Farm Fresh Dairy Products - Executive Summary |
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This is to inform all interested persons, including employees that Farm Fresh Dairy Inc. is complying with OSHA's Process Safety Management Standard (called Process Safety Management or PSM), Title 29 Code of Federal Regulations (CFR) 1910.119, and EPA's Risk Management Program regulations (called RM Program), Title 40 CFR Part 68, have developed policies, to deal with the risks involved with the storage, handling, and of hazardous chemicals. In this way we promote overall plant, worker, and public safety. These programs enable our facility to prevent the occurance, 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. Our safety programs are applied to any activity involving hazardous chemicals including any use, storage, manufacturing, handling, or the on-site movement of s uch chemicals, or combination of these activities. Any group of vessels which are interconnected and separate vessels which are located such that a hazardous chemical could be involved in a potential release shall be considered a single process. Our safety programs prevent accidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment. These rules are detailed and improved as necessary. They are also communicated to and accepted by all employees at the facility. The refrigeration required is provided by mechanical equipment which uses anhydrous ammonia as the thermodynamic working fluid in a closed circulatory system. Ammonia has been the principal working fluid for mechanical refrigeraton systems for the food processing industry. The total refrigeration capacity installed in the facility is approximately 60,000 pounds using two stage compression of 3000 installed horsepower operating at three temperture l evels: -20 degrees (F) in the flash freeze rooms, +15 degrees (F) in the soft freezing areas, and +35 degrees (F) in the refrigerated storage areas. The plants process entails processing of raw milk in such a way as to produce dairy products which are distributed to retail stores. Milk and its products require refrigeration and freezing to preserve the products against spoilage during manufacturing, transportation and storge in retail stores. The worst case scenario would involve a vehicle striking the over head return line support brackets causing the high pressure liquid line to burst or striking the line itself releasing 18,000 pounds of ammonia resulting in a ten minute release. Under the worst-case weather conditions, ammonia could travel 1.7 miles before dispersing enough to no longer pose a hazard to the public. This scenario is unlikely for the following reasons: worst case weather conditions are uncommon; the support brackets are constructed of 4" x 4" steel post with 2" x 2" cross bars supporting the lines; the lines are approximately 20 foot high; safety procedures are in effect to address the safe operation of equipment in this location; training is conducted on the company's "yard vehicle safe operating procedures" as needed to insure employee awarness. The alternative release scenario would involve failure of a transfer hose during unloading resulting in a release of 10,000 pounds of ammonia over a time period of 41.3 minutes. Under common weather conditions, ammonia could travel 0.10 of a mile before dispersing enough to no longer pose a hazard to the public. Transfer hose failure was chosen as the alternative release scenario because it is a temporary conection and constructed of materials other than steel. This scenario is unlikley for the following reasons: emergency equipment such as excess flow valve on the tank truck and valves to isolate the transfer hose; the facilities accident prevention program in-place at the faciliity includes op erating procedures to have personnel present at all times during unloading, and the mechanical integrity program for regular maintenance; inspection and testing, and replacement of equipment. The general accidental release prevention program and chemical-specific prevention steps are found in the process safety management program. The PSM program places necessary checks and balances for maintaing a safe operting refrigeration system. Training procedures are in place to insure that all maintenance employees responsible for maintaining the system receive recertification training every 3 years and any new employee receives training before conducting operations on the ammonia system. Controls and equipment go through an intensive checklist to insure safe operation by qualified maintenance engineers on a daily basis. The system is maintained 24 hours a day 7 days a week by qualified maintenance engineers. The emergency action plan utilized is OSHA's Regulation CFR 1910.38. This plan is in place for the safe evacuation of employees. Training is given to all affected employees before their duty assigment begins. Evacuation exercises are conducted at least once per calender year. The emergency response team is delegated to the Chandler Fire Department. The Chandler Fire Department participates in mock drills approximately once during each calender year and coordinates with Farm Fresh management in areas of planning for emergency response and critical shut down operations during an emergency. Under the Emergency Planning and Community Right to Know Act (EPCRA) and under Section 303 of EPCRA, local emergency planning committees (LEPC's) must prepare an emergency response plan for facilities in their planning district having toxic substances listed uner EPCRA Section 302 in excess of the threshold planning quantity established under that section. The Lincoln County LEPC and City of Chandler's Civil Defense Director, have been furnished the toxic end points of the worst case and alternative release scenario. Management of Farm Fresh will continue to coordinate response and evacuation procedures with the committee to insure the public sector is protected. If a toxic release occures, Farm Fresh has in its EAP plan, all necessary proceedures in place to promote an effective response if the need arises. The emergency response proceedures include all necessary persons and agencies to contact to insure the utmost protection to the public, enviroment and to its employees. The planned changes to improve safety are: the safety committe will review all safety procedures and programs that are now in effect on a quarterly basis; improving operating safety rules of yard vehicles; improve awareness in training programs concerning the safe operation of equipment while handling product near ammonia lines; Upon reviewing segments of the PSM program it was noticed that not all areas of the mechinical integrity section were completed. These proceedu res have been identified and are targeted for completion by 07/21/1999. This area has been placed into the planned changes to improve safety. |