Land-O'Frost, Inc - Executive Summary |
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EXECUTIVE SUMMARY This report contains the Risk Management Plan (RMP) for the ammonia refrigeration system located at the Land O' Frost facility in Searcy, Arkansas. The RMP was prepared by Primatech in accordance with the requirements of the U.S. Environmental Protection Agency (EPA) Risk Management Program (RM program) regulation (Risk Management Programs for Chemical Incidental Release Prevention, 40 CFR Part 68). Mr. Edward L. Freedman, Senior Principal Engineer from Primatech, was the project manager for the preparation of the RMP. Mr. Travis O. Ellis, Safety and Health Manager, coordinated the preparation of the RMP for Land O' Frost. A. Incidental Release Prevention and Emergency Response Policies Land O' Frost recognizes management's responsibility in protecting it's employees, equipment, property, and the environment. The safety and health of all personnel is very important. The control of incidents has been and will continue to be a basic responsibility of all per sonnel in the Searcy facility. To accomplish the Company's goal in controlling incidental losses, the facility has established a Central Safety Steering Committee. One of the activities associated with the Central Safety Steering Committee has been the development and implementation of incidental release prevention and emergency response programs which are designed to comply with OSHA's Process Safety Management (PSM) standard (Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119), and EPA's Risk Management Program (RM program) regulation (Risk Management Programs for Chemical Incidental Release Prevention, 40 CFR Part 68). Mr. William Marion, Vice President, Operations, is responsible for implementation of the Risk Management Program. The purpose of the incidental release prevention and emergency response programs is to prevent the occurrence, and minimize the consequences, of significant releases of toxic substances as well as fires, explosions, and other type s of catastrophic incidents. Overall, these programs prevent incidental fatalities, injuries and illnesses and avoid physical property damage. The incidental release prevention and emergency response programs help prevent incidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment. These rules are detailed and improved as necessary. They are also communicated to and accepted by all employees at the facility. B. Stationary Source and Regulated Substances Handled Land O' Frost operates a meat processing facility in Searcy, Arkansas. The facility operates an ammonia refrigeration system to provide cooling and freezing capabilities. The amount of anhydrous ammonia (CAS #7662-41-7) contained in the system is in excess of 10,000 pounds. The maximum inventory in the system is 29,350 pounds. Since an ammonia release from the system could pose a risk of offsite public impact and the system is regulated u nder the OSHA PSM standard (29 CFR 1910.119), the system is subject to the Program 3 requirements of the EPA's RM program. The ammonia refrigeration system is designed so that liquid ammonia is pumped from one of two pump recirculation receivers (PRRs) to either the low side air units or the high side air units. At each air unit, the low temperature ammonia liquid flows across heat exchanger coils where the ammonia picks up heat, changing from a liquid to a vapor. The low pressure ammonia vapor is then sent back to the appropriate receiver to complete the cycle. Low pressure suction vapor from the low side PRR is fed to booster compressors. The compressed vapor from the booster compressors is fed to the intercooler. Vapor from the intercooler is fed to high stage compressors. During the compression phase in the compressors the temperature of the ammonia vapor will rise as the pressure of the ammonia vapor is increased. The high pressure ammonia vapor flows from the compressors via a common header to the evaporative condensers where heat is removed, turning the vapor into a high pressure liquid. The high pressure liquid from the condensers is collected in the high pressure receiver. The high pressure liquid collected in the high pressure receiver provides cooling for the compressors. Any non-condensibles in the vapor streams will be removed periodically by an automatic gas purger. The gas purger separates ammonia from the non-condensibles by condensing the ammonia. The condensed ammonia is sent to the intercooler and the non- condensibles are piped to a water bubbler to remove any trace quantities of ammonia. C. Summary of Worst-Case and Alternative Release Scenarios The worst-case release scenario at the Searcy facility involves the release of 29,350 pounds of ammonia over a 10 minute period due to the failure of the high pressure receiver. The maximum quantity in the high pressure receiver is represented by the entire vessel capacity. Under wors t-case weather conditions, ammonia could travel up to 2.0 miles before dispersing enough to no longer pose a hazard to the public. The worst-case release scenario is unlikely for the following reasons: - The worst-case weather conditions which were used for this scenario are uncommon; - Industry standards were followed