PYA/MONARCH - ZEBULON - Executive Summary
EXECUTIVE SUMMARY |
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 Zebulon, NC 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 new facility for over 2 = years, operated within the Raleigh, NC community area for over 30 years providing food products and presently provides over 350 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 environment
al 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, contains a maximum amount of 12,950 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 scenario is the rupture of the large
st 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, 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 33 % 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 1 % of the time during the year.
Alternative Release Scenario
A more realistic release scenario (alternative release) was developed by PYA/Monarch taking into consideration the 2 = 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 minimized. These analyses were conducted u
nder 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, the alternate release scenario shows that no offsite receptors (residences, businesses, arenas, schools, etc.) are impacted.
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 releas
es of anhydrous ammonia, 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
High and low level alarms 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 each workday 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 p
erformed 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, regular
ly scheduled audits are performed 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 2 = years the facility has been in operation, PYA/Monarch has not experienced any accidental release of anhydrous ammonia from the ammonia refrigeration system.
Emergency Response Program
PYA/Monarch has a general emergency response plan that speci
fies 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 and other appropriate emergency response personnel.
4. Notification of qualified ammonia refrigeration contractor to assist in controlling the release/ implement mechanical repairs
5. Alert Local Emergency Planning Committee
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 transportation maps for response agencies.
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 the following methods:
7 Emergency broadcasts on designated radio and television stations
7 Police and fire vehicles equipped with public address systems
7 Public notification of residents
7 Phone calls to any large surrounding businesses, recreational arenas, etc.
PUTTING IT IN PERSPECTIVE
The worst case release, as defined by the EPA, equals the total contents of our largest vessel released within ten minutes and the alternate release is based on a release from an evaporator pipe for five minutes. T
here has never been a release at this site in excess of approx. one pound.