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SSWI INC

Parent Companies:
EPA Facility ID:
100000196771
Other ID:
Facility DUNS:
0

Location:

Address:
510 Pride Boulevard
Hammond, LA 70401
County:
TANGIPAHOA
Lat / Long:
30.517, -90.423 (Get map)
Method:
Census Block - 1990 - Centroid
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
SSWI INC
Phone:
(985) 350-6133
Address:
510 Pride Boulevard
Hammond, LA 70401
Foreign Address:

Person responsible for RMP implementation:

Name:
Gary Zicarelli
Title:
Safety Manager
Email:

Emergency contact:

Name:
Bob Palm
Title:
Warehouse Manager
Phone:
(985) 350-6133
24-hour phone:
(985) 634-0354
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Tangipahoa Parish LEPC
Full-Time Equivalent Employees:
7
Covered by OSHA PSM:
Yes
EPCRA section 302:
No
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Sept. 17, 2012
Inspecting Agency:
EPA
Using Predictive Filing:
No

Processes:

Cold Storage
RMP ID:
1000040964
CBI claimed:
No
Program Level:
3
NAICS:
Refrigerated Warehousing and Storage (49312)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
24,600
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Philip Curwick
Address:
16851 Jefferson Highway
Suite 6D
Baton Rouge, LA 70817
Foreign Address:

Phone:
(225) 754-0405

Latest RMP Submission:

Date:
March 20, 2013
Type:
Resubmission
Reason:
Voluntary update (not described by any of the above reasons)
Registered:
No
RMP ID:
1000033577

Deregistration:

Date:
Effective Date:
Reason:
Source reduced inventory of all regulated substances below TQs
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Cold Storage)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Cold Storage)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Cold Storage)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Cold Storage)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Cold Storage, Refrigerated Warehousing and Storage (49312)
Prevention Program ID:
1000035776
Safety Review Date
Feb. 5, 2013, since latest RMP submission
PHA Update Date
Jan. 10, 2013, since latest RMP submission
PHA Techniques
  • What if
  • Checklist
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Fire Walls
  • Enclosure
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 11, 2013, since latest RMP submission
Training Review Date
Feb. 5, 2013, since latest RMP submission
Maintenance Review Date
Feb. 5, 2013, since latest RMP submission
Maintenance Inspection Date
Feb. 5, 2013, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
May 15, 2006
Management of Change Review Date
Feb. 5, 2013
Pre-startup Review Date
May 15, 2006
Compliance Audit Date
Jan. 3, 2013
Compliance Audit Change Completion Date
Jan. 10, 2014
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Feb. 5, 2013
Hot Work Review Date
Feb. 5, 2013
Contractor Safety Review Date
Feb. 5, 2013, since latest RMP submission
Contractor Safety Eval. Date
Feb. 5, 2013, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
No
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
No
Plan Review Date:
Response Training Date:
None
Local Response Agency:
Local Response Agency Phone:
(985) 542-3473
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
No
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
No
Subject To - Other:

Executive Summary

A. Description of Accidental Release Prevention and Emergency Policies

SSWI INC of Hammond Louisiana recognizes management's responsibility in the protection of its employees, equipment, property, the community, and environment. The control of accidents has been and will continue to be a basic responsibility of all personnel in the company.



To accomplish SSWI of Hammond La's goal in controlling accidental losses, the facility has established a comprehensive Safety Program that not only includes government mandated safety programs, but also includes safety programs and activities that have been identified industry wide for the prevention of accidents. The objectives of SSWI of Hammond Louisiana's Safety Program are to achieve maximum productivity, efficiency and safety performance.



One of the activities associated with SSWI of Hammond Louisiana's Safety Program is the development and implementation of accidental release prevention and emergency response program. These programs are designed to comply with OSHA's Process Safety Management (PSM) standard (Process Safety Management of Highly Hazardous Chemicals, Title 29 Code of Federal Regulations 1910.119) and the EPA's Risk Management Program (RMP) Regulation (Risk Management Programs for Accidental Release Prevention, Title 40 Code of Federal Regulations Part 68). SSWI Inc of Hammond La's Safety Manager is responsible for the management of the accidental release prevention and emergency response programs.



