Rich Products Manufacturing Corporation - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Rich Products Manufacturing Corporation (Rich Products) has implemented emergency response policies in order to meet the following objectives: 1.) To save lives. 2.) To minimize and avoid injuries. 3.) To protect the environment. 4.) To minimize property damage. Rich Products maintains an emergency response committee whose members are the designated emergency coordinators for the facility. The Emergency Response Plan provides the response organization and notification procedures, evacuation routes, ammonia health hazards, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility. This Plan is reviewed and updated at least once per year. This Plan was reviewed and updated to ensure compliance with the PSM and RMP regulations, as well as to incorporate any facility changes. STATIONARY SOURCE AND REGULATED SUBSTANCE The Rich Products facility is lo cated at 801 North Kent Street in Winchester, Virginia. This facility produces frozen bakery products such as bread, rolls, and cookies. The facility maintains refrigeration equipment which uses ammonia as the refrigerant to provide cooling for the finished products. The process, consisting of vessels, piping, valves, and process equipment, cycles ammonia through various physical states (high pressure liquid, low pressure liquid, low pressure vapor, high pressure vapor, then back to high pressure liquid) in order to provide refrigeration and freezing for product. Changes in pressure are directly related to changes in temperature: lowering the ammonia pressure lowers its temperature. Low pressure (cold) liquid ammonia provides refrigeration by removing ambient heat. Removal of ambient heat causes the liquid ammonia (contained within the system) to vaporize. Heat is later removed from the ammonia as it is condensed back into a liquid. Ammonia is used as the refrigerant in the refrigeration process. The total ammonia inventory is 26,000 pounds. HAZARD ASSESSMENT SUMMARY Worst Case Release Result Summary: The worst case release scenario is a release of the total quantity of ammonia in the largest vessel in the ammonia refrigeration system, taking into account administrative controls that limit the maximum quantity in the vessel. The High Pressure Receiver is the largest vessel in the system (with a capacity greater than 26,000 pounds of ammonia) and is assumed to contain the total charge of the system for the worst case scenario. Since the Receiver is located outside, no passive mitigation effects were taken into consideration when determining the release rate of ammonia to the outside atmosphere. The most pessimistic meteorological conditions were used: 1.5 m/s and F stability. This facility is located in an urban setting. The maximum potential downwind distance to 200 ppm was determined using Exhibit 4-4 from EPA's "Risk Management Program Gui dance for Ammonia Refrigeration Facilities", November 1998. This potential release scenario reaches off-site and may affect population receptors. No environmental receptors are affected by this potential scenario. Alternative Release Result Summary: The alternative release scenario was that of a 0.25 inch diameter leak of high pressure liquid ammonia for one hour. The quantity of ammonia released in one hour at this rate is 7560 pounds. This release could occur due to a gasket rupture, pinhole leak, flange seal leak, valve bonnet seal leak, etc. In addition, this release could occur outside; therefore passive mitigation measures were not utilized. The meteorological conditions used were 3 m/s and D stability. This facility is located in an urban setting. The maximum potential downwind distance to 200 ppm was determined using Exhibit 4-5 from EPA's "Risk Management Program Guidance for Ammonia Refrigeration Facilities", November 1998. This potential release scenario reaches off- site and may affect population receptors. No environmental receptors are affected by this potential scenario. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Administrative Measures: The facility operates in accordance with the International Institute of Ammonia Refrigeration (IIAR) guidelines and standards including the following: IIAR Bulletin 107, "Suggested Safety and Operating Procedures When Making Ammonia Refrigeration Tie-ins" IIAR Bulletin 109, "Minimum Safety Criteria for a Safe Ammonia Refrigeration System" IIAR Bulletin 110, "Startup, Inspection, and Maintenance of Ammonia Refrigeration Systems" IIAR, "A Guide to Good Practices for the Operation of an Ammonia Refrigeration System" Building Codes: The facility was constructed to comply with the current edition of all applicable codes, ordinances, regulations, and requirements of the local, county, state, and national bodies having jurisdiction. Special attention is directed to but n ot limited to: AHSI/ASHREA 15-1989 - Safety Code for Mechanical Refrigeration ANSI/IIAR 2-1984 - Equipment, Design, and Installation of Ammonia Mechanical Refrigeration Systems ANSI BB31.5-1983 - Refrigeration Piping ASME - Pressure Vessel Code, Section IX UMC - Uniform Mechanical Code UFC - Uniform Fire Code NFPA - Fire Protection UBC - Uniform Building Code, 1991, Seismic Zone 3 EMERGENCY RESPONSE PROGRAM The Rich Products facility has a Response Plan for On-Site Emergency Operations. This Plan outlines the policies and procedures in place to respond to potential ammonia alarms or releases. The facility has several trained personnel to assist in an orderly evacuation as well as to diagnose the alarm condition. The Response Plan for On-Site Emergency Operations includes the facility emergency coordinators, the staff alerting list, emergency notification list, and the hazardous materials agency notification and procedures. This Plan then proceeds to deta il the procedures for employees and management in the event of a fire, evacuation, compressor room shut down, tornado, blackout, and ammonia release/clean-up. PLANNED CHANGES TO IMPROVE SAFETY Rich Products has conducted a Process Hazard Analysis (PHA), which is a detailed engineering review of the ammonia refrigeration system. From this PHA, several recommendations were made which will increase the safety of the facility. It is expected that the recommendations will be implemented by June 1, 2000. In addition to the PHA, the Rich Products facility has worked to address safety issues as they arise in a continued effort to ensure a safe work environment. The management at Rich Products is planning to continue with this program as follows: 1. Continued maintenance program for ammonia refrigeration equipment to ensure ongoing integrity of the equipment. 2. Continue to have employee involvement in safety development. 3. Continue internal and external safety audits/inspections and implement changes as needed. |