L.J. Minor Factory - Executive Summary |
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The Cleveland plant was purchased by Nestle in 1986 and modified to meet Nestle refrigerated manufacturing standards in 1996. In 1998 additional equipment was installed to increase refrigeration capacity. The facility is located at 2621 W. 25th Street, Cleveland, OH 44109. The facility is primarily a two-story structure of approximately 135,000sq. ft in size. The total number of employees is approximately 230. We are a food manufacturing facility which produces Minor's( bases and flavor/sauce concentrates. Minor's products are used extensively throughout the country, in fine quality restaurants, healthcare facilities and in hotel & restaurant chains. The L. J. Minor factory of the Nestl USA Foodservices Division located at 2621 West 25th Avenue in Cleveland, Ohio uses an ammonia refrigeration system to preserve and protect raw materials, intermediates and products. This system has a maximum intended inventory of 12,000 pounds of anhydrous ammonia. Prior to July of 1998, this syste m held less than 10,000 pounds which would have exempted it from requirements of both the OSHA Process Safety Management (PSM) Standard (29 CFR Part 1910.119) and the EPA Risk Management Plan (RMP) Rule (40 CFR Part 68). Every effort has been made to limit the amount of anhydrous ammonia contained within this system so as to minimize the potential impact of catastrophic failures. Facility process expansions, however, has resulted in present inventory levels. This ammonia refrigeration system consists of: * Five Compressors - three high stage and two booster compressors; * One high pressure receiver and one auxiliary high pressure receiver; * One controlled pressure receiver; * One oil still; * One high temperature suction; * One low temperature suction with dump trap; * Two evaporative condensers - one Frick and one Baltimore Air Coil; * One purger; and, * Ancillary equipment, piping and controls. L. J. Minor management are committed to the prevention of anhydrous ammonia rel eases that have the potential to adversely impact the health and safety of our employees, contractors, visitors and neighbors as well as sensitive receptors and ecosystems adjacent to the L. J. Minor facility. To this end, L. J. Minor personnel have undertaken policies and procedures that: * Ensures that employees know and understand the hazards of anhydrous ammonia through participation in all aspects of the L. J. Minor Process Safety Management (PSM) program; * Documents, maintains and updates all process information relating to the ammonia refrigeration system; * Identifies process upsets that could result in an unwanted release of anhydrous ammonia using the Failure Modes and Effects Analysis (FMEA) method for performing a Process Hazards Analysis (PHA). This PHA resulted in a number of recommendations that, when implemented, will eliminate some potential upsets, minimize the likelihood of occurrence for other potential upsets and reduce the seriousness of consequences for st ill more potential upsets. * Limits the potential for human errors that can lead to unwanted releases of anhydrous ammonia. This is accomplished through the development of written operating procedures which identify potential upsets, alerts system operators to these potential upsets and provides safe methods for avoiding the serious consequences that can result; * Ensures that contractors working on or near the ammonia refrigeration system are aware of the potential hazards and work responsibly to avoid potential anhydrous ammonia releases; * Ensure that existing Safe Work Practices for hot work, confined space entry, lockout / tagout and controlling personnel access to the ammonia refrigeration system are adhered to by all employees, contractors and visitors; * Ensures that safety-critical equipment is inspected and/or tested as required to ensure their continued safe and reliable operation. Where appropriate, periodic preventive maintenance is performed to ensure the ongoing reli ability of all process equipment; * Reviews any new processes or additions to the existing ammonia refrigeration system to ensure that they can be started up and operated safely; * Manages changes to the ammonia refrigeration system to ensure that they are implemented in a manner that minimizes the potential for unwanted releases of anhydrous ammonia; * Investigates all incidents associated with the ammonia refrigeration system so as to learn how they can be avoided in the future; * Ensures that all employees, contractors, visitors and outside emergency service personnel know what to do in the event of an emergency so as to minimize potential injuries as well as off-site consequences; and, * Periodically audits PSM activities so as to ensure that PSM programs undergo continuous improvement. In the course of preparing this Risk Management Plan (RMP), a hazard assessment was performed. This hazard assessment identified and evaluated the potential off-site impacts of a worst case re lease and an alternative release scenario. It is important to note that this hazard assessment is a consequence analysis