Meadow Gold Dairies-Englewood - 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 is 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 Pro grams for Chemical Accidental Release Prevention, 40 CFR Part 68). Emergency action 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, yogurt and ice cream are processed, packaged, sold and distributed from this facility. An important part of the processing and handling involves an ammonia refrigeration system to provide cooling or freezing during processing and storage at the facility. The maximum intended inventory of anhydrous ammonia (CAS # 7662-41-7) contained in the system is 20,000 pounds. 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 or yogurt being cooled or the ice cream being frozen and the coolers and freezers being cooled. 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 pressure 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 4,994 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 coupled with the quantity in the ammonia condensers, SOC vessels and the lines returning liquid ammonia to the high pressure receiver. Under worst-case weather conditions, ammonia could travel 0.9 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. Th e 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. Dual safety relief valves limit operating pressure in the high pressure ammonia receiver; e. 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 240 pounds of ammonia vapor over a 60 minute period due to a leak of a 1/4 inch hole in an ammonia vapor line of the condenser coil at a pressure of approximately 150 psig. Under alternative release weather conditions, the ammonia would be dispersed enough in less than 0.1 mile to no longer pose a hazard to the public. The liklihood 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 an d operating procedures; b. One ammonia condenser is new; c. The ammonia condensers are cleaned routinely and maintained 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 participate 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 are conducted with maintenance personnel using the What-i f/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 a mmonia 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 reviewed. 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 1) On September 21, 1996, a safety relief valve on one small high pressure vessel which serves as a liquid ammonia surge supply for cooling to one ammonia screw compressor failed below its set point. Th is permitted ammonia vapors to escape for 15 minutes resulting in a release of 500 pounds of ammonia to the atmosphere. Our program to replace the safety relief valves with new valves every five years was in effect and the subject safety relief valve had just been replaced a short time previous to the incident. There was no off-site consequence; however, two on-site company employees were administered oxygen by the Englewood Fire Rescue Paramedics and both employees were checked and released by the Swedish Hospital on Logan Street in Englewood. 2) During the holiday weekend of July 1, 1994 through July 4, 1994 an incident occurred where 6,129 pounds of ammonia was purged into water and into our wastewater equalization tanks. The pH was adjusted with acid to a pH of 10.0 or less. Another 50 pounds escaped into the atmosphere or into surface water. 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 Englewood Fire Department. The emergency response 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. Training Programs and Drills G. Planned Changes to improve Safety A new ammonia condenser was installed in 1998 to improve the integrity of the system. |