PYA/MONARCH - MONTGOMERY - Executive Summary |
|
EXECUTIVE SUMMARY PYA/Monarch Montgomery, AL Background Data In accordance with Title 40 of the Code of Federal Regulations Chapter 68 (40 CFR 68) promulgated by the Environmental Protection Agency (EPA), PYA/Monarch submits this Risk Management Plan (RMP) for operations at their Montgomery, AL facility. PYA/Monarch is a food distribution company, distributing food products to various schools, hospitals, restaurants, military installations, etc. PYA/Monarch has been in operation at this facility for over 33 years, and the original company has operated within the Montgomery community area for over 125 years providing food products and presently provides over 475 jobs to the local community. Accidental Release Prevention and Emergency Response Policy PYA/Monarch is committed to protecting the health of its employees, the surrounding community, and the environment. It is PYA/Monarch's policy to manage a safe and healthy workplace, protect the environment and maintain compliance with safety, health and environmental regulations: 40 CFR 68 as well as Occupational Safety and Health Organization (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Federal Regulations, Chapter 1910, Section 119 (29 CFR 1910.119). Stationary Sources and Regulated Substances PYA/Monarch uses anhydrous ammonia, (the 112(r) regulated substance), as a refrigerant to maintain the cooler and freezer sections within the required range of operating temperatures for the stored food products. This is a refrigerant that does not harm the earth's ozone layer. PYA/Monarch's refrigeration system, consisting of receivers, compressors, evaporators, condensers, and piping, can contain a maximum amount of 12,622 pounds of anhydrous ammonia. Worst Case Release Scenario As required by 40 CFR 68 Subpart B, PYA/Monarch has evaluated a worst-case release scenario for anhydrous ammonia using the parameters specified by the EPA. PYA/Monarch's worst-case release scenar io is the rupture of the largest single receiver when filled to 80% capacity (maximum fill capacity allowed by engineering controls) over a 10-minute period. Using the EPA's RMP*Comp program - (version 1.06), the release scenario has off-site impacts. . The worst-case release scenario was developed following EPA regulations and is not considered to be a likely release scenario. During normal operations, PYA/Monarch maintains the receivers at no more than 40% capacity. Only during pump-down operations do the receivers have the potential to be filled to 80% of capacity. The receivers are operated in pump-down mode approximately one time during the year. Alternative Release Scenario A more realistic release scenario (alternative release) was developed by PYA/Monarch taking into consideration the 5 year history of the operation's experience and the hazards identified in the process hazard analyses (PHA's) conducted to ensure that PYA/Monarch's hazards are identified and mini mized. These analyses were conducted under the Occupational Safety and Health Organization (OSHA) Process Safety Management (PSM) regulations. The most likely release scenario identified by PYA/Monarch would be a release caused by a forklift impacting one of the on-site evaporators located inside the plant. In developing the release parameters of this alternative scenario, PYA/Monarch considered the area of highest lift truck traffic near an evaporator, rupture of the largest pipe connected to the evaporator, the average response time of the facility's personnel to reach shutdown equipment, and the mitigation provided by the building structure. Using EPA's RMP*Comp program - (version 1.06), the release scenario has minimal off-site impacts. Accidental Release Prevention Program The ammonia refrigeration system is designed and constructed in accordance with recognized codes for ammonia mechanical refrigerating systems. To prevent and mitigate accidental releases of anhydrous ammoni a, PYA/Monarch has implemented several precautionary measures, such as process/equipment controls, standard operating procedures, preventive maintenance programs, employee training, audit programs, etc. PYA/Monarch has developed and implemented a PSM program pursuant to OSHA regulations and as such, has evaluated the system for the potential of anhydrous ammonia releases. PYA/Monarch uses a variety of safety equipment and procedures to prevent accidental releases. Some of the typical safety equipment and systems used at the facility are: 1.Computer monitoring systems that monitor the operation of the entire refrigeration system, 24 hours a day, seven days a week. This system will trigger alarm systems to indicate out of specification conditions. 2. Compressor monitors which track pressures, temperatures, etc. that will initiate an alarm and shut the system down if limits are exceeded. 3. Ammonia leak detectors which trigger alarms if a leak is detected 4. High and low level a larms and automatic shutdown systems associated with the ammonia tanks. 5. Relief valves to handle unexpected rises in temperature or pressure. 6. Manual shutdown switches located in several areas of the facility 7. Automatic fire alarms and fire sprinkler system in the ammonia room and the entire facility. 