Meadow Gold Dairies-Lincoln - Executive Summary |
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A. Describe accidental release prevention and emergency response policies. Meadow Gold Dairies recognizes management's responsibility in protecting its employees, equipment, property and the environment. The safety and health of all personnel and the protection of the environment are very important. The control of accidents has been and will continue to be a basic responsibility of all personnel in the facility. The Company has a Plant Safety Program. The primary objective of the Plant Safety Program are to achieve maximum efficiency and safety performance. To accomplish the Company's goal in preventing the accidental releases of ammonia and minimizing the impact of any release, the facility has developed and implemented a Process Safety Management and Risk Management program to comply with OSHAs Process Safety Management (PSM) standard (Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119) and EPAs Risk Management Program (RMP) regulation (Risk Management Pr ograms for Chemical Accidental Release Prevention, 40 CFR Part 68). Emergency Response programs have been reviewed as well. The objectives of the PSM/RMP programs are to prevent accidental releases through use of good operating procedures and mechanical intregrity of the ammonia refrigeration system. The Plant Manager is responsible for the management of the accidental release prevention and emergency response programs. B. Stationary Source and Regulated Substances Handled Meadow Gold Dairies operates a milk processing facility where milk products, juice, juice drinks, and cottage cheese are processed, packaged, sold and distributed from this facility. Ice cream is also stored, sold and distributed. An important part of the processing and handling involves an ammonia refrigeration system to provide cooling during processing and storage at the facility. The maximum intended inventory of anhydrous ammonia (CAS # 7662-41-7) contained in the system is slightly more than 12,200 pou nds. The ammonia refrigeration system is a closed loop system whereby liquid ammonia from the high pressure receiver located outside the building is piped in special piping to refrigeration equipment used for cooling or freezing. During cooling or freezing, the pressure of the ammonia is reduced so that the ammonia can take away heat from the milk products being cooled or stored. The ammonia returns to the engine room in larger special piping in vapor form at low pressure to the booster or high side compressors where the vapors are compressed and piped to the condensers located outside. Forced air and recirculated water cool and condense the vapors in the lines. From the condensers, the ammonia flows by gravity back to the high pressure receiver, completing the loop. Ammonia is a non-corrosive chemical; therefore, does not deteriorate the inside of vessels, lines or valves. It also carries a small amount of oil from the compessors. All vessels containing ammonia are ASME pressu re rated above the maximum operating pressure. C. Summary of Worst-Case and Alternative Release Scenarios The Worst-case release scenario at the facility involves the release of 3,712 pounds of ammonia over a 10 minute period which would result due to a failure of the high pressure receiver. This quantity includes all the ammonia in the high pressure receiver V-1 coupled with the quantity in the ammonia condenser EC-1, Master Oil Scrubber V-10 and the lines returning liquid ammonia to the high pressure receiver. The maximum level in the high pressure receiver is limited to 80% of the vessel capacity which would normally only occur in the event of a pump-down by facility procedures. Under worst-case weather conditions, ammonia could travel XX miles before dispersing enough to no longer pose a hazard to the public. The worst-case release scenario is highly unlikely for the following reasons: a. The worst-case weather conditions which were used for this scenario are uncommon; b. Industry and ASME standards were followed for the manufacture and qualtiy control of the high pressure ammonia receiver. U-1A manufacturer's data reports were reviewed and are on file at our facility; c. The high pressure ammonia receiver, while located outdoors, is protected by impact by vehicles or forklifts, kept painted and routinely inspected to prevent external corrosion; d. Ammonia is not corrosive in this service and our high pressure ammonia receiver exterior is maintained in good painted condition to prevent external corrosion; e. Dual safety relief valves limit operating pressure in the high pressure ammonia receiver; f. The facility has a training program designed to ensure that the system is operated by experienced and qualified personnel. The alternative (more likely) release scenario at the facility involves the release of 600 pounds of ammonia vapor over a 60 minute period due to a leak of a 1/4" hole in an ammonia vapor line of the condenser coil at a presssure of 150 psig. Under alternative release conditions, the ammonia would be dispersed enough in less than 0.1 mile to no longer pose a hazard to the public. The likelihood of an alternative release scenario is minimized for the following reasons: a. Positive effects of the PSM/RMP programs on the overall condition of the refrigeration equipment and operating procedures; b. The ammonia condensers are almost new, purchased in 1997; c. The condensers are routinely cleaned and maintained to keep them in good condition or identify a problem that would need to be addressed. D. Description of the Accidental Release Prevention Program The program consists of the following elemenets: a. Employee Participation: Maintenance employees participated in developing the Process Hazard Analysis (PHAs), Standard Operating Procedures (SOPs), and other elements of the program. b. Process Safety Information: Piping and instrumentation diagrams (P&IDs) have been developed where all ammonia vessels , lines and valves are numbered on the drawings. All ammonia vavles (except small guage valves) are numbered. 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. c: Process Hazard Analysis: Studies were conducted with maintenance personnel using the What-if/Check list technique to look at the system and identify potential hazards. d. Operating Procedures: Written procedures have been developed with describe the steps which should be followed to safely operate the ammonia refrigeration system. e. Training: A training program has been developed which ensures that employees are trained on the system and the duties which they should perform to ensure the safe operation of the ammonia refrigeration system. f. Contractors: Contractors are screened and evaluated before they perform work on or near the ammonia refrigeration system. g. Pre-Startup Safety Review : A pre-startup safety review will be completed for all new ammonia projects involving a change to the system to verify that all safety programs are in place, training has been performed, operating procedures developed, P&IDs developed, PHAs completed, and construction has been completed according to the design specifications. h. Mechanical integrity: Annual inspections of the ammonia refrigeration system including lines and valves by a team of management and hourly personnel. Any recommendations are resolved promptly. i. Hot Work Permits: Procedures to be followed to ensure that a signed permit is obtained prior to any cutting, welding, or burning in any area other than one designed as hot work. j. Management of Change: The procedures are designed to ensure that all changes made to the ammonia refrigeration system are properly reviewed. k. Incident Investigation: The procedures are designed to ensure that all changes made to the ammonia refrigeration system are properly revi ewed. l. Compliance Audits: Audits will be conducted every three years to ascertain whether or not the program is in place and working properly. E. Five-Year Accident History No ammonia-related incidents were identified for the facility in the previous five years which resulted in significant on-site or off-site consequences. F. Description of the Emergency Action Plan An emergency action plan has been implemented at the 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 Lincoln Fire Department. The emergency action program consists of the following elements: a. Organization Plan and Responsibilities b. Communication Procedures c. Detailed Action Plans d. First Aid Procedures e. Emergency Medical Treatment Procedures f. Evacuation Plans g. Description of Outside Assistance Available h. Site Re-Entry Procedures i. Train ing Programs and Drills G. Planned Changes to improve Safety Two new ammonia condenser was installed in 1997 to improve the integrity of the system. |