The purpose of the accidental release prevention and emergency response program is to prevent the release of ammonia and to minimize the consequences of ammonia releases. The accidental release prevention and emergency response program is also established for the prevention and response to fires, explosions, terrorist acts, and other types of incidents that may result in catastrophic accidents. As a whole these programs are designed to prevent accidental fatalities, injuries and illnesses, and any physical
damage.



B. Stationary Sources and Regulated Substances Handled

The facility operates a [NAICS#49312 (Refrigerated Warehousing and Storage Facility)] freezer warehouse at 510 Pride Boulevard Hammond, La 70401. An ammonia refrigeration system is in operation to maintain the storage and holding temperatures for neopryne products.



The facility operates an (compound) ammonia refrigeration system, which provides cooling throughout the facility. The amount of anhydrous ammonia (CAS#7664-41-7) contained in this refrigeration system is in the excess of the threshold quantity of 10,000 pounds. SSWI of Hammond Louisiana's maximum potential ammonia inventory in the refrigeration system is calculated to be approximately 24,600 pounds. However, the actual ammonia inventory in the system is estimated to be approximately 11,900 pounds. Due to the volume of ammonia and with the remote possibility of a release of ammonia from the refrigeration system, which could pose a risk to offsite public receptors and have offsite impacts, our refrigeration system is subject to the Program Level 3 requirements of EPA's RMP.



C. Summary of Worst-case and Alternative Release Scenarios

1. Worst-Case

The SSWI Hammond Warehouse is equipped with a two-stage ammonia refrigerating system. For ammonia refrigeration systems, a storage vessel or high-pressure receiver is likely the source of the worst-case release quantity. The facility's ammonia refrigeration system consist of low stage and high stage compressors, whereby ammonia travels throughout the circuit from the discharge of the compressors, through the evaporative condensers, to the high pressure receiver (HPR-

1). The system was not designed with a separate ammonia storage vessel and therefore the entire contents of the system will either drain down or be pumped down to this receiver, if necessary, to remove ammonia from the system. The high pressure receiver is the largest vessel in the SSWI Hammond Warehouse refrigeration system.
Pressures in the high pressure receiver range from approximately 100 to 200 pounds per square inch gage (psig). Under these conditions it was assumed that, as required by the RMP regulations, the entire contents of this vessel would be released in a catastrophic failure. The high pressure receiver is located within a portion of the warehouse structure, i.e., "a building"; however, HPR-1 is positioned near an opening in the building (i.e., a door to the exterior). The potential quantity of ammonia that could be released in the worst-case release scenario was based on a conservative estimate of the maximum shell capacity of the high pressure receiver, HPR-1. Administrative controls and normal operating activities would likely be cause for less ammonia in HPR-1, but a conservative approach was used to model the offsite consequences in a worst-case scenario. Since HPR-1 is located near a door in the warehouse building and makeup air vents for the room ventilation system, it was assumed that the entire contents of the vessel will be released through these openings when modeling this scenario; therefore, no passive mitigation measures were considered for the worst-case scenario. The calculated weight released during the worst-case scenario was found to be approximately 8,850 pounds of anhydrous ammonia.



The worst-case scenario is unlikely for the following reasoons:

-Industry standards and quality controls were followed in the design and construction of the equipment in the ammonia refrigeration system.

-Ammonia is not corrosive in this process.

-Pressure safety relief valves limit the operating pressures in this receiver.

-The facility utilizes a preventive maintenance program to maintain the on-going integrity of the vessel.

-The facility has a training program that insures only qualified personnel operate the system.

-The facility requires that all PSM elements as well as company maintenance policies be followed.

-The facility has coordinated its emergency
response system with the local fire department.