only. No attempt has been made to determine the potential likelihood of occurrence for the two events. While the potential consequences for these events may be considered to be severe, their likelihood of occurrence may be very low. This can moderate the risks associated with a potentially severe event. The Worst Case Release scenario used in this hazard assessment was the catastrophic failure of the high pressure receiver resulting in the instantaneous release of 7,925 pounds of liquid anhydrous ammonia onto the plant floor. The actual emission rate for this release scenario is moderated by the evaporation rate of anhydrous ammonia and the fact that the high pressure receiver is located inside of the plant. As a result, the actual release rate to the outside environment (225 pounds of anhydrous ammonia per minute) is controlled by the building exhaust ventil ation rate. Using the look-up table provided by the U.S. EPA for this purpose, this emission rate would result in a potential impact zone of 0.6 miles radius from the high pressure receiver under worst case meteorological conditions (i.e., wind velocity = 1.5 meters per second and Atmospheric Stability = F). Using demographic data provided within the Landview III software package, this could potentially impact 5,400 people. In addition, such a release could impact several schools, one hospital, the Clark Field Recreational Area and other commercial office and industrial sites. Fortunately, these meteorological conditions normally occur at night when schools and recreational areas are not being occupied. Hospitals, commercial office and industrial sites usually operate at reduced staffing levels during the night, as well. The alternative release scenario modeled for this hazard assessment was the lifting and operation of a pressure relief device within the ammonia refrigeration s ystem. This could be caused by a system overpressure or by a mechanical failure of the pressure relief device. Such a failure would result in the release of anhydrous ammonia at a rate of 29.3 pounds per minute. Since some of the pressure relief devices are located outside of the plant (i.e., on the roof), no reductions in this release rate were made to compensate for passive containment by the building. Using the look-up table provided by the U.S. EPA for this purpose, this emission rate would result in a potential impact zone of 0.1 miles radius from the plant under more typical meteorological conditions (i.e., wind velocity = 3.0 meters per second and Atmospheric Stability = D). Using demographic data provided within the Landview III software package, this could potentially impact 150 people. In addition, such a release could impact one nearby elementary school and other commercial office and industrial sites. Over the last five years of ammonia refrigeration system operation, there have been no incidents that resulted, or could reasonably have been expected to result, in a catastrophic release of anhydrous ammonia. The facility's written Emergency Response Plan provides for plant personnel to respond to any release of anhydrous ammonia from the ammonia refrigeration system. Should they determine a need for HazMat response, they would notify a contracted off-site hazardous response team who is available 24hrs, 7 days a week. An Emergency Response Plan has been prepared to handle release scenarios that have potential impact on the surrounding community. A community notification plan would be activated if the release could affect the surrounding neighborhood. This plan was prepared in cooperation with our local fire, police and medical officials. If the release expands into the surrounding community, a shelter-in-place plan would go into effect. All plant emergency response personnel are identified within the written Emergency Response Plan and receive pe riodic training to ensure that they know and understand the hazards and how they can be avoided. Copies of the plant's written Emergency Response Plan are provided to the Local Emergency Planning Committee (LEPC), fire department, Lutheran Hospital (1730 W 25th St. Cleveland, OH 44113-3170 - 216/696-4300) and other outside emergency service personnel as needed. We at Nestle USA recognize our responsibility as a company to actively address environmental concerns. It is our policy to utilize sound environmental and pollution prevention policies. Nestle has committed resources to develop design specifications for our ammonia refrigeration systems in accordance with nationally recognized engineering practices to ensure safe operation of these systems. Our refrigeration personnel have been provided with state-of-the-art equipment as well as on-going training to be prepared to respond to accidental releases. Nestle factory personnel work closely with local emergency services to prepare for such events by conducting drills and maintaining close communications. We are proud to operate this highly efficient facility in Cleveland, where our employees and families reside. RISK MANAGEMENT PLAN EXECUTIVE SUMMARY (CONTINUED) L. J. Minor Page 4 June 17, 1999 RISK MANAGEMENT PLAN EXECUTIVE SUMMARY L. J. Minor Page 1 June 17, 1999 |