SOUTHWEST DAIRY - Executive Summary |
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SouthWest Dairy is a milk processing plant owned and operated by Brookshire Grocery Company. SouthWest Dairy produces whole milk, 2% milk, reduced fat milk, 1% milk, skim milk, chocolate milk, reduced fat chocolate milk, chocolate drink, buttermilk, eggnog, and orange juice under the Brookshire Grocery Company private label "Dairy Pride". Red Diamond tea is produced in both sweet and unsweet flavors under the Red Diamond label. SouthWest Dairy uses anhydrous ammonia to keep products at federal mandated temperature levels. There is approximately 21,500 pounds of anhydrous ammonia on site. SouthWest Dairy has been using anhydrous ammonia at this location since the 1930's. There has never been an accidental release that required any type of reporting. All anhydrous ammonia piping, including compressors, was replaced in 1992. The main hazards associated with anhydrous ammonia at this location would include a release of the entire system to the atmosphere. Because of the safeties that are in place at the facility, this would be very unlikely to occur, unless there was an event of major catastrophic relevance, such as a tornado. The entire facility is behind an eight-foot fence with barbed wire at the top. The facility is also under guarded security 24 hours a day, 365 days a year. Relevant offsite receptors include residential neighborhoods, industrial businesses, retail businesses, public schools, and a public park. Offsite consequence analysis for a worst case scenario would be approximately 0.6 of a mile. This scenario could possibly occur in the event of an anhydrous ammonia release from the receiver, which holds approximately 4,355 pounds of ammonia at 75% capacity. This release would be liquid which would then gas off. The alternative scenario would be the one to more likely occur than the worst case scenario. It would involve the release of anhydrous ammonia from a 1/4" hole in an ammonia pipe. This scenario would release anhydrous ammonia at a rate of approxima tely 100 pounds per minute at 155psi until valves upstream and downstream were valved out. SouthWest Dairy's maintenance department has over 100 years of combined experience with anhydrous ammonia. Each maintenance employee is trained every six months in donning SCBA, ammonia respirators, and level A suits. Also, each maintenance employee is trained in confined space rescue.SouthWest Dairy and Brookshire Grocery Company have a very close relationship with the LEPC, Tyler Fire Department and Hazmat Team. We invite them to visit our facility on an annual basis to ensure that they will be familiar with the faciltiy if there is an ammonia release. The Tyler Fire Department and Hazmat Team have recognized the experience that SouthWest Dairy possesses with respect to ammonia reponse, and have asked that the Hazmat team backup SouthWest Dairy's Maintenance personnel in the event of an ammonia release. This confidence in our maintenance personnel is particularly important to top management. An y and all risks associated with the release of anhydrous ammonia are taken very seriously by Brookshire Grocery Company and SouthWest Dairy, and thus are held accountable for the safe operation of the anhydrous ammonia system. If the dairy was to experience a large release, the LEPC, Tyler Police Department and Tyler Fire Department will coordinate any evacuation of affected persons at businesses, homes, etc. All other SouthWest Dairy employees, other than maintenance employees, are annually trained in emergency evacuation if there is an anhydrous ammonia release. Furthermore, any new hires of SouthWest Dairy are trained, before they begin work, to evacuate the premises in the event of a release. Windsocks have strategically been placed outside the facility, so that employees can determine the travel of a release, and go upwind of the release. SouthWest Dairy's ammonia equipment is in an enclosed room that is vented to the atmosphere. All piping is routed to the roof, so that if there were a release, the release would be outdoors. Also, all piping from our silos have been tied into one main header that has been run to the roof and placed an additional twenty feet in the air. SouthWest Dairy also has an "Emergency Anhydrous Ammonia Control Box" outside the facility that would allow the entire system to be shut down manually from a safe distance of a large release. SouthWest Dairy was required in 1997 to comply with the Occupational Safety and Health Standard for Process Safety Management. An OSHA compliance officer viewed this plan in 1998 during a surprise inspection that concentrated on anhydrous ammonia and the safety systems that are in place to ensure the safety of all employees. All recommendations made by the compliance officer were quickly carried out and recognized by the agency as going above and beyond the requirements of the general PSM standard. Furthermore, SouthWest Dairy implemented and continues to conduct a preventative maintenance program to ensure that any and all hazards are addressed to reduce the risk of an anhydrous ammonia release. If there were a release of anhydrous ammonia, SouthWest Dairy has a Pollution Crisis Management and Emergency Response Contingency Plan in place. This plan is updated at least annually or whenever deemed necessary by management and the safety and environmental coordinator. This plan was created to enhance the safety of our employees and the local community. SouthWest Dairy Management, Supervision, Security, and the Tyler Hazmat Team all have copies of this document. Furthermore, it is always available to employees in different areas of the plant for reference or a refresher on what to do in the event of an ammonia release. This plan consists of an emergency notification sheet that has important pager and home telephone numbers listed so that personnel may respond to the situation as it dictates. This is coordinated with the LEPC, police and fire departments that respond to the situation as neces sary regarding any type of evacuation plan. The plan also consists of qualifications and duties for ammonia specialists. Ammonia Specialists are members of the maintenance group. Each Specialist is assigned responsibilities to carry out in the event of a release. These employees have been trained in these roles and have demonstrated the ability to react and follow through with these responsibilities. The plan also consists of emergency numbers for the LEPC (Local Emergency Planning Commission), SERC (State Emergency Response Commission), NRC (National Response Commission), and the TNRCC (Texas Natural Resource Conservation Commission). There is also an MSDS for anhydrous ammonia in the plan. This plan was also viewed and approved by the OSHA Compliance Officer who inspected the dairy in 1998. SouthWest Dairy is always looking for ways to limit the possibility of a major release of anhydrous ammonia. We strongly feel that our relationship with our employees, the responding emergency uni ts, governement agencies, and the community has increased awareness of the hazards that exist at this facility. Working together with these different entities has made SouthWest Dairy a safer place for our employees to work, and a safer place for those who live, work and play in this community. |