2. Alternative Release Scenarios

A. First Alternate Release Scenario

Transfer Hose Alternative Release Scenario - Anhydrous ammonia is delivered to the SSWI Hammond Warehouse facility by a local supplier that hauls it by motor truck transport. The tanker trucks reportedly utilized to haul ammonia include a small tanker (6,500-gallon capacity) and a larger tanker (9,055-gallon capacity). However, due to state and federal highway gross weight limits (tractor and tanker) the transporter only hauls a reported 85 percent (%) of the small tanker and 70% of the larger tanker (i.e., 85% of 6,500 gallons = 5,524 gallons and 70% of 9,055 gallons = 6,338 gallons). The tankers trucks used are not compartmentalized. The tanker trucks have passive mitigation systems that would shut down transfer in the event of a low-pressure drop; however, this scenario assumes that this mitigation system also fails during the release.For this alternative scenario, it was assumed that the transporter was making multiple

deliveries and stopped at SSWI first (i.e., with a full load) since the ammonia supplier is located in close proximity to the warehouse. It was assumed that the hose on the transfer truck developed a leak and approximately one-tenth of the load was released to the ground before being discovered and the discharge valve shut off. To be conservative the largest "full load" tanker, or 70% of 9055 gallons = 6,338 gallons, was being used during delivery the day of the release. The calculated pounds released during this alternative scenario would be approximately 5,150 pounds of anhydrous ammonia.



B. Second Alternate Release Scenario

Process Piping Alternative Release Scenario - Process pipework runs along the roof of the SSWI Hammond Warehouse to evaporative condensers and penetrates the roof at various locations to discharge ammonia to the various evaporators. A number of release areas from process pipework were considered in t
his scenario. It is conceivable that an ammonia leak can occur from almost any piping component, i.e., a valve, flange, fitting, etc; however, based on discussion with the ammonia maintenance contractor, the most common leak in an ammonia system, such as the one utilized by SSWI, would be a rust hole leak from a weak weld or erosion at an elbow. It is assumed that gas would be released from a one eighth-

inch diameter hole in the piping. When gas stored under pressure in a closed vessel is discharged to the atmosphere

through a hole or other opening, the gas velocity through that opening may be choked (i.e., attain a maximum velocity).

Using the equation for estimating the unmitigated release rate of a toxic gas from a hole in a pipe, provided in Chapter 7.1.1 for Gaseous Releases in EPA's Risk Management Program Guidance for Offsite Consequence Analysis, March 2009, the release rate from a failed pressure regulator was calculated as 1.66 pounds per minute, based on the following assumptions for equipment pressure (180 pounds per square inch) and temperature (160 degrees Fahrenheit). This method neglects the effects of friction along the pipe and, therefore, provides a conservative estimate of the release rate.

The equation provides an estimate of the initial release rate. It overestimates the overall release rate, because it does not take into account the decrease in the release rate as the pressure in the equipment decreases. Furthermore we assumed that the release would extend for some time period before being discovered. If assuming that the leak developed during the weekend, it could be two to three days before it was detected. Over the course of 48 hours (2,880 minutes)

the total amount of ammonia that would leak would be approximately 4,800 pounds.



C. Third Alternate Release Scenario

Compressor Failure Alternative Release Scenario - Another alternative scenario examined was a catastrophic failure of one of the facility's five compressors, which wou
ld result in an ammonia release. The scenario was based on the failure of a low oil level switch that resulted in compressor casing failure due to over-heating of the pump. The cavity in a compressor has very little capacity, due to the casing design and therefore, the compressor itself would release only a small amount of ammonia in the engine room. The largest amount of ammonia vapor that could potentially be released will leak (de-pressurize) from the high-stage discharge (HSD)piping that runs vertically to the HSD header and the high-stage suction (HSS) piping leading to the compressor from the HSS header, in the machine room. The release amount was estimated to be 100 pounds.



The alternate release scenarios are unlikely for the following reasons:

-SSWI of Hammond La has policies to enforce only that competent personnel work on the system and has the power to remove any offending employee and/or contractor from the companies payroll and or contracts.

-The system was designed using standard practices and is maintained by rigid company standards.

-The maintenance program includes a mechanical integrity audit system.

-The maintenance program includes a shift monitoring procedure of the refrigeration system by fully trained personnel.

-Low level controls, sensors for ammonia monitoring, and maintaining a safe ammonia liquid supply to the vessels acts as active mitigation before the release poses a threat to offsite receptors.

-The piping is routed to avoid impact from traffic sources. A majority of the pipes are located on the roof.

-Forklift operators have been trained and certified by the company, and trained in the locations and operations of the ammonia refrigeration evaporators that are located within their working areas.

-Industry standards were followed for the manufacturing of the ammonia vessels, and the vessels were supplied by a reputable company meeting the guidelines spelled out in the Company's Process Safety Management's Contractors requi
rements as well as requirements for chemical suppliers.

