DOT Foods Inc., (Mt. Sterling) - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The new DOT Foods facility has an emergency response plan in effect. The Emergency Response Plan (Plan) is detailed in the Emergency Planning and Response section of this PSM/RMP document. This Plan was designed 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. DOT Foods maintains a safety committee whose members are the designated emergency coordinators for the facility. The 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 facility changes. STATIONARY SOU RCE AND REGULATED SUBSTANCE The DOT Foods ammonia refrigeration system has been in operation since 1991. Changes/modifications have taken place since the completion of the facility. The ammonia refrigeration process was designed and constructed in accordance with all applicable federal, state, and local regulations. The facility is located at Highway 99 South, Mount Sterling, Illinois 62353. The ammonia refrigeration system uses 28,500 pounds of ammonia for dock operations, warehouse cold storage, and freezer storage. The majority of the system is located in the new and existing machine room including vessels and compressors. The condensers are mounted on the machine room roof, the water tank is located in the existing machine room, and all of the evaporators are located in their respective cold storage rooms/areas. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS The DOT Foods facility was designed and constructed in accordance with the Uniform M echanical Code which specifically outlines requirements for the safe operation of ammonia refrigeration systems. These safety features include a water diffusion tank, ammonia sensors in the new and existing engine room as well as sensors in selected cold storage areas, and automatic shut down systems. In addition, the majority of the ammonia is maintained inside the engine room or on the engine room roof (condensers). Ammonia sensors are located throughout the facility as follows: New Engine Room (1), Existing Engine Room (1), Penthouses (4), Dock Area (10), Relief Header (1), Freezer Area (12), and Cooler Area(1). In the event a sensor detects ammonia, the detection system will alarm as follows: Warning: 50 ppm; Autodialer activates alarm light at control panel and office. Alarm: 250 ppm; Exhaust fans start. Shutdown: 5,000 ppm; Compressor shutdown and King Valve closed. In addition to the Uniform Mechanical Code, the facility will operate in accordance with the International In stitute of Ammonia Refrigeration (IIAR) guidelines. In particular, the IIAR Bulletin 110, "Startup, Inspection, and Maintenance of Ammonia Refrigeration Systems." HAZARD ASSESSMENT SUMMARY Worst Case Release Result Summary Scenario Description: Release of the maximum quantity of ammonia that can be stored in the high pressure receiver - 16,000 pounds - in 10 minutes. No passive mitigation measures were used. The most pessimistic meteorological conditions were used: 1.5 m/s and F stability. The SLAB dispersion model was used to determine the distance to the toxic endpoint of 200 ppm. This release reaches offsite and may affect public receptors. No environmental receptors were affected by this potential release. Alternative Release Result Summary Scenario Description: 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 6000 pounds. The meteorological conditions used were 3 m/s and D stability. T he SLAB dispersion model was used to determine the distance to the toxic endpoint of 200 ppm. This release reaches offsite and may affect public receptors. No environmental receptors were affected by this potential release. FIVE YEAR ACCIDENT HISTORY This facility has been in operation since 1991 and changes/modifications have taken place since the completion. There is no accident history at this facility from June 1994 through June 1999. EMERGENCY RESPONSE PROGRAM DOT Foods maintains a safety committee whose members are the designated emergency coordinators for the facility. The 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 facility changes due to the renovation of the facility. In the event that an ammonia leak is discovered, the person nearest to the leak will alert any personnel in the immediate area who are unaware of the danger, and the DOT Foods Freezer Maintenance Operator (if he/she is present). He/she will then use a portable radio to inform the Incident Commander (Facility Manager) and the other managers and contractors of the situation. The DOT Foods on-duty engineer (Refrigeration Engineer if present) will determine what procedures and personnel are necessary to remedy the problem. The following agencies will be notified: 1. Mt. Sterling Fire Department, Police Departments, and Illinois Highway Patrol; or call the Mt. Sterling Fire Department directly at 217-773-2341. 2. If an ammonia release exceeds 100 pounds (Federal Reportable Quantity CERCLA), call the National Response Center 1-800-424-8802 and the Illinois Emergency Agency at 800-782-7860. The Brown County Emerge ncy and Disaster can be contacted at 217-773-2886. 3. If additional help is required for an ammonia spill or leak, the facility can call Chemtrec - Manufacturing Chemists Association 1-800-424-9300. 4. If an employee ingests ammonia, the Poison Control Center can be reached 24 hours per day at 800-342-9293. 5. If an ammonia release spills into the sewer system, storm drain or any type of water way, contact the Brown County Emergency and Disaster at 217-773-2113. 6. If an ammonia release is significant enough to potentially cause odor complaints from neighboring facilities, contact the Brown County Health Dept. at 217-773-2714 or the Springfield EPA at 217-782-3637. 