8. The entire refrigeration system is inspected daily by facility personnel. 9. Preventative maintenance is performed on the refrigeration equipment meeting or exceeding the equipment manufacturers required frequency. 10. Qualified outside ammonia refrigeration contractors inspect the system and perform any non-routine repairs 11. Any incidents, including small leaks or drips, are investigated and actions developed to prevent re-occurrences 12. Operating employees and contractors are trained in safe ammonia system operation plus in their respective duties in case of a problem or emergency. Response drills are conducted. 13. Routine audits/inspections are performed by PYA/Monarch and others to ensure correct procedures are followed. PYA/Monarch has developed standard operating procedures for the safe implementation of the applicable functions their employees perform and uses qualified ammonia refrigeration contractors to perform required repairs, etc. These safety procedures are reviewed and certified as current and accurate on at least an annual basis. Pursuant to written management of change procedures established by PYA/Monarch, any changes to the operating procedures are to be communicated to affected employees. PYA/Monarch understands that maintaining the refrigeration system in good working order is essential to preventing accidental releases; and has implemented a preventative maintenance program. The preventative maintenance program is scheduled to meet or exceed the equipment manufacturers required frequency. To ensure that PYA/Monarch's control measures are effective in maintaining the safe operation of the plant, regularly scheduled audits are per formed on the ammonia refrigeration system: In accordance with the PSM program, PYA/Monarch conducts detailed PSM compliance audits every three years. Each audit incorporates review of process safety information, process hazard analysis, operating procedures, training programs, system mechanical integrity, management of change, pre-start up review procedures, compliance audit procedures, incident investigation procedures, employee participation programs, hot work permit procedures, and contractor safety procedures. In addition, the facility is routinely inspected by the qualified ammonia contractors, the local fire department, the property insurance carrier, etc. Five - Year Accident History Over the last 5 years, PYA/Monarch has experienced only one accidental off-site release of anhydrous ammonia from the ammonia refrigeration system. This release did not cause any on-site death, injury or significant property damage, or known off-site death, injury, property damage, environm ental damage, or sheltering in place. During a maintenance procedure, approximately 400 pounds of ammonia was released on 8/27/94 due to an improperly sized relief valve. Some of the released gas was sucked into fans at a neighboring facility. As a precautionary measure, five employees from that facility were checked and released from a local emergency room. All relief valves were inspected and replaced as required. Emergency Response Program PYA/Monarch has a general emergency response plan that specifies actions to be taken in the event of a release. These include: 1. Notification of appropriate on-site personnel to shut down the system 2. Sounding of alarms for employee evacuations 3. Notification of local fire department, Haz. Mat. response teams, the Local Emergency Planning Committee and other appropriate emergency response personnel. 4. Notification of qualified ammonia refrigeration contractor to assist in controlling the release/ implement mechanical repairs The specific emergency response activities would depend on the cause and size of the release and would be performed under the direction of the senior professional response person on the scene - (fire chief, etc.) There is no trained emergency Haz. Mat. Response team on site. To ensure that the local, professional Haz. Mat. Emergency Response personnel are familiar with the PYA/Monarch emergency response procedures, they have toured the facility, viewed the ammonia equipment and have reviewed these procedures. To plan for an ammonia release with off-site effects, PYA/Monarch plan includes procedures/equipment to mitigate the release, procedures to inform local response agencies and procedures for public communication. In addition to the above local response agencies, PYA/Monarch has arranged emergency response assistance with a local clean-up contractor. In the event of an anhydrous ammonia release with off-site effects, the general public will be warned using one or more of th e following methods: 7 Broadcasts through local news media channels, initiated by the LEPC. 7 Police and fire department notifying local residents 7 Phone calls to any large surrounding businesses, etc PUTTING IT IN PERSPECTIVE The worst case release, as defined by the EPA, was calculated showing an ammonia release of approximately 50% of the total system contents and the alternate release was calculated as a release of approximately 25% of the system contents. The only release at this site had minimal off-site consequences and was only approximately 3% of the total system contents. |