Emmpak Foods Distribution Center - Executive Summary |
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The Emmpak Foods Distribution Center 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. Emmpak Foods Distribution Center 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 personne l, augmented 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 Emmpak Foods Distribution Center "Emergency Evacuation and Contingency Plan" has been developed in concert with the Milwaukee Fire Department and the Milwaukee 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 Emmpak Foods Distribution Center 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 inc idents involving ammonia refrigeration. The Emmpak Foods Distribution Center is located at 11225 West County Line Road. This facility is a cold storage facility. The facility utilizes anhydrous ammonia as a refrigerant to maintain the proper temperature of finished products. Anhydrous ammonia is an effective refrigerant that has been used for many years by most storage 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. Emmpak Foods Distribution Center operates one distinct ammonia refrigeration system within the facility. The Emmpak Foods Distribution Center refrigeration systems are designed to provide the following: ? operating flexibility (through availability of multiple operating equipment combinations); ? economy and efficiency of operations (through the use of operating pressures commensurate with the degree of cooling required; ? optimal sa fety 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. Emmpak Foods Distribution Center has developed its worst case release scenario assuming that the largest vessel, the High Pressure Receiver/Thermosyphon, normally operated at 40% capacity, ruptured, releasing 7609 pounds of ammonia within the Machinery Room. The mitigated release rate of ammonia has been calculated to be approximately 155.2 pounds per minute. This release has a toxic end-point of approximately 0.62 miles. This scenario was developed utilizing EPA"s "Risk Management Guidelines". It should be noted that such a release is highly improbable, as all Emmpak Foods Distribution Center refrigeration equipment is designed, fabricated, installed and oper ated 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. Emmpak Foods Distribution Center has developed its alternative release scenario assuming a safety relief valve has discharged at a rate of 58 pounds per minute for 10 minutes. This release has a toxic end-point of 0.09 miles. There have been no releases of ammonia from the refrigeration systems during the past five years, since this is a new install ation. The Emmpak Foods Distribution Center 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 Milwaukee County Local Emergency Planning Committee (LEPC) and the Milwaukee 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. |