BONGARDS' CREAMERIES - Executive Summary |
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During the last 15 years there have been a large number of changes that have impacted this entire facility. Bongards Creamery has fallen under new management and with that management comes a committment of leadership, responsibility, and excellence. The new management is committed to a safe work environment for it's employees as well as for the families of the community. Bongards Creamery manufacturers cheese. We have a process plant, a cheese plant and a drying plant. In the process plant all ingredients are combined in one area and the packaging of the cheese takes place in another . One of the regulated threshold chemicals used in the process plant is Nitric Acid. This chemical is used for cleaning purposes and has one bulk storage container that holds about 37,875.20 pounds. The Cheese plant is where the cheese is prepared to be refrigerated. There are no regulated substances in this area that are at or above the threshold value. The next area of this facility is the dry ing plant. The drying plant is where the ingredients are prepared for use in the cheese or process plants. There are no regulated substances in this area that are at or above the threshold value. Anhydrous Ammonia is another regulated chemical at or above threshold that is being used here at Bongards'. This chemical is used in the refrigeration systems throughout the entire facility. Currently the facility is using 16,524.54 pounds of Ammonia in the coolers, air conditioning systems, condensers, evaporators and accumulators. The last regulated substance at or above the threshold quantity is propane. We have 220,000 pounds of propane on hand in two 30,000 gal. storage tanks. Propane is used throughout the entire facility for a number of purposes. The worst case senarios and alternative scenarios for each regulated substance listed were modeled on the RMP Comp. program. In the worst case senario of Anhydrous Ammonia there are no administrative controls that would limit the qua ntity of ammonia released. The passive mitigation measures would be exhaust fans that would pull the fumes out of the area at an average rate of 10,000 FPM, individually. There are pressurized alarms on the newer equipment that would aid in the notification and reaction to a release of ammonia. Another passive mitigation for the release of ammonia would be the drains and sumps that are located throughout the facility. These drains and sumps are designed to carry chemicals to an area of treatment and not into the public sewage system. The alternative senario for an ammonia release would utilize an active mitigation measure of evacuating the area. The worst case senario for the Nitric Acid storage tanks has no adminstrative controls to limit the amount of release. The passive mitigation measures are the same as for the anhydrous ammonia except for the pressurized alarms on the newer equipment, nitric acid tanks are not equipped with that feature. The alternative senario for Nitri c Acid would also be the same as the alternative senario for anhydrous ammonia regarding evacuation of the area. For propane, the worst case senario has one administrative control that is expected to reduce the amount of release. Each tank has been fitted with pressurized safety valves that are expected to engage when the release pressure gets too great. The passive mitigation measures that are being used on the two outside tanks are relief valves, which prevent the build up of pressure inside the tank. For an alternative senario, the propane tanks have an active measure of mitigation in the manual excess flow valve shut off, which would stop the release of propane completely. Bongards Creameries is regulated under the OSHA PSM rule, NFPA 58 rule and many other local and state rules and regulations. Since the change in management there has been a steady motion to bring this facility up to speed with each and every appicable safety rule and regulation. Because of our move toward s safety, we are finding out that more and more areas of our company are becoming subjected to an increasing amount of laws and regulations. These types of instances are particularly encouraging because it fuels our efforts to correct existing processes and implement needed processes. One of the most important parts of our prevention program is the increasing movement towards employee training. Our employees are being trained on a monthly basis with a rapidly growing job transfer rate. At the same time, we are updating and formalizing our equipment and processes to introduce more safety features into the work place. We realize that this process is not a small problem that can be solved over night, however, we will stay committed to the pursuit of betterment. In the past five years we have had only one accident that involved an employee being injured by a regulated threshold quantity chemical. This injury was caused by a bad seal on one of our process injectors. It failed during an operation causing ammonia to be continually injected to the point that the vapors had no time to dissipate and an employee had to be treated for inhalation. There were no offsite injuries and no offsite evacuations. The emergency response program is coordinated with a local fire department and a number of hazardous waste and recycle agencies that cover the midwestern area. Each new employee is being trained on how to react to an emergency situation in correspondence with government rules and regulations. The notification and alert system is demonstrated via 2-way radios and company phone system. There are many improvements that are in the process of being added to the emergency response plan. More training for all employees and more drills to familiarize employees with correct procedures are also being implemented. A more efficient way to notify the surrounding community of about 100 people is currently being analyzed. There will be an installation of new active and passiv e mitigation equipment throughout the facility that will help reduce the amounts of release of regulated chemicals in worst case and alternative measures. While preparing this RMP we realized that we are still behind on many of the required items of compliance for the RMP. We have not maintained an accurate and up to date documentation of our hazard review, operating procedures, maintenance, complaince audits and incident ivestigations. Many of the dates listed for that information correspond to the compliance audit that was conducted at our facility on September 11, 1997 by the Minnesota OSHA. Those items, except for maintenance, have not been performed regularly in accordance to the regulations. We are currently implementing procedures at our facility that will create a regular cycle of monitoring and documentation that will exceed the requirements of the RMP rules and regulations. |