Major Smith - Executive Summary

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Major Smith manufacturers of processed foods at our plant in New Holland.  We have a strong commitment to operate our facility in a safe and responsible manner. 
Ammonia is used at our facility as the cooling medium in our refrigeration systems.  Similar to the function Freon plays in a home or car air conditioning system, ammonia is used to cool water and glycol that in turn cools our product in heat exchangers, coolers and silos.  The ammonia is contained in a closed loop system; it is designed to remain inside the piping and vessels in our facility.  We believe that ammonia provides the safest and most efficient cooling choice for our operation. 
A. Describe the Accident Release Prevention and Emergency Policies 
Major Smith takes many precautions to prevent or minimize accidental releases of ammonia from the refrigeration system.  These precautions include safety controls (alarms and automatic shutdown devices) which are designed to identify and prevent potentia 
lly unsafe conditions like pressure increases that could cause a system failure.  We also have a preventive maintenance program designed to maintain the on-going integrity of the systems, a training program designed to ensure that the systems are operated by qualified personnel, and to respond quickly to system upsets. 
The Facilities Engineer is responsible for the management of these ammonia safety programs. 
B. Stationary Source and Regulated Substances Handled 
The facility operates a refrigeration system with an ammonia inventory of approximately 13,872 pounds.  Ammonia is the only substance covered by the Accidental Release Prevention Regulations handled at the New Holland plant. 
C. Summary of Worst-Case and Alternative Release Scenarios 
EPA requires us to define the worst case release scenario from the New Holland plant as the release of all the ammonia from the largest vessel on site.  At our New Holland plant, this would be 3750 pounds of ammonia over a 10-minute period du 
e to the failure of the high-pressure receiver.  The 3750 pounds represents the maximum amount of ammonia that would be contained in the receiver at any time.  EPA also requires us to assume that the weather conditions are such that there is almost no wind and no mixing in the atmosphere. 
The alternative release scenario at the New Holland plant would involve the release of 2700 pounds of ammonia over a 5-minute period due to the rupture of a =" high-pressure liquid line.  The duration of the release was estimated for the alternative release scenario by estimating the amount of time required to stop the leak.  Again, EPA required us to estimate the impacts of this release under low wind and stable weather conditions.   
Both of these releases are unlikely for many reasons.  Our equipment and system were designed using industry standards for ammonia refrigeration.  We have taken precautions to protect our equipment from obvious threats, like vehicular traffic.  We have a preventive mai 
ntenance program to maintain the on-going integrity of the refrigeration equipment.  Training programs are in place to ensure that qualified personnel operate the systems, and our emergency response procedures allow us to respond quickly in the event of an accident.  And lastly, the weather conditions used in estimating the extent of the releases are uncommon. 
D. Description of the Accidental Release Prevention Program 
The facility has an accident release prevention program that complies with Occupational Safety and Health Act's Process Safety Management Standard and EPA's Risk Management Program Regulation.  The prevention program consists of the following elements: 
- Employee Participation Program 
- Process Safety Information 
- Process Hazard Analysis 
- Operating Procedures 
- Training Program 
- Contractor Safety Program 
- Pre-Startup Safety Review Procedures 
- Mechanical Integrity Program 
- Hot Work Permit Procedures 
- Management of Change Procedures 
- Incident Investigation Proc 
- Compliance Audit Procedures 
E. Five-Year Accident History 
There has been one ammonia-related accident at the New Holland plant in the past five years. 
F. Description of the Emergency Response Program 
An emergency response program has been implemented at the New Holland plant.  This program contains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures. 
The plant response team utilizes employees and our refrigeration contractor who are trained to enter and stop an accidental ammonia release. 
G. Planned Changes to Improve Safety 
Major Smith is committed to operating our ammonia refrigeration system in a safe and responsible manner.  We are continually evaluating our equipment and procedures to meet this objective.  Planned improvements include replacement of equipment such as evaporators and ice builders.
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