Dreyer's Grand Ice Cream - Executive Summary |
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RMP EXECUTIVE SUMMARY A. Accidental Release Prevention and Emergency Response Policies Dreyer's Grand Ice Cream recognizes management's responsibility in protecting its employees, the public, the environment, equipment, and property. The safety a nd health of all personnel are very important. The control of accidents has been and will continue to be a basic responsibility of all personnel in the Union City facility. To accomplish the company's goal in preventing accidents, the facility has established a Plant Safety Program. The objectives of the Plant Safety Program are to: maximize safety performance and prevent injuries and accidents. One of the activities associated with the Plant Safety Program has been the development and implementation of accidental 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 Accidental Release Prevention, 40 CFR Part 68). Mr. Jeffrey Grote, Risk and Safet The purpose of the accidental 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 types of catastrophic accidents. Overall, these programs help prevent accidental fatalities, injuries and illnesses, environmental impacts, and physical property damage. The accidental release prevention and emergency response programs help prevent accidents 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. In addition to the Plant Safety Program, Dreyer's Grand Ice Cream follows the corporate safety policies. Examples of such policies include: Workplace Audits and Inspections Corrective Action Tracking Safety Performance Accountability Job Hazard Evaluation Lock, Tag and Try Behavioral Safety Observations Safety Suggest Program The management at Dreyer's Grand Ice Cream has taken numerous actions to demonstrate its commitment to safety and implementation of safe work procedures. Examples of such actions include: Third-party compliance and safety system audits Capital budgeting for ammonia system risk-reduction projects Capital budgeting for ergonomic risk-reduction projects Positive recognition for employees and teams who work safely Offsite safety training for employees B. Stationary Source and Regulated Substances Handled Dreyer's Grand Ice Cream operates an ammonia refrigeration system at the ice cream facility in Union City, CA. 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 approximately 36,000 pounds. The system is regulated under the OSHA PSM standard (29 CFR 1910.119), and Program 3 requirements of the EPA's RM program regulation. C. Summary of Worst-Case and Alternative Release Scenarios The worst-case release scenario at the Dreyer's facility involves the release of 31,800 pounds of ammonia over a 10 minute period due to the failure of the high pressure receiver. This quantity represents the full capacity of the vessel, which is a conservative assumption as it may only be full once every 10 years during a substantial system pump-down. Since the facility is located in a populated area, the release would reach off site end points and near by public receptors. This distance has been calc The worst-case release scenario is unlikely for the following reasons: The worst-case weather conditions which were used for this scenario are not typical; Industry standards were followed for the manufacture and quality control of the receiver; The receiver is located in a low traffic area which minimizes the possibility of loss of containment due to vehicular impact (e.g., from forklifts etc.); Ammonia is not corrosive in this service and the receiver is relatively new; Operating procedures and pressure safety valves limit operating pressure in the receiver; The facility has a preventive maintenance program in place to maintain the on-going integrity of vessels; The facility has a training program designed to ensure that the system is operated by qualified personnel; and, The facility emergency response procedures enable trained personnel to respond quickly to isolate potential releases. The alternative release scenario at the Dreyer's facility involves the release of 2,760 pounds of ammonia over a 30 minute period through a pressure safety valve (PSV) on the high pressure receiver, which lifts to relieve high system pressure but fails to reseat properly. Under alternative rele ase weather conditions, this scenario would result in a release that would reach off-site end points and near by public receptors. This distance has been calculated based on the method provided in the Risk Mana The alternative release scenario is unlikely for the following reasons: Industry standards were followed for the manufacture and quality control of the pressure relief devices; The system is operated at considerably lower pressures (maximum 135 psig) compared to the PSV's relief pressure setting (300 psig); Ammonia is not corrosive in this service; and the receiver is regularly inspected and maintained. The facility has a preventive maintenance program in place to maintain the on-going integrity of the pressure relief devices; The facility has a training program designed to ensure that the system is operated by qualified personnel; and, The facility emergency response procedures enable trained personnel to respond quickly to isolate potential releases from leaking equ ipment. D. Description of the Accidental 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 to be involved when a process hazard analysis is conducted. The program also ensures that all employees have 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 HAZOP Technique have been conducted to examine the system and identify potential hazards. recommendations are resolved to improve facility safety. Operating Procedures: Written, detailed procedures have been developed which describe the steps which should be followed to saf ely 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: 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 required for new ammonia projects to verify that safety programs are in place, training has been 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 systems are built and maintained using preventive maintenance procedures to minimize unexpected breakdowns or failures. Hot Work Permit: Th ese procedures ensure that a signed permit is obtained prior to cutting, welding, or burning. Management of Change: Procedures are designed to ensure that changes made to the ammonia refrigeration system are properly reviewed. Incident Investigation: Procedures ensure that incidents (and near misses) are investigated, reviewed, and documented using an investigation team. Recommendations are resolved to improve the safety of the facility. Compliance Audits: There are procedures to conduct regular audits of the RM prevention program to ensure that the program is in place and working properly. Recommendations from audits are resolved to improve the RM program. E. Five-Year Accident History There have been no accidental releases that resulted in onsite deaths or injuries in the last five years. In addition, there have been no accidental releases that resulted in offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage in the last f ive years. Onsite property damage occurred as a result of one accidental release of ammonia on December 28, 1995. F. Description of the Emergency Response Program An emergency response program has been implemented at the Dreyer's Grand Ice Cream 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 Freemont Fire Department. The emergency response program consists of the following elements: Organization Plan and Responsibilities Communications Procedures Detailed Action Plans First Aid Procedures Emergency Medical Treatment Procedures Evacuation Plans Description of Outside Assistance Available Site Re-Entry Procedures Training Programs and Drills Revision and Update Criteria G. Planned Changes to Improve Safety The following changes are planned to improve safety conditions and further strengthen the ongoing safety e fforts at the Dreyer's Grand Ice Cream facility: installation of additional ammonia monitoring systems; continued implementation of task-specific safe work practices; increased coordination with local emergency response agencies; continued corporate and third-party compliance and safety system auditing. |