TILLAMOOK COUNTY CREAMERY ASSOCIATION - Executive Summary |
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Tillamook County Creamery Association Risk Management Plan Production of superior dairy products requires the use of some chemicals that could pose a risk to both employees and the public if handled improperly, spilled, or released catastrophically. The Tillamook County Creamery Association recognizes the duty to protect the safety and health of employees, the community, and our customers. Therefore, the Tillamook County Creamery Association has developed, and implemented, a Risk Management Plan for anhydrous ammonia. The purpose of this plan is to keep safe operation a Company priority through establishing policy, identifying risks, documenting maintenance, and tracking compliance with established standards. This plan is a living collaborative effort developed by employees, maintenance engineers, and management. Joanne Breuer, Tillamook County Creamery Association's Safety Director, h as been appointed plan manager and will consult with employees on a regular basis regarding the conduct and development of Process Hazard Analyses (PHA) and plan modification. The Tillamook County Creamery Association produces natural cheddar cheeses that are aged 90 to 720 days. Proper aging requires precise temperature control and extensive refrigeration. As is common in the industry, TCCA uses an anhydrous ammonia refrigeration system in all cheese storage areas. Approximately 20,000 pounds of anhydrous ammonia is contained in the refrigeration system. It is the intent of the Risk Management Plan to identify and prepare for a worst-case release of anhydrous ammonia. This plan applies to all ammonia refrigeration units, lines, tanks, and compressors located throughout the facility. The worst-case scenario identified in the Risk Management Plan is the catastrophic loss of 20,000 pounds of ammonia within 10 minutes. Such a catastrophic release will have off-site consequences that will require notification, and potential evacuation of nearby residences. Anhydrous ammonia is a colorless gas or liquid with a readily detectable odor at 0.7ppm. Ammonia gas is a severe irritant to eyes, skin and respiratory tract. Exposure to concentrations of 2,500 to 6,500 ppm, which could occur in a worst-case scenario, can cause corneal irritation, shortness of breath, bronchospasms, chest pains, and pulmonary edema, which may be fatal. Contained in the plan are procedures to mitigate the off-site consequences and procedures to implement resident notification. An alternate, more likely, scenario identified in the Risk Management Plan is the release of 1 to 5 pounds of anhydrous ammonia. A release of 1 to 5 pounds of anhydrous ammonia still presents a risk to employees and visitors. However, such a release does not have the off-site consequences identified in the worst-case scenario, and will not require notification or evacuation of nearby residences. Maintenance pol icy and training have been developed to facilitate immediate resolution of any ammonia leak, before it can develop into a worst-case scenario. Within the plan are procedures to evacuate employees while repairing the leak. The Risk Management Plan also outlines a Process Hazard Analysis (PHA) program. This program identifies each component of the ammonia refrigeration system and evaluates the potential ammonia release risk. An important item of the PHA program is a "What-If Analysis" of each component. The intent of the "What-If Analysis" is to identify ways in which ammonia could be released, and develop a response to minimize the magnitude of the release. Development of a Risk Management Plan is a proactive effort by the Tillamook County Creamery Association to protect both the employee, and the community from future releases of ammonia. While small releases of ammonia do occur, there has not been a release of a reportable amount of ammonia in the past 5 years. Another im portant aspect of the Risk Management Plan is the Emergency Response Program. The Emergency Response Program is a written action plan outlining the response of the Tillamook County Creamery Association HAZMAT team to any release of ammonia from the refrigeration system. The Emergency Response Plan was developed in coordination with Tillamook County Fire Department, Oregon State Police, Tillamook County Ambulance, 911 Emergency Center, and the Tillamook County General Hospital. Key issues outlined in the plan include: escape routes, decontamination procedures, medical duties, post evacuation procedures, and reporting requirements. All of the agencies involved in the Emergency Response Program train regularly, and participate in periodic ammonia release drills. The Risk Management Plan developed by the Tillamook County Creamery Association is a dynamic document. This plan is updated annually, or whenever any component of the ammonia refrigeration system changes. TCCA is committed to reducing the likelihood of an ammonia release. To improve process safety, and protect employees and the public, improvements to the ammonia refrigeration system will be implemented when identified. |