Standard Process Inc. - Executive Summary |
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A. Describe the Accident Release Prevention and Emergency Policies It is the policy of Standard Process that the receipt, storage, and handling of ammonia at its facility in Palmyra, WI be done in a manner that meets regulatory requirements and protects the health and safety of its workers, the public, and the environment. In order to accomplish this goal, Standard Process has: o Gathered safety information on ammonia; o Performed a structured assessment of hazards of the process and external events that might affect the process; o Performed an offsite consequence analysis of defined release scenarios; o Established a written program for prevention and mitigation of releases; and, o Established a written emergency action plan coordinated with emergency response agencies. The Plant Engineer is responsible for the management of the ammonia safety program. B. Stationary Source and Regulated Substances Handled Standard Process's Palmyra Plant produces dietary supplements for sale to the public. The facility operates an ammonia refrigeration system to cool and freeze raw materials and products during processing. The maximum ammonia inventory at the plant will be approximately 14,000 pounds after additional ammonia is added to accommodate system expansions in June, 2000. Ammonia is the only regulated substance handled at the Palmyra Plant above the thresholds in the regulations. C. Summary of Worst-Case and Alternative Release Scenarios The worst-case release scenario at the Palmyra Plant involves the release of 256 pounds of ammonia per minute over a 35 minute period due to the failure of an ammonia vessel. This release rate reflects written administrative procedures in place at the plant to limit the amount of ammonia stored in the vessel to 60% of its capacity. The release rate also assumes that the enclosed engine room would limit the amount of ammonia released to the atmosphere. Under worst-case conditions, the release could have off-site impacts. The alternative release scenario at the Palmyra Plant involves the release of 7 pounds of ammonia per minute over a 60 minute period from a pressure relief valve. Under alternative release conditions, the release could have off-site impacts. The worst-case and alternative release scenarios 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 followed for the design and manufacture of the equipment in the ammonia refrigeration system; o The ammonia vessel is located in an enclosed room, well protected from outside influences; o Pressure safety valves on the vessel should limit any pressure increases inside the vessel; 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 p rogram designed to ensure that the systems are operated by qualified personnel; and, o The facility has 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 developed a program level 3 accident release prevention program for the ammonia system that complies with OSHA's Process Safety Management Standard 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 inci dents at the Palmyra 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 Palmyra Plant. This program contains procedures describing how the facility will respond to fires, ammonia leaks and other emergencies, including evacuation procedures. The emergency response program includes the following elements: o Emergency Notification Information o Facility Evacuation Procedures o Emergency Response Procedures o Documentation and Incident Follow-Up Procedures The program has been coordinated with the Palmyra Fire Department and the Jefferson County Local Emergency Planning Committee (LEPC). G. Planned Changes to Improve Safety Seven changes were recommended to improve the equipment and the system operating procedures when the ammonia system was analyzed in May, 2000. The recommended changes have been evaluated and will be i mplemented as required. |