Bama Frozen Dough - Executive Summary

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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 
 
The Bama Frozen Dough facility abides by the emergency response procedures and policies detailed in the Bama Frozen Dough Safety Plan manual.  This Plan was designed to meet the following objectives: 
 
   1.)    To save lives. 
   2.)    To minimize and avoid injuries. 
   3.)    To protect the environment. 
   4.)    To minimize property damage. 
 
Bama Frozen Dough maintains an emergency response committee whose members are the designated emergency coordinators for the facility.  The Plan provides the response organization and notification procedures, evacuation routes, ammonia health hazards, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility.  This Plan is reviewed and updated at least once per year.  This Plan was reviewed and updated to ensure compliance with the PSM and RMP regulations, as well as to incorporate any facility changes.  
 
STATIONARY SOURCE AND REGULAT 
ED SUBSTANCE 
 
    The Bama Frozen Dough facility prepares bread products for distribution.  The refrigeration process, consisting of piping, valves, and equipment, cycles ammonia through various physical states (high pressure liquid, low pressure liquid, low pressure vapor, high pressure vapor, then back to high pressure liquid) in order to provide refrigeration for process equipment and cold storage rooms.  Changes in pressure are directly related to changes in temperature.  For example, lowering the ammonia pressure lowers its temperature.  Low pressure (cold) liquid ammonia provides refrigeration by removing ambient heat.  Removal of ambient heat causes the liquid ammonia (contained within the system) to vaporize.  Heat is later removed from the ammonia as it is condensed back into a liquid.  Typical operating conditions range from vacuum (approximately 12" Hg) on the low pressure side of the system to 150-160 psig on the high side. 
                                    
    Ammonia is used as the refrigerant in th 
e refrigeration process. 
 
    The total ammonia inventory is 31300 pounds.   
 
 
HAZARD ASSESSMENT SUMMARY 
 
Worst Case Release Summary 
 
   The worst case release for this facility was that of the maximum quantity of ammonia that can be stored in a vessel.  The largest vessel, PR-1, is located inside the engine room and has a maximum capacity of 13,000 pounds.  This quantity was released in 10 minutes.  This vessel is located inside a building; therefore, the enclosure was used as a passive mitigation measure. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed, and F stability.  The facility is located in an urban setting.  The downwind distance was determined using Exhibit 4-4 from the EPA "Risk Management Program Guidance for Ammonia Refrigeration", November 1998.  The release reaches off-site and may affect population receptors.  No environmental receptors are affected by this potential scenario. 
 
Alternative Release Result Summary 
 
   The alternative rele 
ase scenario was that of a 0.75 inch diameter leak of high pressure gas ammonia for one hour.  This scenario was chosen because the facility has a 0.75 inch ammonia gas line that is located outside the building. The quantity of ammonia released in one hour at this rate is 3,180 pounds.  The meteorological conditions used were 3 meters/second wind speed, and D stability. The facility is located in an urban setting.  The downwind distance to 200 ppm was determined using Exhibit 4-5 from the EPA "Risk Management Program Guidance for Ammonia Refrigeration", November 1998.  The release reaches off-site and may affect population receptors.  No environmental receptors are affected by this potential scenario. 
 
ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS 
 
The facility operates in accordance with the International Institute of Ammonia Refrigeration (IIAR) guidelines and standards including the following: 
 
?    IIAR Bulletin 107, "Suggested Safety and Operating Proce 
dures When Making Ammonia Refrigeration Tie-ins" 
?    IIAR Bulletin 109, "Minimum Safety Criteria for a Safe Ammonia Refrigeration System" 
?    IIAR Bulletin 110, "Startup, Inspection, and Maintenance of Ammonia Refrigeration Systems" 
?    IIAR Publication R-1, "A Guide to Good Practices for the Operation of an Ammonia Refrigeration System" 
 
In addition, the Bama Frozen Dough has implemented a Process Safety Management program for compliance with the OSHA 1910.119 regulation since September 1995. 
 
FIVE YEAR ACCIDENT HISTORY 
 
Since April 1994 through June 2000, there have been no releases involving ammonia, the regulated substance.  
 
EMERGENCY RESPONSE PROGRAM 
 
The Bama Frozen Dough has an Emergency Response Program in place.  The facility has an Emergency Response Team that is trained to First Responder Technician Level on an annual basis.  All Emergency Response Team members are fit tested and respiratory trained annually.    
 
 
PLANNED CHANGES TO IMPROVE SAFETY 
 
The Process Safety Management t 
eam is planning to complete several items over the next year as their continued effort to provide a safe work environment for the Bama Frozen Dough employees.  These changes include the following items: 
 
1.     Continue to train all employees in Process Safety Management and the Bama Safety Plan/Programs. 
 
2.     Continue to have employee involvement in Safety Plan Development. 
 
3.     Continue employee involvement through safety team participation. 
 
4.     Continue internal and external safety audits/inspections and implement changes as needed.
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