Ross Products Division - Executive Summary |
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This Abbott Laboratories, Ross Products Division (Ross) facility is located at 585-625 Cleveland Avenue in Columbus, Ohio. Ross manufactures infant formula and adult medical nutritional products. This facility also houses research & development, pilot plant and division offices. None of the materials used in the manufacture or packaging of these food products are considered to be regulated substances under Risk Management Program (RMP) regulations. The sole regulated chemical at the facility is ammonia, used in a refrigeration system. All federal requirements of OSHA's Process Safety Management program and U.S. EPA's Risk Management Program are adhered to. The Ross Cleveland Avenue facility operates a single, closed-loop ammonia system. All of the ammonia handling equipment and piping is located in the site's Energy Center. The ammonia system is used to chill water to 33 - 40 degrees F. The frigid water is circulated throughout the plant to cool equipment and storage tanks. At no time does the ammonia come in contact with the water. A detailed description of the ammonia refrigerant process is included in Section 7, under the "Prevention Program Description." Since the system received its initial charge, very little ammonia has been added. Ammonia deliveries and releases are rare occurrences. There have been no accidental releases of ammonia in the past five years. This may be attributed to the facility's accidental release prevention program that combines the newest equipment technologies with detailed operational procedures, training and system management practices. In-plant emergency response procedures have been developed that incorporate both Abbott resources and emergency response services available within Columbus and Franklin County. The site maintains a highly trained work force that is extremely familiar with the ammonia system and able to respond to any contingency. The site also has an Emergency Response Team (ERT) on site which i s staffed on each of the three shifts. ERT members are also trained to OSHA's "Hazardous Materials Technician" level. These ERT members are first responders for any site emergency and are specifically trained to assist Energy Center Personnel with any situation that may arise. Implementation and maintenance of systems and programs discussed in this report have the full support of Abbott management. Abbott has a global environmental, health & safety policy that applies to all Abbott locations worldwide. The policy explicitly requires all locations to: "maintain a safe and healthy workplace and environment;" and, "comply with all applicable laws... designed to protect human health, safety and the environment.' The site's general accidental release prevention program is based on the following key elements: High level of training for the operators; Preventive Maintenance Program; State-of-the-art process and safety equipment; Accurately written operating procedures, written wi th the participation of the operators; Regular hazard reviews of equipment and procedures; and Ongoing auditing and inspection program. Ammonia-specific exposure prevention steps include: the availability of self-contained breathing apparatus for operators and emergency responders; limited or controlled access to the ammonia equipment rooms; ammonia detectors; and a Process Safety Management program. To ensure continuing proper operation, each piece of ammonia equipment is monitored through the facility's Preventative Maintenance (PM) program. The PMs are generated automatically from a computer database. Equipment is inspected and serviced during these PMs. Equipment condition is documented. In addition to the PM system, each year during the plant shutdown a certified ammonia contractor performs a complete inspection of each compressor. The certified contractors also check other pieces of ammonia equipment such as alarms and control systems. Included in the ammonia system 's list of safety features are relief valves. Safety relief valves allow the system to relieve over pressurization in a controlled manner avoiding a dangerous buildup of pressure. All safety valves are piped into a common relief piping system that has both a rupture disk and an ammonia detector in the piping at the discharge point. The detector is tied into the site's monitoring system and will sound if a reading of 50 ppm is detected. All safety valves are replaced every five years. A "worst-case scenario" using conditions predefined by U.S. EPA requires dispersion modeling to reflect all of the following assumptions: all control devices fail; the Energy Center building collapses; the entire contents of the ammonia system are released into the environment in ten minutes; and atmospheric conditions are selected that minimize downwind mixing. It is Abbott's strong contention that equipment design, rarely opening the system to add or remove ammonia, frequent inspection and maintenanc e, and high level of training provided to site personnel make the actual probability of a "worst case" release an extremely remote occurrence. The results of the worst-case scenario would result in an off-site impact. Depending on wind direction, a long narrow plume could reach one or more of the following potential receptors: residences, schools, recreational areas, industrial and office areas, a hospital or a correctional facility. Modeling and results are summarized in Section 2. The modeling software used was Degadis+ 2.1. An alternate release scenario for the Cleveland Avenue facility involves a break in a liquid level sight glass. The subsequent ammonia release, contained inside of the Energy Center building and promptly correct by site personnel, would result in a much smaller off-site impact. This scenario was selected based on an actual incident that occurred once in site history (but more than five years ago). The alternate scenario results in a much smaller release that dissipates more quickly under average weather conditions. Depending on wind speed and direction, this scenario could affect residences, a school or industrial and office areas. There have been no system changes since the implementation of the PSM program and the "management of change" procedures. However, as recently as the April 1999 process hazard analysis and overall facility safety audit, the safety of the system continues to be examined and improvements continue to be proposed. The most recent recommendations are being evaluated as of this writing. There is one planned improvement to the ammonia system. The Columbus Compressor Assembly Replacement project will rebuild one of the two ammonia compressors. The compressors will be restored to a "new" condition. All leak prevention devices related to the compressor will be upgraded. This project will trigger a "management of change" review and associated updates to system documentation. |