Hanover Foods Corp - Clayton, DE Plant - Executive Summary |
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Accidental Release Prevention and Emergency Response Policies Hanover Foods is commited to the safe operation of our facility. This commitment is demonstrated by the signjficant use of resources expended in process control equipment, employee training, and management oversight. Hanover Foods uses a written safety policy that outlines our concern and commitment to safety. Facility Descriptionand Regulated Substance Handled Hanover Foods is a diverse processor of fresh, frozen and canned food products. The Clayton, Delaware facility, the subject of this RMP, processes frozen foods only. The plant uses anhydrous ammonia as a refrigerant due to its unique properties. The ammonia refrigeration system consists of a main receiver, six freezers, three cold storage units, two chiller rooms, and associated piping and process control equipment. The maximum amount of ammonia in the system at any time is 71,000 pounds. Ammonia is the only EPA RMP regulated substance exceeding the thresh old quantity at the site. The ammonia refrigeration system falls under Prevention Program 3 of the RMP. Worst Case and Alternate Release Scenarios The worst-case release scenario is the catastrophic release of 18,000 pounds of ammonia from the main receiver, which is the largest vessel in the system. In accordance with the RMP regulation, the release was modeled over a 10-minute period with no mitigating factors. The distance to the toxic endpoint of 0.14 mg/L would reach off-site receptors. EPA's model, RMP*Comp, was used in calculating the extent of the release. Because the probability of the worst-case release scenario is minute, EPA allows calculation of an alternative release scenario. Hanover Food's alternate release scenario, although unlikely to occur, has a greater chance of occuring than the worst-case release. Hanover Food's alternative release scenario is a hose leak on the liquid side of the automerio, which is a freezer. Ammonia would be released at an estimat ed rate of 62 pounds per minute for 3.5 minutes. The automerio is located inside a building, which provides a passive mitigating factor. The room in which the automerio is located is staffed at all times, and the leak could be stopped within 3.5 minutes. This provides an active mitigating factor. The distance to the toxic endpoint would not reach an off-site receptor. RMP*Comp was used in calculating the distance to the toxic endpoint. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps Hanover Foods understands the risks of using ammonia, and has several active programs in place to mitigate any potential problems. We are subject to OSHA Process Safety Management and utilize the 12 elements, including process hazards analysis, standard operating procedures, and employee training, to manage our system. All changes are reviewed by our management of change system, and process hazard reviews are conducted before being placed into operation. This f acility is staffed by qualified refrigeration personnel 24 hours a day for 365 days a year. Hanover Foods has three ammonia detection monitors placed throughout the refrigeration system. The monitors are set to alarm if an ammonia leak is detected. Five-Year Accident History Hanover Foods has had no ammonia releases in the past five years that resulted in on-site deaths, injuries, or significant property damage, or off-site deaths, injuries, property damage, environmental damage, evacuations, or sheltering in place. Emergency Response Program Hanover Foods maintains a written emergency response plan that includes evacuation procedures, emergency coodinator responsibilities, notification procedures, and emergency medical procedures. We have a fully staffed and trained emergency response team that would respond to an ammonia emergency at the site. Our team receives annual training on emergency response. Planned Changes to Improve Safety Hanover Foods provides ongoing traini ng to its employees, and we are member of the Refrigeration Engineers and Technicians Association (RETA). We will continue to use RETA's guidelines in managing our ammonia refrigeration system. |