The Minute Maid Company - Paw Paw Plant - Executive Summary
The Minute Maid Company - Paw Paw Plant
Paw Paw, Michigan Production Facility
Risk Management Plan for Ammonia
1. Accidental Release Prevention and Emergency Response Policies
The Minute Maid Company is strongly committed to employee, public, and environmental safety. This commitment is inherent to our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with our regulated processes. It is our policy to implement appropriate controls to prevent possible accidental releases of regulated substances. However, if such an accidental release does occur, we are coordinated with the Village of Paw Paw Fire Department and the Van Buren County LEPC for emergency response support.
2. The Stationary Source and the Regulated Substances Handled
This facility is used for the production of juice and fruit drink products. Ammonia is the only RMP regu
lated substance present at this facility in a threshold quantity. It is utilized as the primary cooling media in our closed-loop refrigeration system. The system's purpose is to provide cold storage capabilities for certain products. The facilty has three separate ammonia systems. The amount of ammonia currently present in the largest refrigeration system totals approximately 14,000 pounds. The two smaller systems contain 3,639 pounds and 2,652 pounds of ammonia respectively. Due to the size and characteristics of our ammonia refrigeration system, as well as Process Safety Management (PSM) applicability, this facility is covered under Program 3 of the RMP regulations.
3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario
To evaluate both the worst case and alternative release scenarios, the computer dispersion model DEGADIS was utilized excl
usively. While the DEGADIS model is not specifically referenced in the RMP Offsite Consequence Analysis Guidance, the ALOHA-DEGADIS model is listed as an acceptable model for this purpose. ALOHA is a simplified version of the DEGADIS model. Since the mathematical approximation processes used in ALOHA are less accurate than those used in DEGADIS, The Minute Maid Company decided to use the DEGADIS model rather than the ALOHA simplification. The following paragraphs provide details of the chosen scenarios.
The worst case scenario would involve the catastrophic failure of the low-pressure receiver, which has the capacity to hold the entire contents of the large refrigeration system during a maintenance condition. As specified in the RMP Guidance for Ammonia Refrigeration, the worst case scenario assumes that the entire contents of the vessel (14,000 pounds) is released over a period of 10 minutes, yielding a release rate of 1,400 pounds per minute. Under worst case weather cond
itions (Class F atmospheric stability and 1.5 m/s windspeed) as required by the RMP rule, DEGADIS yielded a distance of 0.87 miles to the toxic endpoint of 0.14 mg/L (200 ppm) ("zone of influence"). The estimated residential population for the zone of influence is approximately 400 based on 1990 census data calculated by LANDVIEW III software. Other public receptors identified within the zone of influence include at least one recreation area and commercial/industrial areas. No environmental receptors are known to be located within the zone of influence.
Several alternative release scenarios were evaluated; however, most of these scenarios, when modeled, did not reach a toxic endpoint offsite. For the purpose of this RMP submission, the following alternative release scenario was chosen because it is one of the few that would reach an endpoint offsite as required by the RMP rule. The scenario chosen involves the slow leak of ammonia from a source equivalent to a 0.125 inch ho
le in the high pressure part of the ammonia system. This scenario could be representative of multiple situations such as a small hole in a vessel or pipe, a pinpoint hole in a condenser coil, or a packing leak around a valve stem. Due to the presence of isolation valves, the release would be stopped within a 5 - 10 minute timeframe. Approximately 138 pounds of ammonia could be released over 10 minutes. Under average weather conditions for this area, DEGADIS yielded a distance to toxic endpoint of 0.082 miles. The majority of area within the zone of influence exhibits open topography, with comercial and industrial buildings being the only offsite receptors identified. Landview III software estimates that approximately 11 persons reside within the alternative release scenario's zone of influence. However, the facility has specifically confirmed that there are no residences within 0.082 miles of the potential release source.
4. The General Accidental Release Prevention Program
and the Chemical-Specific Prevention Steps
The facility has taken all necessary steps to comply with the accidental release prevention requirements set forth in 40 CFR part 68. Our facility is also subject to the OSHA PSM standard under 29 CFR 1910.119, as well as the EPCRA Section 302 and 311/312 notification/reporting requirements. The following sections briefly describe the elements of the accidental release prevention program that is in place at our facility.
