Edwards Baking Company - Executive Summary
Ed wards Baking Company Executive Summary for Ammonia Refrigeration System |
1. Accidental Release Prevention and Emergency Response Policies
We at Edwards Baking Company are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances.
2. The Stationary Source and the Regulated Substances Handled
Our facility's primary activities Frozen Desert Manufacturingr. We have 1 regulated substances present at our facility. These substance is Ammonia (anhydrous). Ammonia (anhydrous) is used for Refridgeration of Frozen Foods (Pies).
The maximum inventory of Ammonia (anhydrous) at our facility is 40000.00 lb..
3. The Worst Case Release Scenar
io(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario
To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios.
The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from Refrigeration System. In this scenario 10000 lb. of Ammonia (anhydrous) is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 1.6 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L.
The alternative release scenario for Ammonia (anhydrous) involves a release from Refrigeration System. The scenar
io involves the release of 2000 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. The release is also assumed to be controlled by emergency shutdown system(s). These active mitigation systems have the effect of being able to control and shut down the system via remote access. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.31 miles.
4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. The following sections briefly describe the elements of the release prevention program that is in place at our stationar
Process Safety Information
Edwards Baking Company maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes.
Process Hazard Analysis
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is a detallied Process Hazard analysis. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of twice a yearr or if a proceess change or event occurs. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 08/05/1998.
For the purposes of safely conducting activities within our covered processes, Edwards Baking Company maintains written operating procedures. These p
rocedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes.
Edwards Baking Company has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every 2 years and more frequently as needed.
Edwards Baking Company carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with
previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.
Management of Change
Written procedures are in place at Edwards Baking Company to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 08/05/1998. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification.
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Edwards Baking Company. The most recent review was performed on 06/28/1998. These reviews are conducted to confirm that construction, equipment, operating
and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
Edwards Baking Company conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on 06/10/1999. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner.
Edwards Baking Company promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years.
Edwards Baking Company truly believes that process safety management and accident prevention is
a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular.
On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Edwards Baking Company has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur.
5. Five-year Accident Historys
Edwards Baking Company has had an excellent record of preventing accidental releases over the las
t 5 years. Due to our stringent release prevention policies, no accidental releases have occurred during this period.
6. Emergency Response Plan
Edwards Baking Company carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas.
To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.
7. Planned Changes to Improve Safety
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Emproved emergency egress measures and bett
er communication with outside services are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by the Fall of 1999.