Morningstar Foods, Inc. Gustine - Executive Summary |
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EXECUTIVE SUMMARY Suiza Foods Corporation is a leading manufacturer and distributor of fresh milk and related dairy products, shelf-stable and refrigerated food and beverage products, frozen food products, coffee, and plastic containers. The Company's products are distributed throughout the United States and Puerto Rico Morningstar Foods Inc, Gustine is a division of Suiza Foods Corporation. It is our corporate and company policy to provide every employee a safe and healthy workplace. Our corporate safety policy provides guidance for implementation, operation and review of the standards that govern the Ammonia Refrigeration Systems that use anhydrous ammonia or any other highly hazardous chemical that are defined by the threshold planning quantities of the Federal and/or State standard. This includes any of the operational facilities that manufacture, store and distribute product in the company. The personal health and safety of each employee is our first concern and top priority. Management will provide a safe and healthy workplace to the greatest degree possible. Our efforts for personal safety and health shall be in keeping with the highest standards. To accomplish this, management will provide all reasonable safeguards to ensure safe working conditions. The Gustine facility is located in central California. The facility employs approximately 150 hourly associates, and 20 salaried associates. Our primary products include extended shelf dairy and non-dairy food products. The refrigeration system is used for processing and cold storage of dairy food products. THE WORST-CASE RELEASE SCENARIO (S) AND THE ALTERNATIVE RELEASE SCENARIO (S) The following scenarios were modeled using the following guidance of the EPA Model Program: Definitions from EPA Model Risk Management Program and Plan for Ammonia Refrigeration, Appendix A and B; SAIC, May 1996 and the RMP Comptm FedEPA Software for concentric radius' of the Worst-Case and Alternative Case Scenarios. Anhydrous ammonia used in refrigeration systems is gaseous at ambient temperature and pressure and is handled as a gas in a liquid state under pressure. The CalARP regulations require the analysis of a worst-case release scenario specific to the vessel in the system which holds the greatest amount of pressurized liquid, and would be released as a gaseous liquid release in a 10 minute period (Section 2750, c, 1). The release rate must be assumed to be one-tenth the total quantity. The pressurized liquid receiver is the largest vessel in the system and is a dedicated liquid reservoir for anhydrous ammonia. The estimated release quantity for the scenario of this system is 7,041 pounds. This assumes the failure of any administrative controls, or passive mitigation measures to the system. The resultant release then is assumed to be at a rate of 704.1 pounds per minute. The CalARP regulations require the use of the parameters stated in section 2750.2 in order to estimate the distance to the toxic endpoint for a worst-case scenario. The table below lists the parameters. These parameters are from the guidance given in Section 2.0 for the 'EPA Model Program.' The guidance is as follows: 7 Wind speed: 1.5 meters per second 7 Atmospheric stability class: 'F' 7 Height of release: ground level 7 Surface roughness: urban topography based on the use of surrounding properties 7 Ambient temperature/humidity: 25 degrees centigrade and 50% humidity 7 Model classification for anhydrous ammonia: Dense or neutrally buoyant gases 7 Model classification for temperature assumed at substance release: 25 degrees centigrade The toxic endpoint for ammonia is 0.14 mg/l or 200 parts per-million (PPM). Based upon the definition of exposure of 'safe' airborne concentration (Section 2.1.1) of the model the interpolation of the toxic endpoint for the release of 7041 pounds of ammonia is 4,224 feet (0.8 miles). This is based on the release of the specified vessel under the quali fied weather conditions. The estimated population within the worst-case release scenario radius constitutes a mixture of commercial, industrial and residential receptors. Based on EPA Landview-marplot software calculations the population density in this area would be 1500 people. ALTERNATIVE RELEASE SCENARIO The CalARP regulation requires that the facility evaluate a release scenario that is more likely to occur than the worst-case release scenario and that will reach an endpoint offsite (Section 2750.4,b, 1). Using the 'EPA Model Program' definitions for this type of release a typical scenario line rupture with an orifice leading to an airborne release (Section 2.2.2) for the high pressure side of the system will have a corresponding release of 704.1 pounds of ammonia per minute. This coupled with the data for evaluation for the corresponding section describes a wind speed of 3 meters per second and an atmospheric stability class 'D'. Therefore, the predicted distance to t he toxic endpoint is 1056 feet (0.2 miles). The estimated population within this release scenario is 1360 people. Employees of the facility, commercial businesses one block south and west, make up the majority of the effected population. Some residence bounded by the plant to the north and east could be effected. This population estimate is based on employees and surrounding minimally effected structures that are mainly commercial with a very few residential. The Gustine facility falls under OSHA's PSM regulations. In addition to our PSM program, we have quarterly audits by a refrigeration contractor. We are actively training our maintenance associates. Selected associates attend RETA NH3 training classes, and are RETA certified. Our emergency responders are trained to the 40-hour Technician level. The PSM program is integrated with our formal corporate safety program. Contractor controls, welding, respirators, Confined Space Entry, Lockout, etc. are all covered in our saf ety program. THE FIVE-YEAR ACCIDENT HISTORY We have maintained excellent ammonia accident release prevention programs. The Gustine Plant had only one incident involving the release of Ammonia. On July 21, 1998, a maintenance associate was draining oil from a drop-leg on the NH3 system. He did not follow correct procedures. Proper procedure w includes use of a hose and a water-filled bucket. The associate failed to use a hose or bucket. He opened the system to atmosphere. The oil was purged, followed by ammonia. The associate panicked and ran from the drop leg, allowing some ammonia to continue to release. Local authorities were called. The release lasted for 1 hour and 32 minutes. We estimate that 270 pounds of ammonia were released. EMERGENCY RESPONSE PROGRAM Our emergency response program consists of training for the associates, rapid communication, and mitigation. Specific associates are trained and certified as emergency responders. All associates are trained in e vacuation, hazard communication, and chemical safety. Our emergency response plans are filed and reviewed by California Office of Emergency Services. The general procedure is as follows: 1. Immediately notify the Emergency Response Team over the paging system or radio. 2. If the NH3 problem is deemed to be serious, then "9-1-1" (for the Fire Department) will be called by the Emergency Response Team. 3. Immediately initiate plant evacuation procedures. PLANNED CHANGES TO IMPROVE SAFETY It is the intent of the Morningstar division to become proficient in emergency response by training the workforce as an emergency response team. The make up of the team and planned response will be under the review and direction of the Corporate Safety and Training Director. The process safety management policy of Suiza National is as follows: Identify, evaluate and continually improve on processes that effect the ability to prevent and mitigate the risk of release of acutely hazardous materials at each facility. We will communicate effectively to management, effected employees and the community the necessary awareness and preparation for the response to any potential events based on the probability of the risk. Next, we will integrate all potentially compatible safety requirements and guidelines that are expected and implied for use at all company facilities and that enhance the capability of this system. Finally, it is our goal to maintain ongoing compliance of all PSM requirements. Our company has an extensive safety audit program. Each facility is audited quarterly and annually. Plant personnel perform the quarterly audit. The Corporate Safety Director performs the annual audit. The audit scores are tied in with overall plant ratings. Management is accountable for the facility rating. Emergency response, evacuation, PSM, hazcom, etc. are all covered by the safety audit. Each audit includes specific recommendations for correcting program deficiencies. |