM) standard (Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119), and EPA's Risk Management Program (RMP program) regulation (Risk Management Programs for Chemical Accidental Release Prevention, 40 CFR Part 68).  Mr. Greg Hutton, Chief Engineer, is responsible for implementation of the Risk Management Program. 
 
The purpose of the accidental release prevention and emergency response programs is to prevent the occurrence, and minimize the consequences of significant releases of toxic substances as well as fires, explosions, and other types of catastrophic accidents.  Overall, these programs prevent accidental fatalities, injuries and illnesses and avoid physical property damage. 
 
The accidental release prevention and emergency response programs help prevent accidents because they focus on the rules, procedures, and practices whi 
ch govern individual processes, activities, or pieces of equipment.  These rules are detailed and improved as (often as) necessary.  They are also communicated to and accepted by all employees at the facility. 
 
B.   Stationary Source and Regulated Substances Handled 
 
Texas Freezer Inc. operates a cold storage facility in Dallas, TX.  The facility operates two  ammonia refrigeration systems (i. e., the Building 1 and Building 2 Refrigeration Systems) to provide cooling and freezing capabilities.  The amount of anhydrous ammonia (CAS #7662-41-7) contained in these systems is below the EPA's  threshold of 10,000 pounds.  The maximum amount of ammonia charged to the Building 1 and 2 Refrigeration Systems is 9,500 and 9,000 pounds respectively.  Since ammonia releases from these systems could pose a risk of offsite public impact and the facility currently complies with the OSHA PSM standard (29 CFR 1910.119), the systems have been subjected to the Program 3 requirements of the EPA's RM prog 
ram. 
 
C.   Summary of Worst-Case and Alternative Release Scenarios 
 
Building 1 Refrigeration System 
 
The worst-case release scenario for the Building 1 refrigeration system at the Dallas facility involves the release of 8,597 pounds of ammonia over a 10 minute period due to the failure of the controlled pressure receiver (CPR-1).  This quantity represents the full capacity of the vessel, which is a conservative assumption as it may only be full once in a three-year period during a substantial system pump-down.  Under worst-case weather conditions, ammonia could travel 1.16 miles before dispersing enough to no longer pose a hazard to the public. 
 
The worst-case release scenario related to the Building 1 refrigeration system is unlikely for the following reasons: 
 
        The worst-case weather conditions which were used for this scenario are not typical; 
        The controlled pressure receiver is located in an enclosed area that could help to contain such a release and minimize traffic (e. g.; f 
orklifts) near the receiver; 
        Industry standards have been followed for the manufacture and quality control of the receiver; 
        Ammonia is not corrosive in this service and the vessel is relatively new;  
        Pressure safety valves limit operating pressure in the receiver; 
        An ammonia detector which is tied to emergency ventilation fans and an external monitoring system is located near the controlled pressure receiver in the ammonia refrigeration system; 
        The facility has a preventive maintenance program in place to maintain the on-going integrity of vessels;  
        The facility has a training program designed to ensure that the system is operated by qualified personnel; and, 
        The facility emergency response procedures enable trained personnel to respond quickly to isolate any potential releases. 
 
The alternative release scenario considered for the Building 1 Refrigeration System involves the release of 943 pounds of ammonia due to the opening of the 3/4" pressure safety valve on th 
e rooftop condenser in response to elevated compressor discharge pressures.  It was assumed that the pressure safety valve would remain open for 10 minutes while the system pressure is reduced and then reseat properly.  Under alternative release weather conditions, ammonia could travel 0.10 miles before dispersing enough to no longer pose a hazard to the public. 
 
The alternative release scenario for the Building 1 refrigeration system is unlikely for the following reasons: 
 
        The refrigeration system is operated at relatively low system pressures (120- 140 psig) compared to general industry practice (140-180 psig); 
        A dedicated Allen-Bradley PLC, equipped with alarm and shutdown functions, constantly monitors system parameters; 
        The facility has a preventative maintenance program in place to monitor the on-going integrity of the system;  
        The facility has a training program designed to ensure that the system is operated by qualified personnel; and, 
        The facility emergency resp 
onse procedures enable trained personnel to respond quickly to isolate any potential releases. 
    
Building 2 Refrigeration System 
 
The worst-case release scenario for the Building 2 refrigeration system at the Dallas facility involves the release of 6,985 pounds of ammonia over a 10 minute period due to the failure of the controlled pressure receiver (CPR-1).  This quantity represents the full capacity of the vessel, which is a conservative assumption as it could be at most 40% full during normal operating conditions.   Under worst-case weather conditions, ammonia could travel 1.0 miles before dispersing enough to no longer pose a hazard to the public.  
 