-The facility requires that all PSM elements as well as company maintenance policies be followed.

-The facility has trained emergency response personnel and established response procedures, so on site personnel can respond quickly to isolate any potential ammonia releases.

-The facility maintains equipment to support the emergecy response teams so they can address vessel repair specific to ammonia in the event of a leak.

-Only trained and authorized personnel have access to the Ammonia System.

-House keeping and maintenance practices are enforced to keep the area and plant clear of debris.



D: Description of Accidental Release Prevention Program

The prevention program consists of the following elements:



1. Employee Participation:

This program ensures that the employees are involved in establishing and implementing the prevention program. Employees are also involved when a process hazard analysis is conducted. The program also ensures that the employees have complete access to the program on company property. Regularly scheduled meetings are held to discuss any concerns.

2. Process Safety Information:

Written information has been collected which enables the employees or members of the general public to identify and understand the potential hazards in the refrigeration system. This written information includes the MSDS program as well as a description of the design of the refrigeration system. The written information also includes the MSDS on the ammonia in the refrigeration, standards, guidelines, and basic information about the chemistry of the refrigeration system, and the thermodynamic properties of the refrigeration system.

3. Process Hazards Analysis:

A formal analysis using the What-If/Checklist Technique was conducted prior to the start-up of the system to identify potential hazards. For each Management of Change and at regularly scheduled intervals, a Process Hazard Analysis will be condu
cted and the corporate review team will review its recommendations.

4. Operating Procedures:

Written operating procedures have been developed that describes the steps to be followed to operate the refrigeration system safely. Every Management of Change and any operation involving the refrigeration system that was not previously identified will have an operating procedure developed and implemented for the actions required.

5. Training:

A training scheduled has been established and implemented which ensures that all employees understand their responsibility during an emergency situation, whether its evacuating the building, reponding to a release, or various other responsibilities during and after an ammonia release. Additional training schedules have been established and implemented for the operators of the ammonia refrigeration system.

6. Contractors:

All contractors will be screened and evaluated prior to any work on or near the ammonia refrigeration system. The contractors will also be periodically evaluated to ensure they perform their work duties safely.

All contractors that work on the refrigeration system will also be required to have an ongoing safety program that includes compliance to 29 CFR 1910.120, 1910.38, 1910.119, AND 1910.134.

7. Pre-Startup Safety Review:

A Pre-Startup Safety Review will be completed for all new ammonia projects prior to its start-up to verify that all safety programs are established, all the training has been completed by all individuals involved, and construction has been completed according to design standards and guidelines.

8. Mechanical Integrity:

A Mechanical Integrity program is established to ensure that the ammonia refrigeration system is built to the established codes and is maintained to the manufacturer's recommendations. Preventive maintenance procedures are also established to ensure the refrigeration system is maintained properly to minimize unexpected breakdown or failures.

9. Hot Work Permit:

A hot wor
k program has been established and implemented so that any cutting, welding, or burning operation on the ammonia refrigeration system must be authorized by the general manager or the maintenance manager.

10. Management of Change:

These procedures ensure that the general manager and the maintenance manager properly review all changes made to the systems.

11. Incident Investigation:

These procedures ensure that any incident (and near misses) are investigated, reviewed, and documented using an investigation team.

12. Compliance Audit:

An audit of the Process Safety Management Program and Risk Management Plan will be performed on a regular schedule to ensure that the program is being continually implemented and working properly.



E. Five-year Accident History

No ammonia release incidents have occurred at this facility.



F. Description of the Emergency Response Program

The facility is included in the local emergency response plan. However, an Emergency Response Program has been established and implemented at the facility. The program contains procedures describing how the facility will respond to ammonia leaks, as well as other emergencies, including evacuation procedures. The emergency response program consists of the following elements:

1. Organization Plan and Responsibilities

2. Communication Procedures

3. Detailed Action Plans

4. Fire Assistance Procedures

5. Emergency Medical Treatment Procedures

6. Evacuation Plans

7. Description of Outside Assistance

8. Site Re-Entry Procedures

9. Training Program and Drills

10. Risk Management Plan

11. Process Management Plan