Johnsonville Sausage Company - Executive Summary |
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The Johnsonville Sausage Company is committed to promoting a safe operating environment for the facility, its employees and the surrounding community. The facility is complying with OSHA's Process Safety Management (PSM) standard, and EPA" Risk Management Program rule. The purpose of these regulations is to ensure that the covered process (ammonia refrigeration) is designed, operated and maintained safely. Compliance with these regulations helps prevent ammonia releases from the process. Additionally, these regulations required development of procedures to minimize releases of ammonia in the event that they do occur, and to outline appropriate emergency response steps to take in the event of a release. Johnsonville Sausage Company has implemented a Process Safety Management program for its ammonia refrigeration process operation and maintenance. This was accomplished through the development of a PSM Team comprised of Operations, Maintenance, Safety and Engineering personnel, augmen ted by the support of refrigeration contractor personnel. The PSM Program has been incorporated as both policy, and most importantly, procedure in every day operations and maintenance of the ammonia refrigeration system. The Johnsonville Sausage Company "Emergency Evacuation and Contingency Plan" has been developed in concert with the Johnsonville Fire Department and the Sheboygan County Emergency Response Government. The plan addressed fire, explosion, spills or releases of toxics, severe weather and other criteria. The plan details response actions by the Johnsonville Foods Emergency Response Team for such emergencies, safety and emergency equipment, communication responsibilities, and coordination with off-site responders. The plan includes "Emergency Response to Anhydrous Ammonia", specifically addressing incidents involving ammonia refrigeration. The Johnsonville Sausage Company is located at 4202 County Highway J, Sheboygan Falls, Wisconsin, 53085. This facility produces sausages. The facility utilizes anhydrous ammonia as a refrigerant to maintain the proper temperature of ingredients, processes, and finished products. Anhydrous ammonia is an effective refrigerant that has been used for many years by most food processing facilities. Anhydrous ammonia is normally a gas at ambient temperatures and atmospheric pressure, but it is utilized in the refrigeration process as a gas liquefied under pressure. Johnsonville Sausage Company operates three distinct ammonia refrigeration systems within the facility: The Countryside system; the Nu-Temp system; and the Logistics system. These three systems are normally operated isolated from each other, and independently of each other. The Johnsonville Foods refrigeration systems are designed to provide the following: ? operating flexibility (through availability of m ultiple operating equipment combinations); ? economy and efficiency of operations (through the use of operating pressures commensurate with the degree of cooling required; ? optimal safety performance (through minimal use of ammonia liquid pumps, utilizing instead the pressure differentials established in the system to move liquid refrigerant; and ? consistency of operation, utilizing programmable logic controllers (PLCs) to monitor, record, operate and modulate refrigeration equipment as conditions require. Johnsonville Sausage Company has developed its worst case release scenario assuming that the largest vessel, the +25 F intercooler, normally operated at 30% capacity, has filled to 100 % and ruptured, releasing 13,070 pounds of ammonia within the Machinery Room. The mitigated release rate of ammonia has been calculated to be approximately 270 pounds per minute. This release has a toxic end-point of approximately 1.0 miles. This scenario was developed utilizing EPA"s "Risk Manag ement Guidelines". It should be noted that such a release is highly improbable, as all Johnsonville Sausage Company refrigeration equipment is designed, fabricated installed and operated consistent with IIAR, ASME and Wisconsin Administrative Code specifications. Precautions that would make such a scenario unlikely include: the vessels are enclosed in a building that would withstand and help to contain such a release; ammonia is not corrosive in these service conditions; pressure relief safety valves limit the operating pressures in this vessel; the prevention program in place at the facility includes a mechanical integrity program for regular maintenance, testing and inspection; installed ammonia sensors warn of leaks in the process; and an emergency response team, plan and equipment is in place at the facility. Johnsonville Sausage Company has developed its alternative release scenario assuming the safety relief valve has discharged at a rate of 130 pounds per minute for 10 minu tes. This release has a toxic end-point of 0.2 miles. There have been minor releases of ammonia from the refrigeration systems during the past five years, associated with the construction, testing, and start-up that could be expected with the growth and expansion of the facility and the refrigeration process. None of these releases resulted in injury, evacuation, or off-site restoration. The Johnsonville Sausage Company emergency response program is based on the OSHA requirements for Emergency Action Plans (29 CFR 1910.38 and 1910.119) and HAZWOPER (29 CFR 1910.120). We have trained employees for emergency response and maintain a written response plan. The plan is coordinated with the Sheboygan County Local Emergency Planning Committee (LEPC) and the Johnsonville Fire Department. We conduct periodic drills for implementation of the emergency response plan at the facility, and anticipated increased participation with the LEPC and Fire Department. |