for the manufacture and quality control of the receiver; - Ammonia is not corrosive in this service and the vessel is relatively new; - Pressure safety valves limit operating pressure in the receiver; - The high pressure receiver in the ammonia refrigeration system is located on a pad away from forklift traffic areas; - The facility is developing a preventive maintenance program to maintain the on-going integrity of vessels; - The facility is developing a training program that is designed to ensure that the system is operated by qualified personnel; and, - The facility emergency response procedures which enable trained personnel to respond quickly to isolate a ny potential releases. The alternative release scenario at the Searcy facility involves the release of 11,256 pounds of ammonia over a 60 minute period due to relief from two pressure relief valves on the high pressure receiver. Under alternative release weather conditions, ammonia could travel up to 0.1 miles before dispersing enough to no longer pose a hazard to the public. D. Description of the Incidental Release Prevention Program The prevention program consists of the following elements: Employee Participation: This program involves the employees in establishing and implementing the program. Employees are also involved when a process hazard analysis is conducted. The program also ensures that all employees have complete access to the program. Process Safety Information: Written information has been collected which enables the employees to identify and understand the potential hazards in the system. The written information includes the ammonia MSDS and a description of the design of the ammonia refrigeration system. Process Hazard Analysis: Formal studies using the What-If Technique have been conducted to look at the system and identify potential hazards. Operating Procedures: Written, detailed procedures have been developed which describe the steps which should be followed to safely operate the ammonia refrigeration system. Training: A training program has been developed which ensures that employees are trained on all aspects of the system and on the duties which they should perform to ensure the safe operation of the ammonia refrigeration system. Contractors: All contractors are screened and evaluated before they perform work on or near the ammonia refrigeration system. The contractors are also periodically evaluated to ensure that they perform work by following safe work practices. Pre-Startup Safety Review: A pre-startup safety review is completed for all new ammonia projects to verify that all safety programs are in place, training has be en performed, and construction has been completed according to design standards before the project is put into use. Mechanical Integrity: This program ensures that the ammonia refrigeration system is built and maintained using preventive maintenance procedures to minimize unexpected breakdowns or failures. Hot Work Permit: These procedures ensure that a signed permit is obtained prior to any cutting, welding, or burning. Management of Change: The procedures are designed to ensure that all changes made to the ammonia refrigeration system are properly reviewed. Incident Investigation: The procedures ensure that any incidents (and close calls) are investigated, reviewed, and documented using an investigation team. Compliance Audits: There are procedures to conduct regular audits of the program to ensure that the program is in place and working properly. E. Five-Year Incident History A five-year incident history must be prepared as part of the hazard assessment and included in t he Risk Management Plan (RMP). The purpose of the five-year incident history is to identify and describe each incidental release from a covered process within the previous five years that resulted in significant on-site or offsite consequences to help prevent the recurrence of similar releases. No ammonia-related incidents were identified for the Searcy facility in the previous five years which resulted in significant on-site or offsite consequences. F. Description of the Emergency Response Program An emergency response program has been implemented at the Searcy facility. This program contains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures. The program has been coordinated with the Searcy Fire Department. The emergency response program consists of the following elements: Emergency Telephone Call Log Coordination with Local Authorities Structure of Authority Emergency Team Role Descriptions Media Int eraction Procedure Emergency Notification Procedures Emergency Evacuation Instructions Personnel Accounting Procedures Notification Procedures Severe Weather Bomb Threat Fire and/or Explosion Medical Civil Strife Hazardous Materials Response Fire Prevention Contractors and Subcontractors Critique of Emergency Action Plan and Follow-up G. Planned Changes to Improve Safety Forty-three (43) changes to improve safety were recommended to the equipment (hardware recommendations) and system operating procedures (procedural recommendations) when the ammonia refrigeration system was most recently analyzed during the PHA in November 1998. The recommended changes will be evaluated and implemented as required. |