Empire Cheese, Inc. - Executive Summary |
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Executive Summary: Risk Management Plan submission for Empire Cheese, Cuba, NY Empire Cheese and its parent company, Great Lakes Cheese, operate a facility in Cuba, NY which produces a variety of cheeses. Milk, cream, and additives arrive in bulk from other locations. The milk is fermented into various cheeses, processed, cooled, and packaged. After packaging, the product is stored in our refrigerated warehouse facility until shipped to the customer or for further processing (slicing, shredding, etc.). Most large refrigerated facilities use a chemical called anhydrous ammonia as a vital part of the refrigeration system. Ammonia performs the same functions as the hydrochlorofluorocarbon - "Freon" refrigerants used in home air conditioners, refrigerators, automobiles, etc. Ammonia is the most environmentally friendly, energy- and capital-efficient refrigerant available for industrial applications; "Freons" are not suitable for many industrial uses. Anhydrous ammonia is also used wi dely as a fertilizer, both for direct injection into the ground and for manufacture of other fertilizers. Because of its moderate toxicity and slight flammability, it is considered a hazardous material. Empire Cheese is committed to maintaining a safe manufacturing operation for our employees and the surrounding community. This commitment includes the ammonia refrigeration system. To further safety in our facility, the refrigeration system is constructed under permit from local authorities, such as the building and fire departments. Additionally, we adhere where appropriate to industry-consensus codes and standards, including the ASHRAE Safety Code for Refrigeration and the IIAR-2 standard of the International Institute of Ammonia Refrigeration. Finally, to comply with requirements of the Occupational Safety and Health Administration and the United States Environmental Protection Agency, we implement a method called Process Safety Management to ensure that the refrigeration syste m is operated and maintained safely. We use a variety of methods to ensure that accidental releases of hazardous materials are prevented to the greatest extent possible. In addition to professional design and installation to accepted engineering standards, our Process Safety Management program includes elements addressing: 7 Employee Participation: We involve our employees at all appropriate points in our program. 7 Process Safety Information: We maintain information relating to the safety of ammonia and the design limits of the refrigeration system so that our employees are fully informed. 7 Process Hazards Analysis: We conduct detailed studies of our refrigeration system and some major modifications to identify the important hazards and safeguards. 7 Operating Procedures: We provide written operating procedures to help our staff stay within the safe operating limits of the refrigeration equipment. 7 Mechanical Integrity (Maintenance and Quality Control): We use a comprehensive prog ram of inspections and preventive maintenance to keep mechanical failures from occurring. 7 Training: We train our mechanics in safe operation and maintenance of the refrigeration system. 7 Management of Change: Alterations to the refrigeration system are screened to verify that they are within the original safe design limits. 7 Pre-Startup Safety Review: For certain types of major changes, we conduct a formal safety review before startup to ensure that the new equipment has been designed and installed properly. 7 Contractors: We carefully screen contractors who work on our property to ensure that they have a safe work record. 7 Hot Work Permits: We strictly control welding and other work that could start a fire near the ammonia equipment. 7 Emergency Response: Should a serious incident occur, we maintain our own emergency response program, coordinated with the Cuba Fire Department and the Local Emergency Planning Committee. 7 Incident Investigation: After an incident, we investigate to determine the causes and any suitable actions to address them. 7 Compliance Audits: Approximately every three years, we examine the safety program in detail to identify areas for improvement. 7 Trade Secrets: OSHA and EPA require us to maintain a trade secrets program in case confidential information affecting the safety of the ammonia refrigeration system is ever found. 7 Management System: An overall management system monitors the ongoing progress of safety items. As required by the EPA, we have analyzed "worst-case" and "alternative" hypothetical ammonia release scenarios and their consequences, details of which appear in other portions of this Risk Management Plan. The methodology used to evaluate these accidents is prescribed by regulation, and makes no effort to estimate the likelihood or "risk" of these incidents. Empire Cheese uses other methods to develop plausible scenarios for emergency planning and response drills. The "worst-case" release scenario involves loss of the contents of a high-pressure receiver vessel over ten minutes. As required, this scenario has offsite impact, meaning that a level of 200 ppm ammonia is reached beyond the property line. The alternative scenario involves lifting of a relief valve, a safety device provided on all vessels to prevent accidents such as the one specified as the "worst-case." The alternative scenario also has offsite impact. We estimated that the release would end after ten minutes, a plausible value considering the normal behavior of relief valves and ammonia in vessels. We used a computer program supplied by the Environmental Protection Agency to estimate the offsite impacts. (See the Risk Management Plan, available from the Environmental Protection Agency, for details on the offsite impacts; due to National Security concerns, the U.S. Government has advised the regulated community not to disclose the actual numerical data in this Executive Summary.) There have been no accidental releases of a mmonia in the past five years Empire relies upon the efforts of community emergency response personnel to respond to any serious accident at the facility. We support the efforts of the Cuba Fire Department and other Alleghany County emergency organizations by providing information and technical assistance. Many members of the responding organizations are full-time employees at Empire Cheese. Through our Process Safety Management program, we systematically look for possible system changes to improve safety in our facility. Because our facility is new, the opportunity for such changes is small. At time of writing, few significant changes planned for safety reasons. As changes are made (or as process hazards analysis studies are updated - which we do on a regular schedule), safety issues and improvements are identified and made as a matter of course. An example of this is our plans to change the way certain maintenance operations are performed to better protect our employees from harm. Our adherence to accepted codes and standards drastically reduces the number of safety issues in a change; safety is designed in rather than added later. |