Gorton's - Executive Summary

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                         RISK MANAGEMENT PROGRAM 
                                                    EXECUTIVE SUMMARY 
1.  General accidental release and prevention policy of Gorton's. 
Gorton' is a frozen seafood processing facility that utilizes anhydrous ammonia as a 
refrigerant. Anhydrous ammonia is considered extremely hazardous by the Environmental 
Protection Agency. 
The same properties that make ammonia a valuable refrigerant also makes it necessary to 
observe certain safety precautions during it's use to prevent exposure to our workers, 
the surrounding community and the environment. 
It is our policy at Gorton's to implement the requirements of the Risk Management 
Program by managing and operating this facility in full compliance with all applicable 
federal and state regulations that we are governed by. The objective is to minimize the 
risk of an accidental release of hazardous materials. Our plant personnel have been 
trained on equipm 
ent operating procedures 
and various safety devices incorporated in our facility to prevent accidental releases. If 
a situation arises beyond the capability of Gorton's personnel, their refrigeration 
contractor, (Recco) is used 
as a response team with possible assistance from the State Hazardous Materials 
Response Team. 
2.  Stationary source and regulated substance handled. 
Gorton's, 127 Rogers Street, Gloucester, Massachusetts operates a refrigeration 
system utilizing anhydrous ammonia as the primary refrigerant. Mechanical 
refrigeration is a thermodynamic process where the refrigerant, ammonia, is used as 
a heat exchanging fluid to maintain a desired temperature in an enclosed 
environment. The refrigeration cycle consists of evaporation, compression, 
condensation and expansion. Evaporation and condensation are designed to alter the 
quantity of energy associated with the refrigerant. Compression and expansion are 
designed to 
change the availability of the associated energy. The refr 
igeration cycle is a closed 
loop process. The ammonia cycle utilizes fluid temperature, pressure and latent heat of 
vaporization for cooling. The refrigeration system uses this phenomenon to remove heat 
from a desired space, and then to discard that heat through condensation, to an area 
where it is of no consequence. 
Gorton's facility adjoins an Americold Cold Storage facility that receives finished 
product from Gorton's.  The refrigeration system is actually a spilt system that is 
operated by Americold. Americold operates the machine room (compressors, condenser, 
receivers) while Gorton's 
operates and maintains the low side of the system, (pump receivers, coil evaporators, 
water chillers and coolers) to maintain processing, freezer and holding room 
temperatures required for the processing and storage of our product. There are 
approximately 400 employees at this facility, including hourly and salary personnel, 
that manufacture and prepare shipment of frozen seafood products via truck 
approximately 24 hours a day, five days a week. 
The refrigeration system contains 40,000 pounds of aggregate ammonia. The potential 
that could lead to an accidental release of the ammonia include, but are not limited 
to, equipment failure, damage to piping, damage to equipment, human error, etc. 
Although ammonia is a colorless, tasteless liquid, it's dominant characteristic is 
it's pungent, distinct odor.  Persons exposed to ammonia will not voluntarily stay in 
areas of even small concentrations, although these levels would not normally result in 
any health risks. Risks from accidental exposure to ammonia in a vapor state are 
irritations to the eyes, nose and throat. The extent of irritation depends on the 
exposure amount and length of time exposed. 
Ammonia is classified non-flammable by the Department of Transportation.  Ammonia will 
but only in a very narrow concentration level when accompanied with an ignition 
3. Worst case  and alternate case release sce 
narios including administrative and 
engineering controls to limit/ prevent accidental release. 
Worst case scenario depicts continuous source leak from the Low Pressure Pump 
Receiver located in a yard area adjacent to the Americold machine room. The 
receivers normal operating level is 4,400 pounds of ammonia. Although the 
receivers total capacity is 8,800 pounds, this exceeds engineering controls which 
limit the liquid level to a maximum of 80% at any time. 
Considering the "catastrophic" possibility does exist for this vessel to release it's 
entire contents, engineering controls incorporated into the system would normally prevent 
such a release. 
   Worst case release scenario criteria for the Gorton's 
    Ammonia Quantity:                  4,400 pounds 
    Rate of Release:                   440 lbs / min. (10 
    min. release) LOC (Level of Concern):            200 
    ppm  (EPA ERPG-2) 
    Physical State:                    Gas 
e of Area:                     Urban 
    Wind Speed:                        1.5 m/sec 
    Distance to Endpoint                    1.3 miles 
Alternate release scenario is represented by the release of ammonia vapor from a 
safety relief valve (SRV) due to an over-pressurization condition on the pump 
recirculator vessel located in 
the yard area. The indicated relief valve would be performing exactly as it is designed 
to do during an over-pressurization condition. Valve would open to relieve the over- 
pressure and vent into the atmosphere via the roof vent pipe. 
    Alternate case release scenario criteria for the Gorton's facility. 
    Ammonia Quantity:                  225 pounds 
    Rate of Release:                         16 pounds/min. (25 min. release) 
    Wind Speed:                        3.0 m/sec. 
    Distance to Endpoint:                   .1 miles 
    The following administrative and engineering controls are in place 
at Gorton's. 
These controls are designed to e 
liminate, or reduce the possibilities of an 
accidental release from the refrigeration system. 
    *  Electronic ammonia detection installed in +20 Room on second floor. Alarm 
activates a local visual and audible alarm to alert plant personnel of the potential 
ammonia leak in the monitored area. Detection system is monitored 24 hours a day. 
Security company monitoring 
system will alert proper personnel in the event of a detection. 
    *  High liquid level switches are configured to pump recirculators. High level 
switches will shut down associated compressor operation during a high level condition. 
    * All compressors (Americold monitored) are configured with critical safety 
controls (high pressure, low pressure, high oil temp cut-outs, etc.) to shut down the 
respective compressor in the event of an abnormal operating condition. 
    *  Safety Relief Valves are configured to all pressure vessels, condensers and 
oil separators to eliminate over pressurization condi 
tions in those associated pieces 
    of equipment. *  Periodic Maintenance Program is in place within Gorton's and 
    Americold's maintenance 
department to ensure the refrigeration system and it's components are kept in optimum 
mechanical and operating status. Weekly rounds are made by plant personnel to verify 
proper equipment operation. 
*  Security personnel on premises 24 hours a day, seven days a week to monitor facility 
access as well as make rounds to detect malfunctions within the refrigeration 
4.  Five-year accident history. 
The Gorton's facility  has had zero accidental releases to report. 
5.   Emergency Action Program 
The purpose of Gorton's Emergency Action Plan is to: 
1.   Minimize exposure to our employees and the surrounding community in the event of a 
    hazardous material release or spill. 
2.  Assure the safe emergency evacuation of the plant in the instance that it is 
3.  Provide for prompt medical attention to any employees who become seriously injured 
    or ill at work. 
4.  Facility management has developed an Emergency Action Plan to ensure a fast and 
          efficient response in the event of an accidental release of hazardous 
Our Emergency Action Plan currently meets requirements as set forth in OSHA 29 
CFR        1910.38, 
Employee Emergency and Fire Prevention Plans.
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