Moroni Feed Processing Division - Executive Summary |
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MORONI FEED PROCESSING DIVISION PSM/RMP ROGRAM I. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY POLICIES Moroni Feed Processing Division recognizes management's responsibility in protecting it's employees, equipment, property, and the environment against the hazards of an unintentional ammonia release. The safety and health of all employees and the public is very important. The control of accidents has been and will continue to be a basic responsibility of all personnel in the facility. The Moroni Feed PSM/RMP program assigns and documents the specific responsibilities for developing, implementing and integrating the OSHA PSM and the EPA RMP standards into its safety program. The Moroni Feed PSM/RMP program focuses attention on "Making PSM/RMP the way we manage our ammonia based refrigeration system" rather than a project we expect to complete and put on the shelf when the filing date has passed. Moroni Feed believes that Employee participation is the key to a successful program. Operating level employees, particularly the Maintenance and Refrigeration Manager and the Refrigeration System Operators, have been deeplly involved in the PSM/RMP program development, implementation and integration and they assume the major responsibility for operating the Moroni, Utah facility safely. The Moroni Feed Emergency Response Program has been developed with the complete cooperation and support of the Moroni Volunteer Fire Department. All Moroni Feed employees have received documented emergency response training. II. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED Moroni Feed Processing Division Manages a turkey processing operation. The refrigeration system is required for the Processing, storage and distribution of Frozen Turkeys. The refrigeration system contains no more than 33,000 pounds of Anhydrous Ammonia. Anhydrous Am monia is the only Hazardous Material on site in quantities above the threshold quantity. III. SUMMARY OF WORST CASE AND ALTERNATIVE RELEASE SCENARIOS The WORST CASE release scenario involves the complete rupture of the High Pressure Receive. A maximum release of 19,525 pounds of ammonia over a 10 minute period was considered. Under worst case weather conditions ammonia could travel up to 1.7 miles before dispersing. A WORST CASE release is very, very, very, unlikely to occur during the life of the facility, this is because of the release prevention and mitigation features incorporated in the Moroni Feed PSM/RMP program. An alternative case release scenario that we call WORST CASE CREDIBLE was slightly more likely. A 3905 pound ammonia vapor loss from failure of a psv to reseat or from ruptured vapor piping. Unsder worst case weather conditions ammonia could travel up to .2 mile before dispersing. This release is very, very unli kely to occur during the life of the Moroni Feed facility. An alternative case release that we call MOST LIKELY, MOST SEVERE was slightly more likely still. A 100 pound ammonia loss from a failing ammonia transfer hose during the unloading operation. Under worst case weather conditions ammonia could travel up to .1 mile before dispersing This release is very unlikely to occur during the life of the Moroni Feed facility. IV. DESCRIPTION OF THE MORONI FEED ACCIDENTAL RELEASE PREVENTION PROGRAM Moroni Feed conducts an annual training and response exercise with the Moronie Volunteer Fire Department to practice, train and update the Moroni Feed Emergency Response Program. Moroni Feed conducts an annual PSM/RMP implementation progress audit of the entire PSM/RMP program to identify strengths and weaknesses and make improvements. Moroni Feed considers the PSM/RMP manuals to be "living" documents that must be updated and revised regularly to maintain t heir viability. Moroni Feed emphasizes and insists on "employee participation" from the refrigeration system operators in all aspects of the developent, implementation, and integration of their PSM/RMP program. Moroni Feed provides a comprehensive, computer based, user friendly training program with "one-on-one" teacher involvement in specific training modules for each ammonia refrigeration employee. Moroni Feed maintains a pro-active "open-door" policy toward neighbors and concerned community citizens. Facility tours and risk management discussions are scheduled and conducted upon written request. V. FIVE YEAR ACCIDENTAL RELEASE HISTORY There have been no releases of ammonia that resulted in an injury, or that had an off-site impact, or that resulted in significant property damage either on-site or off-site. VI. Emergency Response Program Facility employees have been trained to respond to accidental ammonia release. The site emergency plan has bee n coordinated with the community emergency plan under the jurisdiction of the Local Emergency Planning Commission (LEPC) and the Moroni Volunteer Fire Department. VII. PLANNED CHANGES TO IMPROVE SAFETY Moroni Feed recognizes that (even though their Ammonia release and injury experience has been excellent) their PSM/RMP program will provide much needed improvement to their safety effort. The PSM/RMP program is considered to be a set of "living" documents and procedures that will require constant attention, development, and revision before "Safety" becomes becomes second nature. Moroni Feed expects to improve safety performance by emphasizing the following elements of their PSM/RMP Program (1) Employee Participation is the "Key" to a successful program. Both the Maintenance and Refrigeration Manager and the Refrigeration System Operators will be deeply involved in Verifying the P&ID's, Developing and updating the Standard Operating Procedures, and performin g the documented Preventive Maintenance Inspections. (2) The Moroni Feed PSM/RMP Program will increasingly become: (a) computer based, (b) user friendly, (c) based on "one-on-one" involvement with specified and qualified trainers, (d) revised and re-written to minimize paperwork and maximize documentation, and (e) revised and re-written to be understood and used by the operating level employees. (3) All recommendations developed during the HAZOP were designed to improve the safety performance of the Moroni Feed Ammonia Refrigeration Process. Moroni Feed expects to evaluate each recommendation in a timely manner and implement, as soon as possible, those recommendations that will reduce the possibility of a release and/or mitigate the consequences of an unintentional release. |