7. If there is an accident that involves a fatality or if three or more people are hospitalized for injuries, call the local Peoria OSHA Office at 309-671-7033. PLANNED CHANGES TO IMPROVE SAFETY The Process Hazard Analysis provided the mitigation measures outlined below to improve safety at the DOT Foods facil ity located at Highway 99 South, Mount Sterling, Illinois. R01 Institute an emergency response plan with specific responsibilities defined. Also include when an evacuation should be initiated as well as who is responsible for activating the evacuation. Consider using the fire alarm for ammonia evacuation notification; ensure that someone notifies fire department that the fire alarm is due to an ammonia release. R02 Coordinate with local fire department regarding whether they will assist DOT Foods with entering the engine room to shut down a release (since DOT Foods only one SCBA). Also evaluate whether the SCBA is in compliance with current standards and/or the SCBA is being inspected according to manufacturer's recommendations. R03 Conduct annual evacuation drills. R04 Keep records of the evacuation drill outlining results, recommendations, and mitigations. R05 Include in mechanical integrity program that the relief valves will be replaced/recertified every five years or w hen a release occurs. R06 Ensure that there is procedure for properly changing substations. R07 Ensure that the procedure for changing the filters is included in the Operating Procedures section of the PSM document and that the maintenance schedule in the Mechanical Integrity section of the PSM document includes the change-out frequency for these filters. R08 Ensure emergency response plan includes when to use escape masks and when an operator is allowed to re-enter a room to shut down or fix a leak. R09 Implement a contractor safety program. R10 Consider the necessity of a wind sock and where it should be located. R11 Investigate the feasibility of a backup power source (i.e. batteries, UPS, etc.). R12 Include in emergency response program what to do in the event of a low pressure liquid spill on the machine room floor (i.e. using an absorbent material for cleanup). R13 Include a test of the high level alarm and switches in mechanical integrity program. R14 Ensure that operating procedures include an oil drain procedure. R15 Ensure that there are operating procedures for this abnormal operation documented in the operating procedures section of the PSM document. R16 Consider the feasibility of installing a solenoid valve on the high pressure receiver line that would shut down in the dock evaporators if the ammonia sensor is activated. R17 Review evacuation procedures with respect to employee notification and accountability. R18 Ensure that evacuation routes and/or exit locations are posted in several areas in the building. R19 Consider implementing a procedure so that the operator notifies someone prior to going on the roof if a leak is suspected. Include the buddy system and portable eyewash stations in this procedure. R20 Evaluate the fall protection regulation with respect to the procedures that the operator must follow regarding escape from a toxic release versus fall protection that may hinder escape. R21 Ensure that there is a procedure to properly locked out condenser prior to entering for cleaning. R22 Install a disconnect at the condenser so the operator can be sure that the power to the condenser is off. R23 Check against the manufacturer's recommendations regarding the frequency of the ammonia sensor calibration requirements. R24 Consider adding a third shutoff switch (glass enclosed and located in battery room) that is accessible by a designated individual that is not an operator (i.e. on the weekends). This person will need to be designated and trained as to when to use the shut off etc. R25 Consider adding ammonia placarding to the machine room door. R26 Consider adding DO NOT ENTER and/or AUTHORIZED PERSONNEL ONLY signs to the control room door in accordance with OSHA sign and tag requirements (1910.145). R27 Examine the exit signs in the machine room to ensure compliance with OSHA's 1910.37(q), Means of Egress and Exit Signs. Consider the need for a step outside the machine room d oor that exits to the outside. R28 Consider labeling the important valves in the ammonia system (i.e. any valves referred to in the operator procedures). R29 Install a new sign in the machine room that indicates the total amount of ammonia in the system. R30 Tag the valves and lines inside the emergency relief box. R31 Consider including a summary of the emergency response plan that shows telephone numbers of emergency response personnel. R32 Label the emergency relief box with warning label such as EMERGENCY USE ONLY. In addition, ensure that the box is locked either with a break-away lock or keys distributed such that someone is always on site with a key. R33 Consider installing guardrails around the condenser catwalks. R34 Consider installing additional grading around the duct work from the freezer/cooler to the penthouse. R35 Implement and review operating procedures, including delivery, startup, shutdown, and emergency operations. R36 Develop and implement an em ergency response program and use the Emergency Response Action Plan Checklist as a guideline. R37 Check OSHA hearing protection requirements (1910.95). R38 Consider installing steps/bridges over the roof pipelines. R39 Review the air intake location at the Dry Warehouse to determine if shelter-in-place or evacuation is the best procedure in the event of an ammonia release at the freezer warehouse. |