Chief Wenatchee, Inc - Executive Summary |
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A. Chief Wenatchee's, Inc. (hereafter referred to as Chief Wenatchee) accidental release prevention policy involves a unified approach that integrates technologies, procedures, and management practices. It is the policy of Chief Wenatchee to adhere to all applicable federal and state safety and environmental regulations. Chief Wenatchee's emergency response policy involves the preparation of response plans and training of employees. Chief Wenatchee has trained its refrigeration personnel, along with certain maintenance and other personnel, in hazardous materials response (24 hours). This training includes emphasis on anhydrous ammonia, in addition to other requirements set forth in 29 CFR 1910.120(q) and WAC 296-62, Part P (HAZWOPER). At Chief Wenatchee anhydrous ammonia is used on-site. Ammonia is considered hazardous by EPA and is listed on the Extremely Hazardous Substance (EHS) list. Chemical properties of ammonia make it necessary to observe certain safety precautions in hand ling ammonia in order to: 7 Prevent unnecessary human exposure 7 Reduce the threat to our personnel 7 Reduce the threat to the community B. Chief Wenatchee is a fruit processing and cold storage facility, located in the city of Wenatchee, county of Chelan, state of Washington. The regulated substance used at Chief Wenatchee is anhydrous ammonia (CAS# 7664-41-7). The anhydrous ammonia is used as a refrigerant. There is 18,000 pounds of anhydrous ammonia in the entire system. Chief Wenatchee uses other hazardous substances on-site, however they do not meet or exceed the threshold limits established in 40 CFR 68.130. However, Chief Wenatchee believes in the concept set forth in the "General Duty Clause" of the Clean Air Act. To this effect, Chief Wenatchee has established policies, procedures and training to reduce the risk of an accidental hazardous substance release for the safety of its employees and surrounding areas. C. The off-site consequence analysis considers two ammonia release scenarios identified as "worst case" and "alternative" scenarios. The worst case scenario is defined by the Environmental Protection Agency (EPA), which states that "the owner or operator shall assume that the maximum quantity in the largest vessel is released ". The alternative scenario is defined as "more likely to occur than the worst case scenario". Worst-Case Scenario - Failure of the largest vessel would release 5,300 pounds of anhydrous ammonia. The release would occur inside the compressor room; its walls are not in direct contact with the outside. The distance to the toxic end-point of 0.14 mg/L is 0.9 mile. The "risk radius" extends past the boundaries of the plant, into public receptor areas. Distance was determined by use of RMP-COMP. Alternative Release Scenario - Several alternative scenarios were modeled, using ALOHA, version 5.2.1, however a release from the bottom (liquid space) of the receiver, under normal operating conditions, was chosen. This alt ernative scenario provided the greatest risk radius, 770 yards. The mitigating effect from being enclosed inside a building was used, reducing the computed release rate by 20%. D. Chief Wenatchee's accidental release prevent program is based on the following key elements: 7 Training of personnel 7 Preventative maintenance program 7 Use of safety equipment 7 Use of accurate and effective written operating procedures The ammonia refrigeration system was installed to standards and local codes at the time of installation. Piping and equipment is secured and protected; compressor (engine) room doors are tight fitting and open outwards. Other safety systems Chief Wenatchee utilizes include: 7 Computerized controls, which can be operated remotely 7 Suction trap hi-level float 7 High discharge pressure shut down 7 Low suction pressure shut down 7 High discharge temperature shut down 7 Oil pressure failure shut down 7 High amperes shut down 7 Automatic timer to prevent short cycling 7 Oil f ilters plugged shut down 7 250 psi relief valves on high pressure side, to prevent overpressure situations 7 150 psi relief valves on low pressure side, to prevent overpressure situations Operating Procedures and checklists have been prepared by Chief Wenatchee to be used by employees performing operational functions. Procedures are kept in the engine room and the refrigeration engineer's office. These procedures include: 7 Pre-start up procedures 7 Routine operations 7 Maintenance 7 Response to major and minor releases 7 emergency action plan E. Chief Wenatchee has not had any accidents involving ammonia in the last five years. F. In addition to the operating procedures, Chief Wenatchee has established Emergency Response Guidelines for releases involving ammonia. These procedures are part of the ongoing training. Chief Wenatchee has organized and trained employees in 24-hour response (to ammonia releases) training and key employees have received Incident Command Training. G. C hief Wenatchee plans to install ammonia monitors/detectors in the engine room. The engine room ventilation fan will be connected to an ammonia monitor so that the fan will activate upon reaching a threshold less than 40,000 parts per million, which is < of ammonia's lower explosive limit (LEL). The actual threshold will be at, or less than, 1,000 ppm and the monitor will be connected to the auto dialer, to alarm refrigeration personnel of a potential ammonia release. |