Agrilink Foods - Bergen - Executive Summary |
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Risk Management Plan Bergen Facility Executive Summary This is to inform all interested persons, including employees that Agrilink Foods is complying with OSHA's Process Safety Management Standard (called Process Safety Management or PSM), Title 29 Code of Federal Regulations (CFR) 1910.119, and EPA's Risk Management Program regulations (called RM Program), Title 40 CFR Part 68, to manage the risks involved with the storage, handling, and processing of hazardous chemicals. In this way we promote overall plant, worker, and public safety. These programs enable our facility to minimize the occurrence and 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. Our safety programs are applied to any activity involving hazardous chemicals including any use, storage, handling, or the on-site movement of such chemicals. Any group of vessels which are interconnected and separate vessels which are located such that a hazardous chemical could be involved in a potential release shall be considered a single process. Our safety programs minimize accidents because they focus on the rules, procedures, and practices that govern individual processes, activities, or equipment. These programs are detailed and improved as necessary. They are also communicated to and accepted by all employees at the facility. Description The ammonia refrigeration process at the facility consists of various pumps, compressors, and condensers that are used to change the state of ammonia from a gas to a liquid in a closed system. The system operation is very similar to the operation of a household refrigerator. We have several independent systems, with the largest system containing 40,000 pounds.The total on site inventory of liquid ammonia is 60,000 pounds and used for the process of freezing whole kernel c ut corn, cob corn, green beans, carrots, and peas. Worst-Case Scenario(s) Failure of the high-pressure receiver containing 40,000 pounds of ammonia with the receiver quantity limited to 40,000 pounds of the vessel capacity by facility procedures resulting in a one-minute release. Under worst-case weather conditions, ammonia could travel 3.6 miles before dispersing enough to no longer pose a hazard to the public or the environment. This scenario is unlikely for the following reasons: worst-case weather conditions are uncommon; industry standards for the manufacture and quality control of pressure vessels; ammonia is not corrosive in this service; pressure safety valves limit operating pressure in this vessel; the accident prevention program in place at the facility including the mechanical integrity program for regular maintenance, inspection and testing, and replacement of equipment, as necessary; installed ammonia sensors in the system to warn of leaks; alarms are in place to warn operating personnel of process upsets; and the emergency response plan and equipment in place at the facility. Alternative Release Scenario(s) Failure of a < inch diameter pipe would result in the release of approximately 6000 pounds of ammonia over a time period of 60 minutes. Under common weather conditions, ammonia could travel 0.2 miles before dispersing enough to no longer pose a hazard to the public or environment. The < inch pipe was chosen because it is used to temporarily bleed off a pump so that maintenance activities can be conducted. This scenario is unlikely due to the following reasons: the pump is isolated with valves in the closed position and only a few pounds of ammonia would be released; the valves to the pump would have to fail completely; the facility has an accident prevention program in place including operational procedures that includes having personnel present at all times during maintenance of a pump; a mechanical integrity program for regular maintenanc e of a pump is in place at the facility; routine inspection and testing of valves is conducted; replacement of defective equipment if necessary; and the facility emergency response plan and equipment in place at the facility. Prevention Program The general accident prevention program and ammonia-specific prevention steps were developed as required and they comply with OSHA PSM Standard 29 CFR 1910.119 and EPA RM Program regulations in 40 CFR Part 68. The key prevention steps at the facility consist of the following: 7 Process Safety Information 7 Process Hazard Analysis 7 Standard Operating Procedures 7 Training 7 Mechanical Integrity Program 7 Management of Change 7 Pre-startup Safety Review 7 Compliance Audits 7 Incident Investigation 7 Employee Participation 7 Hot Work Permit 7 Contractor Qualifications Five Year Accident History There has been only one (1) release of ammonia over the past five years, which was on July 16, 1996. That incident resulted in a minor injury to a n employee. A total of 22 pounds of ammoina was released over an 8 minute period due to failure of a relief valve. There were no offsite injuries and no effect on the environment. Emergency Response Program The Bergen's emergency response program is based on the OSHA requirements for Emergency Action Plans (29 CFR 1910.38 and 1910.119) and HAZWOPER (29 CFR 1910.120). We have trained employees for emergency response and maintain a written emergency response plan. This plan is coordinated with the Genessee County Local Emergency Planning Committee (LEPC) and the Bergen Fire Department. We conduct annual drills for implementation of the emergency response plan at the facility with participation of the LEPC and the fire department. |