H & M FOOD SYSTEMS - Executive Summary |
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H & M Food Systems is a food processing facility (SIC 2013) located at 601 East 3rd Street, Lampasas, Texas. The facility operates an ammonia refrigeration system as part of the process. Anhydrous ammonia is the RMP chemical of concern. H&M Food Systems has been at this location since 1993. The facility was operated under other ownership prior to this date. The current capacity of the system is approximately 30,000 pounds. The facility has never experienced a significant incident. The refrigeration system is designed, installed and operated in accordance with the applicable guidelines and standards of the American Society of Mechanical Engineers (ASME), the American National Standards Institute (ANSI), the International Institute of Ammonia Refrigeration (IIAR), the American Society of Heating, Refrigerating, and Air-conditioning Engineers, Inc. (ASHRAE), and the Occupational Safety and Health Administration (OSHA). Qualified outside contractors are used for construction and ma jor repairs or modifications to the system. The system is continuously monitored and inspected by technicians that are trained, qualified, and experienced in ammonia refrigeration. Technicians are qualified in accordance with the requirements of the Refrigeration Engineers and Technicians Association (RETA). H&M Food Systems and the refrigeration staff are all current members of RETA. The system is inspected periodically for proper operation 24 hours per day. Walking inspections are conducted on intervals not longer than 4 hours. System parameters are logged in a permanent record, as are routine maintenance activities. The system is equipped with a series of redundant failsafe devices, sensors, and overrides. In the event a malfunction occurs that could result in an ammonia release, these protective devices shut the system down. The system can't be restarted until the cause of the shutdown is identified and corrected. In addition to operational training, designated technician s and management personnel on each shift have been trained as Incident Commanders in accordance with the provisions of the OSHA Hazardous Waste Operations and Emergency Response (HAZWOPER) rule as stated in 29 CFR 1910.120. A minimum of two (2) Incident Commanders is onsite at all times. Refrigeration Technicians and other staff members are also trained to respond to accidental releases of ammonia from the system. H&M Food Systems has equipment and supplies on-hand to permit trained employees to aggressively locate and control a release, should it occur. The facility conducts a full incident response drill and exercise every year. The facility has implemented a Process Safety Management Program in accordance with applicable OSHA regulations (29 CFR 1910.119). This plan is reviewed annually and updated as necessary. All significant changes to the system are reviewed in accordance with the PSM / RMP management of change provisions in the facility's plan. The EPA requires the faci lity to model the potential offsite impact from a worst-case release of ammonia and an alternate release scenario. The worst-case release is based on a release from the high-pressure liquid receiver located outside the Engine Room. This could potentially release approximately 15,000 pounds of ammonia. Anhydrous ammonia is a gas at normal temperature and pressure. It may be liquefied by pressure in parts of the system. The liquid will quickly vaporize back to a gas when exposed to the atmosphere. This gas is lighter than air and rises quickly into the atmosphere with little environmental impact. Ammonia has an irritating effect on inhalation at high concentrations. Ammonia is highly water soluble. A gas cloud can be mitigated effectively with water spray. H&M can provide water spray. Additional support can be provided by the Lampasas Fire Department. The alternate release scenario involves a release from a safety relief valve. This type of incident could create a gas releas e at a rate of approximately 100 pounds per minute (the rate recommended in the EPA's RMP Guidance for Ammonia Refrigeration document). A release from most safety release valves at the facility will result in a release of less than 100 pounds per minute. H&M Food Systems has complied with the requirements of section 302 and 303 of the Emergency Planning and Community Right to Know Act (EPCRA) by notifying the State Emergency Response Commission (SERC), the Local Emergency Planning Committee (LEPC), and the Fire Department of the presence of ammonia at the site. H&M files a Tier 2 Chemical Inventory each year with the LEPC and the Fire Department, and files a Toxic Release Inventory with the SERC and the LEPC, as required by sections 311, 312, and 313 of EPCRA. The facility's emergency response plan includes procedures for notifying the proper agencies in the event of a reportable release of ammonia. A release of 100 pounds or more must be reported to the National Response Center, the SERC, and LEPC, in accordance with section 304 of EPCRA. The Fire Department has been provided with a copy of the facility's emergency response plan. |