Pepperidge Farm Inc. - Downingtown Plant - Executive Summary |
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A. Describe the Accident Release Prevention and Emergency Policies It is the policy of the Pepperidge Farm Plant in Downingtown, PA to provide working conditions that do not endanger the safety or health of its employees or the environment. All members of management are expected to actively participate in the safety program. The program is designed to establish and maintain safe and healthful working conditions. A key element in the Plant Safety Plan is the Plant Safety Structure. This safety structure involves coordination of safety activities between a Central Safety Committee, Proctor Meetings, and regular Safety Audits. Ammonia safety is a key item in the Plant Safety Plan. Pepperidge Farm takes many precautions to prevent or minimize accidental releases of ammonia. These precautions include safety controls (alarms and automatic shutdown devices) which are designed to identify and prevent potentially unsafe conditions like pressure increases that could cause a system failu re, a preventive maintenance program designed to maintain the on-going integrity of the system, a training program designed to ensure that the system is operated by qualified personnel, and emergency response procedures which enable trained personnel to respond quickly to system upsets. The Manager, Engineering/Maintenance Manager is responsible for the management of the ammonia safety program. B. Stationary Source and Regulated Substances Handled Pepperidge Farm's Downingtown Plant produces frozen food products for sale to the public. The facility operates an ammonia refrigeration system to provide freezing and cooling for the food products produced. The maximum ammonia inventory at the facility is approximately 24,000 pounds. Ammonia is the only regulated substance handled at the Downingtown Plant. C. Summary of Worst-Case and Alternative Release Scenarios The worst-case release scenario for toxic materials at the Downingtown Plant involves the release of 12,200 pounds of anhydrous ammonia over a 10 minute period due to the failure of the ammonia thermosyphon receiver. This maximum inventory reflects the written administrative procedures in place at the plant to limit the amount of ammonia stored in the receiver during pump down conditions to 90% of its capacity. Under worst-case conditions, the resulting ammonia cloud could have off-site impacts. The alternative release scenario for toxic materials at the Downingtown Plant involves the release of 12,200 pounds of ammonia over a 23 minute period due to the rupture of a 1/2" high pressure liquid line in the engine room. Under alternative release conditions, the resulting ammonia cloud could have off-site impacts. The worst-case and alternative release scenarios for toxic materials are unlikely for the following reasons: o The weather conditions that were used for the worst-case release scenario do not occur, while those used for the alternative case are uncommon; o Industry standards are followe d for the design and manufacture of the equipment in the ammonia refrigeration system; o The thermosyphon receiver and the high pressure liquid lines are located in enclosed areas that should help to contain any ammonia releases; o The engine room contains ammonia detectors and ventilation fans that should detect and mitigate the effects of any ammonia releases; o Ammonia is not corrosive in this service; o The facility has a preventive maintenance program in place to maintain the on-going integrity of the ammonia refrigeration equipment; o The facility has a training program designed to ensure that the system is operated by qualified personnel; and, o The facility emergency response procedures that enable trained personnel to respond quickly to isolate any potential releases. D. Description of the Accidental Release Prevention Program The facility has a program level 3 accident release prevention program for the ammonia system that complies with OSHA's Process Safety Management S tandard and EPA's Risk Management Program Regulation. The ammonia prevention program consists of the following elements: o Employee Participation Program o Process Safety Information o Process Hazard Analysis o Operating Procedures o Training Program o Contractor Safety Program o Pre-Startup Safety Review Procedures o Mechanical Integrity Program o Hot Work Permit Procedures o Management of Change Procedures o Incident Investigation Procedures o Compliance Audit Procedures E. Five-Year Accident History There have not been any ammonia-related incidents at the Downingtown Plant during the previous five years that resulted in significant on-site or offsite consequences. F. Description of the Emergency Response Program An emergency response program has been implemented at the Pepperidge Plant. This program contains procedures describing how the facility will respond to fires and other emergencies, including evacuation procedures. The emergency response program includes the following elements: o Designation of an Emergency Crisis Organization o Evacuation Procedures o Response Activities The program has been coordinated with the Downingtown Fire Department. G. Planned Changes to Improve Safety One change was recommended to improve the equipment and the system operating procedures when the ammonia refrigeration system was analyzed in February 1995. The recommended change has been evaluated and will be implemented as required. |