DRAYTON FOODS, LLC - Executive Summary

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Schwan's has historically placed a high priority on chemical  
safety. The corporate environmental compliance manager has been  
assigned overall responsibility for chemical safety in general and  
for ammonia refrigeration safety in particular since 1991.  
Schwan's maintains 3 - shift coverage at all facilities with  
ammonia refrigeration systems covered by this rule. One designated  
person is on call on weekends. 
The Fargo, ND facility manufactures frozen dough. Anhydrous  
ammonia is used in the refrigeration system at this facility.  
Ammonia is the most efficient and environmentally compatible  
refrigerant available. Although it is toxic at high concentration  
and is an irritating gas, it is not a cumulative metabolic poison,  
does not cause cancer or other dread diseases and does not cause  
lasting environmental damage. The refrigeration system at this  
facility contains about 13,100 pounds of ammonia. 
Schwan's calculates ammonia worst case release scenarios using the  
Model RMP fo 
r Ammonia Refrigeration, May 1996. All Schwan's  
manufacturing facilities are located in areas that meet the  
definition of "urban". Schwan's has chosen to calculate worst case  
release poundage for the largest high-pressure receiver in the  
system, filled to full calculated hydraulic capacity. Reduced  
volume for administrative controls was not used, since the  
described scenario would probably occur only as a result of a  
catastrophic vessel rupture caused by a total filling of the  
vessel, closure of all vessel block valves, failure of all  
pressure relief valves, with a simultaneous increase in liquid  
temperature sufficient to overpressure the vessel to the point of  
It is the professional judgement of Schwans Environmental Health  
and Safety Department that a release rate of 400 lb./min. should  
be used as an alternate case scenario in lieu of the 100 lb./min.  
rate suggested in the Model RMP. 
The "urban" site condition will be used. 
Based on the above, the worst-cas 
e ammonia release scenario for  
the Fargo, ND facility will be 6,700 pounds released over a 10- 
minute period. The alternate case will be a release rate of 400  
pounds per minute. 
The ammonia refrigeration system is covered by the OSHA Process  
Safety Management (PSM) rule, 29 CFR 1910.119. 
The Fargo, ND facility is currently organizing and training a 3- 
shift emergency response team, trained at the 24-hour technician  
level. The training will be conducted by the Corporate  
Environmental Compliance Manager. The training will be designed  
with a heavy emphasis on ammonia safety, mechanical isolation,  
personal protective equipment up to use of Level `A' suits and  
interaction with an incident command system (ICS). Copies of  
emergency plans will be filed with the Fire Department and annual  
facility walkthroughs will be conducted with Fire Officers.  
Preplanned command posts and staging areas will be designated and  
Incident Command transfer and liaison functions will be  
A post-incident debriefing will be conducted after  
each incident. 
Since a continuous improvement philosophy is deeply imbedded in  
the Schwan's corporate culture, improvements in system safety are  
implemented as a result of employee-based teams, a designated PSM  
team and as a result of system engineering modifications and  
extensions. Post incident debriefings and incident investigations  
are used to identify additional improvements to system safety.
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