The worst-case release scenario related to the Building 2 refrigeration system is unlikely for the following reasons: 
 
        The worst-case weather conditions which were used for this scenario are not typical; 
        The controlled pressure receiver is located in an enclosed area that could help to contain such a release and minimize traffic ( 
e.g., forklifts) near the receiver; 
        Industry standards have been followed for the manufacture and quality control of the receiver; 
        Ammonia is not corrosive in this service and the vessel is relatively new; 
        Pressure safety valves limit operating pressure in the receiver; 
        An ammonia detector which is tied to emergency ventilation fans and an external monitoring system is located near the controlled pressure receiver in the ammonia refrigeration system; 
        The facility has a preventive maintenance program in place to maintain the on-going integrity of vessels;  
        The facility has a training program designed to ensure that the system is operated by qualified personnel; and, 
        The facility emergency response procedures enable trained personnel to respond quickly to isolate any potential releases. 
 
The alternative release scenario considered for the Building 2 refrigeration system involves the indoor release of 285 pounds of ammonia over a 10 minute period from a flange leak on 
a 1/2" high pressure liquid line.  Under alternative release weather conditions, ammonia could travel 0.10 miles before dispersing enough to no longer pose a hazard to the public. 
 
The alternative release scenario for the Building 2 refrigeration system is unlikely for the following reasons: 
 
        Industry standards have been followed for the manufacture and quality control of these lines; 
        Ammonia is not corrosive in this service; 
        Most of the lines are elevated to minimize potential damage from fork lifts; 
        The facility has a preventive maintenance program in place to maintain the on-going integrity of the system;  
        The facility has a training program designed to ensure that the system is operated by qualified personnel; and, 
        The facility emergency response procedures enable trained personnel to respond quickly to isolate any potential releases by closing isolation valves in the liquid lines. 
 
 
 
D.   Description of the Accidental Release Prevention Program 
 
The prevention p 
rogram consists of the following elements: 
 
        Employee Participation:  This program involves the employees in establishing and implementing the program.  Employees are also to be involved when a process hazard analysis is conducted.  The program also ensures that all employees have complete access to the program. 
 
        Process Safety Information: Written information has been collected which enables the employees to identify and understand the potential hazards in the system. The written information includes the ammonia MSDS and a description of the design of the ammonia refrigeration system. 
 
        Process Hazard Analysis: Formal studies using the What-If Technique have been conducted to look at the system and identify potential hazards. 
 
        Operating Procedures:  Written, detailed procedures have been developed which describe the steps which should be followed to safely operate the ammonia refrigeration system. 
 
        Training: A training program has been developed which ensures that employe 
es are trained on all aspects of the system and on the duties which they should perform to ensure the safe operation of the ammonia refrigeration system. 
 
        Contractors: All contractors are screened and evaluated before they perform work on or near the ammonia refrigeration system.  The contractors are also periodically evaluated to ensure that they perform work by following safe work practices. 
 
        Pre-Startup Safety Review: A pre-startup safety review is completed for all new ammonia projects to verify that all applicable safety programs are in place, training has been performed, and construction has been completed according to design standards before the project is put into use. 
 
        Mechanical Integrity:  This program ensures that the ammonia refrigeration systems are built and maintained using preventive maintenance procedures to minimize unexpected breakdowns or failures. 
 
        Hot Work Permit: These procedures ensure that a signed permit is obtained prior to any cutting, welding,  
or burning. 
 
        Management of Change: The procedures are designed to ensure that all changes made to the ammonia refrigeration system are properly reviewed. 
 
        Incident Investigation: The procedures ensure that any incidents (and near misses) are investigated, reviewed, and documented using an investigation team. 
 
        Compliance Audits: There are procedures to conduct regular audits of the RMP program to ensure that the program is in place and working properly. 
 
E.   Five-Year Accident History 
 
There have been no ammonia-related incidents at the Texas Freezer Inc. Dallas facility within the last five years that have resulted in any onsite or offsite impacts. 
 
F.   Description of the Emergency Response Program 
 
An emergency response program has been implemented at the Dallas facility.  This program contains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures.  The program has been coordinated with the Dallas Fire D 
ept. and the Dallas County LEPC. 
 
The emergency response program consists of the following elements: 
 
        Organization Plan and Responsibilities 
        Communications Procedures 
        Detailed Action Plans 
        First Aid Procedures 
        Emergency Medical Treatment Procedures 
        Evacuation Plans 
        Description of Outside Assistance Available 
        Site Re-Entry Procedures 
        Training Programs and Drills 
 
G.   Planned Changes to Improve Safety 
 
Several recommendations to improve safety were made for either the equipment (hardware recommendations) or the system operating procedures (procedural recommendations) when a process hazard analysis (PHA) study was carried out on February 11-12, 1999 for the  ammonia refrigeration system at the Dallas facility.  The recommended changes have been evaluated by management and are being addressed and will be resolved in a timely manner.
Click to return to beginning