National Steak Processors - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES National Steak Processors (NSP) has implemented emergency response policies in order 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. National Steak Processors is in the process of developing an emergency response committee whose members will have the responsibility of writing the Emergency Response Plan to be used at the NSP facility. The Emergency Response Plan will provide the response organization and notification procedures, evacuation routes, ammonia health hazards, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility. This Plan will be reviewed and updated at least once per year. This Plan will be reviewed and updated to ensure compliance with the PSM and RMP regulations, as well as to incorporate any facility changes. STATIONARY S OURCE AND REGULATED SUBSTANCE The National Steak Processors facility is located at 301 East Fifth Avenue in Owasso, Oklahoma. This facility provides refrigeration and freezing for food products. The process, consisting of vessels, piping, valves, and process equipment, cycles ammonia through various physical states (high pressure liquid, low pressure liquid, low pressure vapor, high pressure vapor, then back to high pressure liquid) in order to provide refrigeration and freezing for product. 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 later removed from the ammonia as it is condensed back into a liquid. Typical operating conditions range from approximately 7 psig on the low pressure side of the system to 160 psig on the high side. Ammonia is used as the refrigerant in the refrigeration process. The total ammonia inventory is 10,500 pounds. HAZARD ASSESSMENT SUMMARY Worst Case Release Result Summary: The worst case release scenario is a release of the total quantity of ammonia in the largest vessel in the ammonia refrigeration system, taking into account administrative controls that limit the maximum quantity in the vessel. The High Pressure Receiver is the largest vessel in the system (with a capacity greater than 10,500 pounds of ammonia) and is assumed to contain the total charge of the system for the worst case scenario. Since the Receiver is located outside, no passive mitigation effects were taken into consideration when determining the release rate of ammonia to the outside atmosphere. The most pessimistic meteorological conditions were used: 1.5 m/s and F stability. This facility is located in an urban setting. The maximum potential downwind distance to 200 ppm was determined using Exhibit 4-4 from EPA's "Risk Management Program Guidance for Ammonia Refrigeration Facilities", November 1998. This potential release scenario reaches off-site and may affect population receptors. No environmental receptors are affected by this potential scenario. In the event that this worst case scenario is realized, the NSP facility has a water diffusion tank which would be employed so as to actively mitigate this scenario. Alternative Release Result Summary The alternative release scenario was that of a 0.25 inch diameter leak of high pressure liquid ammonia for one hour. The quantity of ammonia released in one hour at this rate is 7560 pounds. This release could occur due to a gasket rupture, pinhole leak, flange seal leak, valve bonnet seal leak, etc. In addition, this release could occur outside; therefore passive mitigation measures were not utilized. The meteorological conditions used were 3 m/s and D stability. This facility is located in an urban setting. The ma ximum potential downwind distance to 200 ppm was determined using Exhibit 4-5 from EPA's "Risk Management Program Guidance for Ammonia Refrigeration Facilities", November 1998. This potential release scenario reaches off-site and may affect population receptors. No environmental receptors are affected by this potential scenario. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Administrative Measures: The facility operates in accordance with the International Institute of Ammonia Refrigeration (IIAR) guidelines and standards including the following: IIAR Bulletin 107, "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" Building Codes: The facility was c onstructed to comply with the current edition of all applicable codes, ordinances, regulations, and requirements of the local, county, state, and national bodies having jurisdiction. Special attention is directed to but not limited to: AHSI/ASHREA 15-1989 - Safety Code for Mechanical Refrigeration ANSI/IIAR 2-1984 - Equipment, Design, and Installation of Ammonia Mechanical Refrigeration Systems ANSI BB31.5-1983 - Refrigeration Piping ASME - Pressure Vessel Code, Section IX UMC - Uniform Mechanical Code UFC - Uniform Fire Code NFPA - Fire Protection UBC - Uniform Building Code, 1991, Seismic Zone 3 EMERGENCY RESPONSE PROGRAM The NSP facility has a Response Plan for On-Site Emergency Operations. This Plan outlines the policies and procedures in place to respond to potential ammonia alarms or releases. NSP's policy is to contact 9-1-1 in the event of an ammonia release. The facility has several trained personnel to assist in an orderly evacuation as well as to diagnose the alarm condition. The Response Plan for On-Site Emergency Operations includes the facility emergency coordinators, the staff alerting list, emergency notification list, and the hazardous materials agency notification and procedures. This Plan then proceeds to detail the procedures for employees and management in the event of a fire, evacuation, compressor room shut down, tornado, blackout, and ammonia release/clean-up. PLANNED CHANGES TO IMPROVE SAFETY The facility is in the process of developing an extensive process safety management program for compliance with OSHA 1910.119. This includes a Process Hazard Analysis (PHA), which is a detailed engineering review of the ammonia refrigeration system. The Process Hazard Analysis is the basis for many of the decisions and procedures associated with an effective PSM/RMP. It is a systematic effort to determine the potential hazards associated with the process and to evaluate mitigation alternatives including equipment mo difications, procedural modifications, and training. An effective PHA considers and analyzes the potential consequences associated with a release of the hazardous materials including fires, explosions, and exposure of people to toxic materials. It focuses on equipment, instrumentation, utilities, human actions, facility siting, and external events. In addition to a detailed engineering/safety analysis, NSP is preparing a complete set of operating and maintenance procedures. These procedures will be used as part of the operator initial and refresher training program. |