Blue Ridge Farms, Inc., Brooklyn, NY - Executive Summary |
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RISK MANAGEMENT PLAN Blue Ridge Farms, Inc. Brooklyn, NY Anhydrous Ammonia Refrigeration EXECUTIVE SUMMARY As part of the Clean Air Act Amendments of 1990, the Environmental Protection Agency (EPA) was charged with overseeing the implementation of Section 112(r) of the Act. This section of the Act requires industrial facilities that handle large quantities of certain toxic substances or flammables to prepare a Risk Management Plan (RMP) and implement an accidental release prevention program to prevent catastrophic releases of these substances into the environment and surrounding community. The Act also provides for public communication of this RMP to establish dialog between facilities and the surrounding community concerning the risks associated the plant. This document presents the Blue Ridge Farms Inc.'s (BRF) RMP. The facility handles anhydrous ammonia as a refrigerant in an amount over the EPA threshold limit for inclusion in an RMP. The facility's release prevention pr ograms are also discussed. 1.0 Accidental Release Prevention and Emergency Response Policies One of the key purposes of the prevention program is to establish a process safety system in facilities. Process safety is a before-the-fact accident prevention system with its roots at the earliest foundations of equipment design, maintenance and operation. The facility has analyzed hazards and safeguards, and takes pro-active steps to ensure that incidents are prevented or that the consequences of an unlikely event are mitigated. BRF has established a Process Safety Management (PSM) program as part of its OSHA compliance efforts. The EPA recognizes this program in the RMP regulations. This PSM program encompasses the following, and other, elements: * Facility operator training with regard to the safe handling of toxic substances; * Performing hazards analyses on the existing ammonia refrigeration system; * Ensuring that operating procedures, manuals and engineering information on t he facility are kept up to date; * Ensuring the mechanical integrity of operating equipment through routine maintenance and inspection; and * Investigating all incidents that could have resulted in a major release or accident. Should an emergency arises, the employees are trained to muster at a safe location inside or outside of the building and called for outside responders as necessary. In addition, the facility has an emergency response plan that is coordinated with the New York City Fire Department on the response to fires or ammonia release, public sheltering, and the coordination of other support service providers such as police or paramedics. 2.0 The Stationary Sources and Regulated Substances Handled As discussed above, this RMP discusses the handling of anhydrous ammonia in the refrigeration system. The ammonia refrigeration process at BRF was used to provide cooling to different units in the facility. Liquid ammonia stored in a circulation tank is pumped through vari ous fan coil units to provide cooling through evaporation of the liquid ammonia inside the cooling coil. Ammonia vapor is then returned to the circulation tank and to a set of ammonia compressors. The compressors are used to compress ammonia vapor to 150 psig and route the gas through a set of condensers where ammonia gas is condensed to liquid. From there, the condensed ammonia is then routed to the two ammonia storage tanks. When the liquid level in the ammonia circulation tank is low, liquid ammonia is transferred from the ammonia storage tank to the circulation tank. The facility handled about 20,000 lbs of anhydrous ammonia in the refrigeration system, and the largest storage vessel has a capacity of 16,000 lbs. 3.0 RMP Offsite Consequence Analysis This section describes the "worst-case release" and "alternative case release" scenarios for the regulated toxic substance at the facility. A "worst-case release" is defined by the EPA as a release of the entire largest single- point quantity in a scenario that would create the largest offsite consequence under worst-case atmospheric conditions and a rapid release rate. The offsite consequences are determined as the distances where the released substances can reach their endpoints. That is, for toxic substances, the endpoints are defined as the concentrations that represent the maximums at which the agency believes that nearly all people could be exposed for up to one hour without serious or irreversible health affects. Since the worst-case release scenarios are based on extreme conditions, they are extremely unlikely to occur. One worst-case scenario is presented to represent all regulated toxic substances handled at the facility. The "alternative-case" scenario is presented as, although still unlikely, a more realistic scenario that could occur under abnormal conditions. At least one alternative release scenario is analyzed for each of the toxic substances registered in the RMP. The RMP presents a wo rst-case release scenario for the anhydrous ammonia handled at the facility. Based on a review of refinery information and processes, the worst-case scenario was identified as a release of all 16,000 pounds of anhydrous ammonia from the storage vessel. The potential consequences of these worst-case scenarios were analyzed using the EPA's RMP*Comp program. The results indicated that there could be off-site consequences to the surrounding community. The selected alternative release scenario for anhydrous ammonia is based on potential pipe leakage through a faulty flange. This event was identified through the hazard analysis as a potential situation that could occur in piping that is in similar services. In the RMP alternative scenario, a leak occurs at a faulty flange on the ammonia recirculation pump discharge. The leak has an equivalent hole-size of 0.25 inches in diameter. As soon as the leak develops, the pump was shut off and the leak is isolated. This active mitigation acti on takes place in less than 30 seconds after the detection of the leak; as a result, the release quantity is reduced to about 20 percent of the original flow in the pipe, resulting in a release of about 465 pounds of anhydrous ammonia before it can be mitigated. The analysis indicated that there could be consequences to the population outside the facility. 4.0 General Accidental Release Prevention Program and Prevention Steps As discussed above, the facility has been working with a PSM program under OSHA. The EPA recognized this OSHA process in the development of the RMP program. The OSHA program satisfies the RMP requirements for a prevention program. The facility's PSM program elements include: * Process Safety Information * Process Hazards Analysis * Operating Procedures * Training * Mechanical Integrity * Management of Change * Pre-startup Safety Review * Compliance Audits * Incident Investigation * Employee Participation * Hot Work Permits * Contractors The facility is in the process of implementing these elements under the OSHA standard. Some of the PSM elements have been completed such as hazard review, incident investigation, employee participation, compliance audit, pre-startup safety review, management of change, while others such as operating procedures and mechanical integrity, are still in the process of completion 5.0 Five Year Accident History In the last five years, there were no accidental releases of anhydrous ammonia that meet the criteria for inclusion in this RMP. 6.0 Emergency Response Program The facility has established an emergency response program that satisfies the RMP requirements. The emergency response program was coordinated with the local Fire Department. The emergency response program includes a spill prevention program as well as emergency response procedures specifically tailored to the accidental releases of anhydrous ammonia. In general, the facility has no capability to respond to a large scale release of a mmonia; it relies on the local Fire Department to respond to these emergency situations. In the past, the facility has conducted drills with the local Fire Department to ensure that emergency responses are performed properly and adequately. 7.0 Planned Changes to Improve Safety The PSM program at the facility has resulted in the generation of a number of recommendations to improve safety. The recommendations come from efforts such as process hazards analysis, as well as from the management-of-change process that govern changes to process plants. These recommendations have included items such as including more information on piping & instrument diagrams, adding alarms or monitors, and constructing a new blast wall. The facility plans to continue this program to improve safety and reliability. |