Welch Foods, Inc. - Lawton, MI - Executive Summary

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Welch Foods, Inc. (Welch's) is a membership cooperative marketing association representing fruit growers. The Welch's facility in Lawton, Michigan is comprised of one fruit juice processing plant owned by Welch's. The facility is involved in production of concentrated fruit juices and by-products. The two processes located within the facility boundary use a chemical subject to the RMP regulation - ammonia - for refrigeration purposes. These are the Central Refrigeration System and the Freezer System. With recent modifications to the refrigeration system' the Central Refrigeration System contains more than the 10,000 pound threshold of ammonia; however, the Freezer System does not exceed the 10,000 pound threshold. 
Pursuant to the RMP regulations (40 CFR 68) and the Process Safety Management (29 CFR 1910.119) standard, Welch's has developed a comprehensive PSM written program to protect workers and the surrounding community from exposure to anhydrous ammonia. The facility completed a p 
rocess hazards analysis (PHA) for ammonia using a modified what-if?/checklist approach. The checklist was an industry standard assessment developed by the International Institute of Ammonia Refrigeration (IIAR). The PHA was completed using technical and operations staff from the Welch's facility and experienced facilitators from an outside engineering firm. 
Welch's implementation of the PSM program includes employee education in the hazards of ammonia and measures that can be used to reduce employee and community exposure to accidental ammonia releases. The plan includes a preventive maintenance program (mechanical integrity) for the ammonia system and a program for both pre-startup safety reviews and management of changes (MOC) to the ammonia refrigeration system. The program also includes specific requirements for safe work practices (such as safe approaches to welding and similar hot work) and safety requirements for contractors who may be hired to work on the refrigeration system. 
Lastly, the PSM written program incorporates the Welch's facility's emergency response plan and places special emphasis on handling accidental releases of ammonia and coordination of emergency response with local fire departments and other emergency response organizations. 
As part of the RMP requirements, Welch's undertook a review of the potential offsite consequences of the accidental release of the largest vessel of ammonia at the facility. Although such a release is highly unlikely, the regulation requires this review. Welch's analysis indicates that such a release would involve the release of the contents of the facility's indoor tank farm accumulator. This release would result in the potential exposure of an area approximately 2.0 miles in diameter (distance to endpoint of 1.0 miles). The total population within this potential exposure area is approximately 924. 
Although the worst-case scenario is highly unlikely, there are accidental release scenarios that might result in a  
release of ammonia affecting employees of surrounding businesses and residents in the surrounding area. Welch's has analyzed incidents occurring at other ammonia refrigeration facilities, past operating experience, and the results of the internal process hazards analysis (PHA), to determine an alternative case. For the Welch's facility, this release is assumed to be a 1/2" hole in the return line from the condenser, located on the roof. Such a release would affect an area approximately 0.36 miles in diameter (distance to endpoint of 0.18 miles). The total population within this potential exposure area is approximately 25. Residences are located within this radius. 
Welch's is committed to minimizing accidental releases from the ammonia refrigeration processes. Facility management is involved in the design, operation, and maintenance of the system. Facility personnel at all levels have been involved in the development of the PSM and RMP programs. Management has committed to working with 
local agencies and the community to educate the public regarding the hazards of ammonia and to ensure a safety workplace and surrounding community. Specific questions regarding Welch's RMP compliance should be addressed to the Plant Manager. 
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