Milkco, Inc. - Executive Summary
MILKCO, INC. |
ASHEVILLE, NORTH CAROLINA
RISK MANAGEMENT PLAN
EXECUTIVE SUMMARY (40 CFR 68.155)
In accordance with Title 40 of the Code of Federal Regulations Chapter 68 (40 CFR 68) promulgated by the Environmental Protection Agency (EPA), Milkco, Inc. (Milkco) submits this Risk Management Plan (RMP) for operations at their Asheville, North Carolina facility. Milkco's operations include the processing and packaging of milk products, orange juice and flavored drink products. Milkco has been in operation at this facility for over 17 years and provides over 250 jobs to the local community.
Accidental Release Prevention and Emergency Response Policy
Milkco is committed to protecting the health of its employees, the surrounding community, and the environment; therefore it is Milkco policy to maintain compliance with 40 CFR 68 as well as Occupational Safety and Health Organization (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of
Federal Regulations Chapter 1910, Section 119 (29 CFR 1910.119), and OSHA's Hazardous Operations and Emergency Response regulations (29 CFR 1910.120).
Stationary Sources and Regulated Substances
Milkco is required to maintain low temperatures in the milk processing areas of the plant that are within standards required by the United States Department of Agriculture (USDA) to ensure quality in the final products. Milkco uses anhydrous ammonia as a refrigerant to maintain the 18,000 ft2 storage area within the required range of operating temperatures. Milkco's refrigeration system consisting of a high-pressure receiver, recirculator, compressors, evaporators, condensers, and piping can contain a quantity of anhydrous ammonia in excess of the 10,000 pound threshold given in 40 CFR 68 Appendix A.
Worst Case Release Scenario
As required by 40 CFR 68 Subpart B, Milkco has evaluated a worst-case release scenario for anhydrous ammonia using the parameters specified by the EPA. Milkco's w
orst case release scenario is the rupture of the largest single tank (high-pressure receiver) over a 10 minute period. In developing the release parameters of this worst-case scenario, Milkco considered passive mitigation provided by the building structure. Using the EPA's RMP*Comp( program, it was determined that the distance to the toxic endpoint in this worst-case scenario has the potential to result in an offsite release. The worst-case release scenario was developed following EPA regulations and is not considered to be a likely release scenario.
Alternative Release Scenarios
Milkco evaluated several options to be considered as alternative release scenarios. After careful consideration, Milkco decided to include two alternative release scenarios in their RMP document. The alternative release scenarios were developed for evaluation because they are expected to be more likely to occur than the worst-case scenario.
The first alternate release scenario (Alternative Release Scen
ario 1) identified by Milkco would be the failure of a transfer hose. In developing the release parameters of Alternative Release Scenario 1, Milkco considered average response time to shut the system down. The other alternate release scenario (Alternative Release Scenario 2) identified by Milkco would be a 1/2-inch process piping break. In developing the release parameters of Alternative Release Scenario 2, Milkco considered average response time to shut the system down and passive mitigation provided by the building structure. Using EPA's RMP*Comp( program and EPA's RMP Offsite Consequence Analysis Guidance Document, the distance to the toxic endpoint in either alternative release scenario has the potential to result in offsite consequences.
Accidental Release Prevention Program
To prevent and mitigate accidental releases of anhydrous ammonia, Milkco has implemented several precautionary measures. Milkco has developed and implemented a process safety management (PSM) program.
As such, the anhydrous ammonia system has been evaluated for release potential. Some of the controls installed to prevent catastrophic releases of ammonia are process equipment (vents, relief valves, check valves and manual shutoffs) and automated controls (leak detection sensors, interlocks and automatic shutoffs via remote switch or computer modem).
Milkco has developed standard operating procedures (SOPs) with incorporated safety measures for all employees and contractors that have contact with the ammonia refrigeration system. Milkco encourages employee participation in the development of the control measures used at the plant. Employees have the opportunity to voice opinions, concerns, questions, or ideas during the monthly training sessions or during the quarterly safety meetings. Conversely, Milkco employees may approach their supervisor directly or place suggestions in the suggestion box for topics that require more immediate attention.
Milkco understands that maintain
ing the refrigeration system in good working order is essential to preventing accidental releases. As such, an independent engineering company conducts preventive maintenance on the process equipment on a monthly basis. The preventive maintenance program is scheduled, documented and managed to ensure that regular maintenance occurs on the system. In addition, an independent third party conducts testing (thermographic studies) semi-annually to ensure the mechanical integrity of critical refrigeration system components.
To confirm that control measures are effective in maintaining the safe operation of the plant, regularly scheduled audits are performed on the ammonia refrigeration system. In accordance with the PSM program, Milkco will conduct compliance audits every three years. Since the ammonia system was recently installed in 1997, the first compliance audit will be conducted in the year 2000. The local fire department does not conduct formal audits; however, Milkco occasiona
lly invites the fire department to tour the facility. In addition, the following agencies audit the Milkco facility on a regular basis:
* North Carolina Department of Environmental Health and Natural Resources - Monthly
* North Carolina Department of Agriculture - Bimonthly
* Military Inspectors - Semi-annually
* Company's Insurance Carrier - Annually
* Department of Labor - Annually
* Food and Drug Administration - Biannually
Five-Year Accident History
Over the last five years, Milkco has not experienced an accidental offsite release of anhydrous ammonia.
Emergency Response Program
Milkco has documented emergency response procedures in order to facilitate response efforts in the event of an offsite anhydrous ammonia release. Included in the emergency response program are measures to be taken internally by Milkco and procedures to inform local emergency response agencies.
Milkco has trained approximately 17 on-site personnel to respond to accidental ammonia releases and other em
ergencies. These personnel are trained in accordance with 29 CFR 1910.120, OSHA's Hazardous Operations and Emergency Response regulations according to their duties and function. Five of these personnel are trained to the level of Incident Commander and 12 personnel are trained to the technician level. They receive annual update training.
To assure that the local municipal response agencies are familiar with Milkco's emergency response procedures, copies of the emergency response document have been submitted for review and approval by the local agencies. Buncombe County Emergency Management Committee (EMC) has reviewed Milkco's emergency response procedures. In the event of an anhydrous ammonia release resulting in offsite consequences, the general public will be notified by the EMC.
Planned Changes to Improve Safety
Milkco is currently in the process of installing a fire sprinkler system with automated and manual controls. Also, Milkco has implemented a continuous training pro
gram to improve safety awareness.