Sorrento Lactalis, Inc. - Executive Summary
SORRENTO LACTALIS LLC |
I. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY POLICIES
Sorrento Lactalis, LLC 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 Sorrento Lactalis, LLC 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. TheSorrento Lactalis, LLC 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 t
he shelf when the filing date has passed.
Sorrento Lactalis, LLC 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,will be deeplly involved in the PSM/RMP program development, implementation and integration and they will assume the major responsibility for operating the Nampa, Idaho facility safely.
The Sorrento Lactalis, LLC Emergency Response Program has been developed with the complete cooperation and support of the Nampa Fire Department. All Sorrento Lactalis, LLC employees have received documented emergency response training.
II. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED
Sorrento Lactalis, LLC manages a Cheese Making operation. The refrigeration system is required for the Processing, storage and distribution of cheese. The refrigeration system contains no more than 20,000 pounds of Anhydrous Ammonia. An
hydrous Ammonia is the only Hazardous Material on site in amounts 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 Receiver.
Administrative and equipment controls specify that thereceiver is not ever filled above 85% capacity. Therefore, a maximum release of 15,500 pounds of ammonia over a 10 minute period was considered.
Under worst case weather conditions ammonia could travel up to 1.5 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 Sorrento Lactalis, LLC
An alternative case release scenario that we call WORST CASE CREDIBLE was slightly more likely.
A 3480 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 .1 mile before dispersing.
This release is very, very unlikely to occur during the life of the Sorrento Lactalis, LLC 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 their 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.
Emergency Response Program
Facility employees have been trained to respond to accidental ammonia release. The site emergency plan has been coordinated with the community emergency plan under the jurisdiction of the Local Emergency Planning Commission (LEPC) and the Nampa, Idaho Fire Department.
VII. PLANNED CHANGES TO IMPROVE SAFETY
Sorento Lactalis, LLC 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.
Sorrento Lactalis, LLC 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 performing the documented Preventive Maintenance Inspections.
(2) The Sorrento Lactalis, LLC 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 theSorrento Lactalis, LLC Ammonia Refrigeration Process. Sorrento Lactalis, LLC 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 unintenti