State Fair Foods - Executive Summary |
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Texas Utilities Integrated Solutions is a Texas Utilities Company which is committed to providing quality utility services to industry while maintaining the highest standards of safety for both employees and the public. The system described in this submittal is a refrigeration system utilized in the production of corn dogs by State Fair Foods, a subsidiary of Sara Lee Corporation. Anhydrous Ammonia is the chemical of concern. It is used as the refrigerant in the system, which refrigerates the raw materials used in the corn dog manufacturing and freezes the final product. A total of 86,000 pounds of ammonia is recirculated and/or stored in the system. The design and construction of the system is in accordance with the applicable guidelines and recommendations of the American Society of Mechanical Engineers (ASME), the American National Standards Institute (ANSI), the International Institute of Ammonia Refrigeration (IIAR), the American Society of Heating, Refrigerating, and Air-Con ditioning Engineers, Inc. (ASHRAE), and the Occupational Safety and Health Administration (OSHA). The system is continuously monitored and inspected by personnel which are qualified and trained in accordance with the requirements of the Refrigeration Engineers and Technicians Association. These operators continuously monitor the system for any indication of leaks or equipment problems using a process control system and permanent, continuous ammonia detectors capable of distinguishing the presence of ammonia in the atmosphere down to a few parts per million. In addition, the system is visually inspected via a walk-through checklist once every four (4) hours, twenty-four (24) hours per day. Any indication of deviation from process set points or leaks would result in the immediate isolation of the problem from the remainder of the system for prompt repair. Design, maintenance, repair, and operation of the system are conducted in accordance with OSHA regulation 29 CFR 1910.119 (Proces s Safety Management of Highly Hazardous Chemicals). In the event that a leak should occur in the system in spite of precautions taken, the system is equipped with ammonia detectors which are located at strategic points throughout the facility. These ammonia detectors will sound an alarm and alert the operators upon detecting an ammonia level in the air greater than thirty-five (35) parts per million, which is well below the OSHA Permissible Exposure Level of fifty (50) parts per million. For the purposes of this submittal, to satisfy the requirements of 40 CFR Part 68, the Environmental Protection Agency requires that the facility submit a worst case release scenario. This is the complete release of liquid ammonia from the vessel in the system designated as the high pressure receiver in a time period of ten minutes. This worst case release would result in an ammonia release of approximately 33,000 pounds in the ten-minute period, which would result in off-site impacts. The inform ation presented here is based upon the guidelines included in the document "Model Risk Management Program and Plan for Ammonia Refrigeration", May, 1996, prepared by Science Application International Corporation and available on the Environmental Portection Agency's Chemical Emergency Preparedness and Prevention Office Homepage at http://www.epa.gov/swercepp. The alternate scenario presented in this submittal is based upon the rupture or breakage of a small pipe due to forklift traffic or other impact. The facility does not allow forklift traffic in the area of the ammonia vessels or compressors in order to minimize the possibility of this occurrence. Again, the information presented is based upon the "Model Risk Management Program and Plan for Ammonia Refrigeration". This ammonia refrigeration system was started in April of 1999, and as such, has no accident history to summarize. Texas Utilities Integrated Solutions has implemented an Emergency Response Plan to be followed in the event of an accident or release. This Emergency Response Plan describes the notification protocol to be used in the event of an ammonia release, and the response action to be taken to contain or stop the release. The notifications in the event of a sudden release of over 100 lbs of ammonia would include the local fire department, the Tarrant County Local Emergency Planning Committee, the State Emergency Response Commission, and the National Response Center. The fire department and the Tarrant County Local Emergency Planning Committee have been provided with copies of the facility Emergency Response Plan. |