The Drescher Corporation - Executive Summary

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Executive Summary 
A.   Describe Accidental Release Prevention and Emergency Policies 
 
The Drescher Corporation is committed to all federal, state and local laws on safety and health in the workplace.  To assist in providing a safe and healthful work environment for Associates, customers, and visitors, Drescher has established a workplace safety program.  This program is a top priority for Drescher.  The Safety Department has the responsibility for implementing, administering, monitoring, and evaluating the safety program.  Its success depends on the alertness and personal commitment of all. 
Drescher provides information to Associates about workplace safety and health issues through regular internal communication channels such as Supervisor-Associate meetings, bulletin board postings, memos, or other written communications.  A safety advisory group has been established to assist in these activities and to facilitate effective communications between Associates and management about workpl 
ace safety and health issues. 
 
Associates and supervisors receive periodic workplace safety training.  The training covers potential safety and health hazards and safe work practices and procedures to eliminate or minimize hazards. 
Each Associate is expected to obey safety rules and to exercise caution in all work activities.  Associates must immediately report any unsafe condition to the appropriate supervisor.  Associates who violate safety standards, who cause hazardous or dangerous situations, or who fail to report or, where appropriate, remedy such situations, may be subject to disciplinary action, up to and including termination of employment. 
 
In the case of accidents that result in injury, regardless of how insignificant the injury may appear, Associates should immediately notify the Safety Director or the appropriate supervisor.  Such reports are necessary to comply with laws and initiate insurance and worker+s compensation benefits procedures. 
Accidental Release Prevention an 
d Emergency Policies are designed to comply with OSHA+s Process Safety Management (PSM) standard (Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119) and EPA+s Risk Management Program (RM program) regulation (Risk Management Programs for Chemical Accidental Release Prevention, 40 CFR Part 68).  
 
The purpose of the accidental release prevention and emergency action programs is to prevent the occurrence, and minimize the consequences, of significant releases of toxic substances as well as fires, explosions, and other types of catastrophic accidents.  Overall, these programs prevent accidental fatalities, injuries and illnesses and avoid physical property damage. 
 
B.  Stationary Source and Regulated Substances Handled 
 
This company operates a freezing and storage warehouse for the perishable food industry.  This facility operates an ammonia refrigeration system to provide cooling and freezing capabilities.  The amount of anhydrous ammonia (CAS #7662-41-7) contained i 
n this system is in excess of 10,000 pounds.  The ammonia inventory of this system is approximately 15,000 lbs.  Since ammonia releases from this system could pose a risk of offsite public impact and is regulated under the OSHA PSM standard (29 CFR 1910.119), the system is subject to the Program 3 requirements of the EPA's RM program. 
 
The closed loop ammonia refrigeration system at The Drescher Corporation, Brownsville, Tennessee, facility provides (2) major suction pressures (temperatures) for use in the preservation of perishable food products. This provides refrigerant temperatures of -20|F. with the use of low suction compressors and provides temperatures of +20| intermediate suction compressors. 
 
The higher pressure portions of the system include the condenser, located on the roof, along with refrigerant vent lines where any leaks can dissipate to the air, joining ammonia produced by lightning where it can be consumed as it goes through a natural biodegrading process.  Normal saf 
eties include: high pressure cut-outs, relief valves, and ventilating systems for machine room areas. 
 
The anhydrous ammonia refrigeration system consists of a Frick Computer Controlled two temperature level, single stage system which operates at -20|F. and +20|F. suction, and condensing with evaporative condensers at 95|F.  The system provides cooling for the storage freezer, dock, two coolers, and the 75|F. dry storage area.   
 
The system is controlled via microprocessors with hot gas defrost control, compressor sequencing, and evaporative condenser fan and pump control.  The system is also capable of remote operation via modem and is capable of temperature monitoring and control. 
 
An ammonia detection system is installed as part of the central control system and will monitor locations where ammonia refrigerant is present.  The system in the engine room will bring on emergency ventilation fans. 
 
C.  Summary of Worst-Case and Alternative  Release Scenarios 
 
The Worst Case Release Scen 
ario is determined to be a catastrophic release from the high pressure receiver V-1.  This vessel operates at ambient temperature and approximately 135 psi. 
 
The V-1 receiver is a vertical vessel and is 7 feet in diameter and 16 feet in length.  When 64% filled, vessel capacity is approximately 15,000 pounds of ammonia. 
 
Assumed is that the release occurs through a circular hole located at the bottom of the vessel.  For this Worst Case Release Scenario, the distance from source to toxic endpoint is 1.4 miles or 7,392 feet. 
 
The worst-case release scenario is unlikely for the following reasons: 
 
The worst-case weather conditions which were used for this scenario are uncommon; 
 
Industry standards were followed for the manufacture and quality control of these vessels; 
 
Ammonia is not corrosive in this service; 
 
Pressure safety valves limit operating pressures in these vessels and vessels have design margins of safety of about 4 to 1. 
 
Alternative Release Scenario Analysis 
 
An Alternative  
Release Scenario is chosen as a pipe failure.  The potential for a pipe failure is significant given the extensive ammonia piping system extending throughout the Facility. 
 
Assumed is the failure of a 1-inch pipe connected to the V-1 receiver.  Using EPA-suggested meteorological parameters for alternative scenarios and following a one-hour release, the distance from release point to the toxic endpoint is 195 yards or 585 feet.  
 
The Alternative Release Scenario is unlikely for the following reasons: 
 
The high pressure liquid lines are located in enclosed areas that could help to contain such a release; 
 
Industry standards were followed for the manufacture and quality control of these lines; 
 
Ammonia is not corrosive in this service; 
 
Vessel design uses a factor of approximately 4 to 1 margin for safety. 
 
Active mitigation considered would be the Emergency Shutdown System which permits system to equalize to 50-60 psig. 
 
D.  Description of the Accidental Release Prevention Program 
 
The 
prevention program (OSHA Process Safety Management CFR 1910.119) consists of the following elements: 
 
Employee Participation 
Process Safety Information 
Process Hazard Analysis 
Operating Procedures 
Training 
Contractors 
Pre-startup Safety Review 
Mechanical Integrity 
Hot Work Permit 
Management of Change 
Incident Investigation 
Compliance Audits 
 
E.  Five-Year Accident History 
 
The ammonia refrigeration system addressed by the study is new.  A five-year accident history is not applicable. 
 
F.  Description of the Emergency Response Program 
 
This facility has an Emergency Action Plan.  The plan contains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures, escape routes, critical operations shutdown procedures, procedures to account for all employees, rescue and medical duties assignment, means of reporting fires and emergencies, name of responsible person, alarm system, training and fire prevention. 
 
G.  Planned Changes 
to Improve Safety 
 
A Process Hazard Analysis was conducted on January 30, 2001.  Any recommendations resulting from this analysis will be evaluated and implemented as required.
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