WEST LYNN CREAMERY - Executive Summary |
|
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES AT WEST LYNN CREAMERY West Lynn Creamery (WLC) was founded in 1937 under private ownership and remained under this form of ownership until 1998 when it was purchased and became a division of Suiza T.T.L., LLC of Dallas, Texas. WLC is located on an approximate 20 acre site at 626 Lynnway in Lynn, Massachusettes and has over 700 employees. WLC distributes its products throughout the East Cost. WLC product lines include milk, cream, juices, spring water, butter, margarine, eggs and a variety of similar resale items. WLC packagtes speciality products such as ultra-pasteurized creams and milks, non-dairy and cultured products and a variety of icecream and frozen yogurt products. In producing and storing the above diary products, it is necessary to provide utmost sanitary and, for some foods, refrigerated conditions. In providing the necessary sterile food preservation, WLC employes an ammonia refrigeration system which con tains approximately 39,000 pounds of ammonia in a closed-loop pressurized system. Due to the nature and properties of ammonia, it is necessary to use specially rated and durable equipment, piping and auxiliary systems in order to maintain a safe, fully contained and constantly reliable refrigeration system. WLC has pledge to its employees, its customers and its community that it will rigorously maintain the highest standards of safety of this system. The control of accidents and material releases has been and will continue to be the primary responsibility of all WLC employees. Process Safety and Risk Management Team To ensure that WLC fulfills its pledge to maintain a safe and reliable ammonia refrigeration system, management has designated and staffed a Process Safety and Risk Program Management Team (PSRMPT). This team consists of the Chief Engineer, WLC Safety Manager, Maintenance Manager and Environmental, Health and Safety Manager. The latter manager has responsibili ty for leading this team in its charter of maintaining a safe and reliable ammonia refrigeration system and in assuring compliance with the OSHA Process Safety Management standard and the EPA Risk Management Program, or Accidental Release Prevention regulation. 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 prevent accidental fatalities, injuries and illnesses and avoid physical property damage. STATIONARY SOURCE AND REGULATED SUBSTANCE MANAGED In the manufacture and storage of food products WLC utilizes an anydrous ammonia (CAS 7662-41-7) system to provide the necessary temperature control for preserving food sterility and preventing food spoilage. The largest storage vessel used for storing ammonia is an approximately 4,500 gallon high pressure rece iver that has a maximum ammonia storage quantity of 22,000 pounds. In order to improve process safety and operability, WLC administratively controls the quantity of ammonia in this vessel to 80% of its capacity, or 17,700 pounds. This administrative control is included in the written ammonia refrigeration operating procedure. Since an ammonia release could pose a risk of offsite public and environmental impact, this ammonia refrigeration system is designated as subject to the Program 3 requirements of EPA's Risk Management Program regulation and must be enlisted for its potential offsite release consequences. OFFSITE CONSEQUENCE ANALYSIS SCENARIOS Completion of the offsite consequences analysis portion of the Risk Management Plan includes worst-case and alternative release scenarios. The worst case scenario is established as the release of the 17,700 pounds of anhydrous ammonia from the high pressure receiver in a period of 10 minutes. Passive mitigating features for this scenar io are a large sump area that would contain the entire release liquid volume and the location of the high pressure receiver within an enclosed (i.e., not outside or in a tightly contained room). Also included is a drain sump which directs the flow to the onsite aerobic/anaerobic wastewater treatment facility. The latter is not included as a consequence mitigating factor however. Despite incorporating the administrative control of limiting the quantity of anhydrous ammonia to 80% of the high pressure receiver quantity of 17,700 pounds, this worst case release would have offsite consequences that would entend beyond the WLC property line into the adjacent community. The alternative release scenario defined for the anhydrous ammonia system is the mechanical failure of a pressure relief valve that releases ammonia at a rate of 95 pounds per minute over the period of an hour. There would not be any mitigation provided for this type of release that would emit approximately 5,700 pounds of ammonia over the one hour period. The offsite consequence for this scenario would result in only a slight offsite consequence. Both of these scenarios will be used in further developing the WLC emergency response planning efforts and integrating them with those of the local responding agencies. It should be explained that the worst case release scenario definition included in EPA's Risk Management Plan submittal is not a likely situation in light of the following: - The worst-case weather conditions which were used for this scenario are very uncommon; - Industry standards were followed for the manufacture and quality control of the high pressure receiver; - Failure of this unit for any reason is unlikely as is indicated in EPA's Accidental Release Information Program (ARIP) which lists causes of reportable anhydrous ammonia releases; - The facility has a preventive maintenance program in place to maintain the on-going integrity of the vessels; - The facility has a training program designed to ensure that the system is operated by qualified personnel; and, - The facility has emergency response procedures which enable trained personnel to respond quickly to isolate any ammonia release. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND AMMONIA SPECIFIC PREVENTION STEPS West Lynn Creamery's accidental release prevention program includes documented equipment preventive maintenance, employee training and process/equipment monitoring. The preventive maintenance program is monitored using a computerized maintenance management system called Grand PM. The latter program is based on equipment manufacturer's recommendations, the International Institute of Ammonia Refrigeration (IIAR) guidelines and accumulated facility experience. Ammonia detectors are installed in the ammonia compressor rooms, the compressor room ventilation system and in the equipment pressure relief valve discharge header vent lines. The detectors are interlocked such that an exceedance will activate an alarm, start the standby ventilation system and automatically shutdown all power to the ammonia compressor rooms. This system is designed to quickly identify and eliminate emission sources. Ammonia Refrigeration Technicians are Emergency Response personnel who are trained on an annual basis to assure that proper operating procedures and maintenance practices are followed. Annual HAZWOPER refresher training is also provided. FIVE YEAR ACCIDENT HISTORY Within the last five years the West Lynn Creamery had had only one ammonia release that has resulted in an accident to one of its employees. An ammonia refrigeration technician's hands were sprayed with liquid ammonia which was under pressure. The rapid evaporation of the ammonia liquid on the technician's hands resulted in badly frost-bitten hands. The cause of the ammonia release was found to be due to a leaking manual block valve while re moving a piping plug. This defective valve was replaced. In the past there have never been any ammonia releases that have ever resulted in the need to evacuate or shelter-in-place any of the West Lynn Creamery community neighbors. DESCRIPTION OF EMERGENCY RESPONSE PROGRAM An emergency response program has been implemented at the facility. This program contained procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procdedures. The program has been coordinated with the Fire Department and Local Emergency Planning Committee. The emergency response program consists of the folliwng major elements: - Organization Plan and Responsibilities - Communications and Notification Procedures - Detailed Action Plans - Fire Aid Procedures - Emergency Medical Treatment Procedures - Evaluation Plans - Description of Outside Assistance Available - Site Re-entry Procedures - Training Programs a nd Drills In the past five years WLC has twice conducted emergency drills that have included coordination with the Lynn Fire Department and Local ""Emergency Planning Committee. These drills have resulted in improved emergency response by all the participants and is anticipated that this improvement will continue in future years. PLANNED CHANGES FOR CONTINUED EMERGENCY RESPONSE AND SAFETY IMPROVEMENT WLC has continually improved its emergency response planning and capability. This includes the formation of HazMat emergency response teams that respond to emergency situations. This team is trained under the OSHA HAZWOPER requirements and completes refresher training on an annual basis. HazMat team coverage is continuous on all shifts at WLC. Future emergency response capability improvements will include the following: - More frequent drills with local and district response agencies; - Emergency response planning and coordination with adjacent communities; - Emergen cy response planning and coordination with adjacent commercial and manufacturing operations; - Improved detection early release systems. |