Modern Storage Company - Executive Summary |
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Executive Summary This is to inform all interested persons, including employees that Modern Storage Company is complying with OSHA's Process Safety Management Standard (called Process Safety Management or PSM), Title 29 Code of Federal Regulations (CFR) 1910.19, and EPA's Risk Management Program regulations (called RM Program), Title 40 CFR Part 68, to deal with the risks involved with the storage, handling, and processing of hazardous chemicals. In this way we promote plant, worker, and public safety. These programs enable our facility 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. Modern Storage Company provides refrigerated warehouse storage to the public. Anhydrous ammonia (CAS 7664-41-7) is used as the refrigerant fluid. Modern Storage is subject to the EPA RM program because its refrigeration system contains more than 10,000 pounds of anhydrous ammonia. Our safety programs are applied to any activity involving hazardous chemicals including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. Any group of vessels which are interconnected and separate vessels which are located such that a hazardous chemical could be involved in a potential release shall be considered a single process. Our safety programs prevent accidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment. These rules are detailed and improved as necessary. They are also communicated to and accepted by all employees at the facility. A worst-case release of ammonia has been identified resulting from a failure of a high pressure vessel in a rooftop evaporator containing 728 pounds of ammonia. During in a ten minute period all the vessel's contents are estimated to be released. Under worst-case weather conditions, ammonia could travel 0.50 mile before dispersing enough to no longer pose a hazard to the public. This scenario is unlikely for the following reasons: worst-case weather conditions are uncommon; industry standards for manufacture and the quality control of pressure vessels; ammonia is not corrosive in this service; pressure relief valves limit operating pressure in this vessel; the accident prevention program in place at the facility including the mechanical integrity program for regular maintenance, inspection and testing, and replacement of equipment, if necessary; installed ammonia sensors in the system to warn of leaks; alarms and the auto-dialing system in place to warn operating personnel of process upsets; and the emergency response plan and equipment in place at the facility. An alternative release scenario with potential off-site impacts has been identified inv olving a pin hole release from the same rooftop evaporator pressure vessel. Under common weather conditions, ammonia could travel 0.09 mile before dispersing enough to no longer pose a hazard to the public. This scenario was chosen because it could result from a smaller, and thus potentially more likely, failure than in the worst-case scenario. This scenario is unlikely for the same reasons as the worst-case scenario. Modern Storage Company's accidental release prevention program includes a process hazards analysis for the ammonia refrigeration system, development and implementation of standard operating procedures (SOPs), periodic equipment inspection, regular maintenance, equipment replacement as needed, process area detection for ammonia, and alarm systems. SOPs include normal startup, operation and shutdown; emergency shutdown; hot work permit program; and lockout/tagout procedures. There have been no accidental releases of ammonia in the past 5 years. In case of an emergenc y, Modern Storage Company will notify the South Greenville Fire Department. Modern Storage Company employees will not respond to accidental releases and, as such, does not maintain a facility emergency response plan pursuant to EPA RM Program regulations (68.90(b)). Currently, Modern Storage Company plans to replace all safety pressure relief valves, install a check valve in system charging line, and install backup water supply to evaporative condensers. |