Lender's Bagel Bakery - West Seneca Plant - Executive Summary |
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Lender's Bagel Bakery manufactures a variety of bagels at our bakery in West Seneca. We have produced bagels in West Seneca since 1976. We have a strong commitment to operate our facility in a safe and responsible manner. Ammonia is used at our facility as the cooling medium in our refrigeration systems. Similar to the function Freon plays in a home or car air conditioning system, ammonia is used to cool the air in our industrial freezers and product coolers. The ammonia is contained in a closed loop system; it is designed to remain inside the piping and vessels in our facility. We believe that ammonia provides the safest and most efficient cooling choice for our operation. A. Describe the Accident Release Prevention and Emergency Policies Lender's takes many precautions to prevent or minimize accidental releases of ammonia from the refrigeration systems. These precautions include safety controls (alarms and automatic shutdown devices) which are designed to identify and preve nt potentially unsafe conditions like pressure increases that could cause a system failure. We also have a preventive maintenance program designed to maintain the on-going integrity of the systems, a training program designed to ensure that the systems are operated by qualified personnel, and emergency response procedures which enable trained personnel to respond quickly to system upsets. The Technical Manager is responsible for the management of these ammonia safety programs. B. Stationary Source and Regulated Substances Handled Lender's Bagel Bakery produces frozen bagels for sale to the public. The facility operates two ammonia refrigeration systems. The ammonia inventory for both refrigeration systems is approximately 25,000 pounds. Ammonia is the only substance covered by the Accidental Release Prevention Regulations handled at the West Seneca Plant. C. Summary of Worst-Case and Alternative Release Scenarios EPA requires us to define the worst case release scena rio as the release of all the ammonia from the largest vessel on site. For our West Seneca plant, this would be 6,000 pounds due to the failure of the high pressure receiver. The 6,000 pounds represents the maximum amount of ammonia that would be contained in the receiver at any time. We have written procedures in place to assure that this is so. EPA also requires us to assume that the weather conditions are such that there is almost no wind and no mixing in the atmosphere. The alternative release scenario at the West Seneca plant would involve the release of 1,400 pounds of ammonia over a 2.6-minute period due to the rupture of a 1/2" receiver sight glass in the refrigeration system. The duration of the release was determined for the alternative release scenario by estimating the amount of time needed for the receiver to empty. Again, EPA required us to estimate the impacts of this release under low wind and stable weather conditions. Both of these releases are unlikely for m any reasons. Our equipment and system were designed using industry standards for ammonia refrigeration. We have taken precautions to protect our equipment from obvious threats, like vehicular traffic. We have a preventive maintenance program to maintain the on-going integrity of the refrigeration equipment. Training programs are in place to ensure that qualified personnel operate the systems, and our emergency response procedures allow us to respond quickly in the event of an accident. D. Description of the Accidental Release Prevention Program The facility has an accident release prevention program that complies with the Occupational Safety and Health Act's Process Safety Management Standard and EPA's Risk Management Program Regulation. The prevention program consists of the following elements: - Employee Participation Program - Process Safety Information - Process Hazard Analysis - Operating Procedures - Training Program - Contractor Safety Program - Pre-Startup Sa fety Review Procedures - Mechanical Integrity Program - Hot Work Permit Procedures - Management of Change Procedures - Incident Investigation Procedures - Compliance Audit Procedures E. Five-Year Accident History There have been no accidents at the West Seneca Plant during the past five years. F. Description of the Emergency Response Program An emergency response program has been implemented at the West Seneca Plant. This program contains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures. The plant has an on-site employee response team trained to enter and stop an accidental ammonia release. This team meets regularly for training and practice drills. We have conducted an emergency drill with the local fire department and other local response agencies. G. Planned Changes to Improve Safety Lender's Bagel Bakery is committed to operating our ammonia refrigeration system in a safe and respo nsible manner. We are continually evaluating our equipment and procedures to meet this objective. Planned improvements include updates to our written operating procedures and an increased focus on contractor safety. |