There is not a PHA that goes by where someone ask me "why are we discussing power outages, when we have no control over them"? It is quite simple, we need to analyze what could/would happen if we loose power! Yes, loosing the power may be out of our hands somewhat, but what happens when we loose it will be 100% our responsibility. Case in hand...
Oregon cheese processing company pays EPA penalty for failing to report ammonia release
Release Date: 05/23/2012
Contact Information: Hanady Kader, EPA Public Affairs, 206-553-0454,
; Suzanne Powers, EPA Emergency Response Program, 360-753-9475,
(Seattle— May 23, 2012) Columbia River Processing, Inc. failed to report an anhydrous ammonia release at its Boardman, Oregon cheese processing facility in June 2008. The company agreed to a settlement with the U.S. Environmental Protection Agency that includes a $42,435 penalty.
On June 30, 2008, an electrical storm caused power surges that disrupted the computers and compressors that control the ammonia system at the facility. The computer failure caused a pressure relief valve to open, releasing nearly 2,500 pounds of ammonia into the environment, according to the EPA settlement. Columbia River Processing failed to immediately notify local and state agencies about the release. No injuries were reported at the time of the incident.
According to Wally Moon, EPA Preparedness and Prevention Unit Manager in Seattle, these cases are about protecting workers, emergency responders and the community. “When unintended chemical releases occur, every minute counts,” said EPA’s Moon. “Emergency responders need to be notified promptly to react effectively.” Ammonia is a pungent, toxic gas that attacks skin, eyes, throat, and lungs and can cause serious injury or death. The ammonia release and the failure to notify appropriate agencies are violations of the federal Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and the Emergency Planning and Community Right-to-Know Act (EPCRA).
So we may not be able to prevent "loss of power", but we can certainly PROTECT assets and MITIGATE consequences in the event of a power loss. There are just too many uncontrollable variables to PREVENT this deviation from occurring, but there are many options available to use to PRTOTECT our assets and MITIGATE the consequences. One such method is to utilize an emergency power supply for critical components. This emergency power supply may be as small as a Uninterruptible Power Supply (UPS) or as large as a diesel generator; it will all depend on how many critical components need emergency power and what their power demands are.
It is true that installing a large diesel generator is an expensive project, but one of our clients did so about 9 months before Tropical Storm Ike came up through Ohio knocking out power for weeks. This client could not operate fully under emergency power but the system did allow for their refrigeration process to remain in operation and maintain temperature in critical areas for the 6 days they were without power. Not only did the enmergency generator prevent the loss of millions of dollars of inventory, it minimized the disruption to their business by allowing them to start up productiondays ahead of their competitors. Plant engineer even claims that the business picked up some new business from competitors because of their ability to fill orders so much quicker than others in the area.
So basically this means our PHAs should include a review of the consequences if power is lost to our covered process and/or the critical utilities that are utilized as safe guards within our process. If the consequences are a release of the HHC/EHS, serious consideration should be given to back-up emergency power supplies. This hazard review should consider the length of time power is loss and the number of times "loss of power" occurs in a year. We should ALWAYS assume the event will occur at the worst time and last for a couple of days (especially for our friends in Hurricane territory). The loss of power may be from a lighting strike - but it may also be from an ice storm, tornado, or hurricane - in which case it may be many days the process is without power.
Just ask... without power what happens to my process? Would we be able to control the HHC without power on the "hottest"/"coldest" day of the year? Without any power/control, what would stop a release from my process? This is often times not a popular discussion to be had - BUT WE HAVE TO HAVE THE DISCUSSION or we may be caught red handed in the next power outage.
For information on EPA's Emergency Planning and Community Right to Know Act, visit http://www.epa.gov/compliance/civil/epcra/epcraenfstatreq.html
For more about toxic effects of Anhydrous Ammonia (NIOSH GUIDE): http://www.cdc.gov/niosh/npg/npgd0028.html
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