Process Safety Information
The Minute Maid Company maintains a detailed record of safety information that describes the chemical hazards, operating parameters, and equipment designs associated with the ammonia refrigeration system.
Process Hazard Analysis
As part of the ammonia refrigeration system installation process, and as required under PSM, the facility conducted a comprehensive study to ensure that hazards associated with its ammo
nia refrigeration system are identified and controlled efficiently. These studies, using "What If" scenarios, will be repeated every 5 years by a team of qualified personnel with expertise in refrigeration engineering and process operations. Any findings related to the process hazard analysis will be addressed in a timely manner.
For the purpose of safely conducting activities related to our ammonia refrigeration system, The Minute Maid Company maintains written operating procedures. These procedures address various modes of operation including startup, normal operations, emergency operations, normal shutdown, and emergency shutdown. The information is regularly reviewed and is readily accessible to all operators and contractors who work with the ammonia refrigeration system.
The Minute Maid Company has a comprehensive training program in place to e
nsure that employees who are working with the ammonia refrigeration system are competent in all relevant operating procedures. Refresher training is provided at least every three (3) years or more frequently as needed.
The Minute Maid Company carries out and documents maintenance checks on ammonia refrigeration system equipment to ensure proper operation. Process equipment examined by these checks includes among others: pressure vessels, piping systems, pressure relief valves, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in applicable maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.
Management of Change
Written procedures are
in place at The Minute Maid Company to manage changes in ammonia refrigeration system technology, equipment, and procedures. Process operators, maintenance personnel, or any other employee whose job tasks are affected by an ammonia refrigeration system modification are promptly made aware of, and offered training to deal with, the modification.
Pre-start up safety reviews are conducted any time the ammonia refrigeration system, or any of its components, are opened for repairs, tie-ins, or modifications. These reviews are conducted to confirm that construction, equipment, operating procedures, and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
The Minute Maid Company will conduct audits on a regular basis to ensure that the provisions set out under the RMP rule are being properly implemented. These audits
will be carried out at least every three (3) years and any corrective actions required as a result of the audits shall be undertaken in a safe and prompt manner.
The Minute Maid Company promptly investigates any incident that has resulted in, or could reasonably result in, an accidental release of ammonia. These investigations are undertaken to identify the situation leading to the incident, as well as any corrective actions implemented to prevent the release from reoccurring. All incident investigation reports will be retained for a minimum of five (5) years.
The Minute Maid Company truly believes that accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information related
to RMP implementation, including Process Hazard Analyses (PHA) information.
On occasion, our company hires experienced contractors to conduct specialized maintenance and/or construction activities related to the ammonia refrigeration system. Prior to selecting a contractor, a thorough evaluation is made of the contractor's safety performance. The Minute Maid Company has a strict policy of informing the contractors of known potential hazards related to the contractor's work with the ammonia refrigeration system. Contractors are also informed of all the procedures for emergency response should an accidental release of ammonia occur.
5. Five-year Accident History
The ammonia refrigeration system at this facility has been operational for over 20 years and, although it has experienced a few minor accidental releases during this period, no releases had any off site impact. Additionally, no releases had any
adverse health or safety impact on employees within the facility.
6. Emergency Response Plan
The Minute Maid Company Emergency Response Policy focuses on evacuation of the facility in the event of an ammonia emergency, with local emergency response agencies performing all rescue, firefighting, first-aid, medical treatment, and other response functions. The facility maintains a written Emergency Response Plan to document specific procedures to be implemented in the event of various emergencies, including an ammonia release. The Emergency Response Plan includes procedures for facility evacuation, as well as for notification of the local emergency response agencies which are responsible for notifying the public. The plan is promptly updated to reflect any pertinent changes taking place within the facility that would require modified procedures.
The Van Buren County LEPC is the Local Emergency Planning Committee (LEPC) with which our Emergency Response Plan has been coo
rdinated. The Paw Paw Fire Department is the primary emergency response agency for all facility emergencies, including ammonia releases.
7. Planned Changes to Improve Safety
The facility has no currently planned changes to the ammonia refrigeration system, but will periodically assess opportunities to improve the safety of that system.