Brakebush Brothers, Inc. - Executive Summary

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Brakebush Brothers, Inc., located at N4993 6th Drive, Westfield, WI, is a family owned poultry processing facility that has been in operation in this area for 75 years. Anhydrous ammonia is used as a refrigerant at this facility for processing and to provide cooling for storage rooms. Our refrigeration system is a closed loop system with normal operating pressures that range between a low side of 0 psi to a high side of 160 psi. The maximum amount of ammonia in the system, at any one time, is estimated at 20,000 pounds. 
Worst-case Release Scenario for a Toxic Substance: 
Our worst-case release is the failure of the largest vessel in our refrigeration system. This vessel is called the High Pressure Receiver (HPR) and measures 8' x 14' with a maximum capacity of 26,000 pounds. Located outside the building, no passive mitigation was considered. Although the normal operating level of this receiver is between 8,600 to 13,000 pounds, the worst-case analysis takes into account the possibility 
the HPR would be full. Using the tables and equations found in chapter 4 of  EPA's "RMP Guidance for Ammonia Refrigeration", the toxic endpoint was calculated at 2.90 miles. Based on census data provided by "Landview III", within this radius is a population of 500, one school (Westfield School), residential housing, and a few retail businesses. There are no hospitals located within this area.  
Alternative release scenario for a toxic substance: 
The alternative release toxic endpoint was also determined using EPA's "RMP Guidance for Ammonia Refrigeration" reference tables and equations. A pressure relief valve failure was the most likely cause of an ammonia release. Using the tables provided in the RMP Guidance, a 10 minute release of ammonia at 540 lbs/min, from the High Pressure Receiver relief valve, would affect an area of .40 miles. The estimated population, according to Landview III, within distance to endpoint is 10. There are also some residences and retail businesses. There a 
re no schools or hospitals within this radius.  
Accidental Release and Emergency Response Policies: 
Brakebush Brothers has established an in-house emergency response team to quickly respond to and handle releases of Anhydrous Ammonia. The established steps include initial training under the OSHA regulation 29 CFR 1910.120 HAZWOPER. The facility has also established annual retraining for all personnel that are on the HAZMAT Team as well as periodic spill drills and plant wide evacuation drills to assure all employees are prepared in the event of an emergency. We have also coordinated efforts with Marquette County HAZMAT  to establish a joint response program. These established plans and procedures shall be periodically reviewed to assure that they are current and up to date. 
Emergency Response Program: 
We have trained the selected personnel, including refrigeration operators, in Hazardous Waste Operation and Emergency Response, 29 CFR 1910.120. The trained personnel will assess each r 
elease situation and determine the appropriate emergency response to initiate. This could be by simply tightening a packing nut or flange bolt or initiating a system shut down. Brakebush Brothers has established written operating procedures for the ammonia refrigeration system and has included in those procedures the Emergency Shutdown and isolation in the event of a release. We have also purchased Level B Chemical Suites, Self Contained Breathing Apparatus and other appropriate equipment to support the in-house HAZMAT team. This team will coordinate their efforts with the outside emergency services to assure the safety of all. 
Five Year Accident History:  
There have been no accidental releases in the past five years. 
General Accidental Release Prevention Program and Chemical Specific Prevention Steps: 
Brakebush Brothers, Inc. has not only complied with the EPA Risk Management Program but also the OSHA Process Safety Management regulation to assure that the Ammonia Refrigeration Syst 
em is well maintained and employees are properly trained and periodically retrained to assure they are kept up to date on any changes and new operations that may effect them. In addition, to maintain the mechanical integrity and safety of this process, this facility practices the following industry codes and standards: 
ASME Boiler & Pressure Valve Codes 
ANSI B31.3 Piping Code 
IIAR industry guideline for safety and good engineering practices 
NFPA guidelines for fire protection equipment 
Through regular audits, training, maintenance, testing and inspection programs Brakebush Brothers has established a history of safe operation and that community emergency action plans are current and training with community services is done for a safe response in the event of an accidental release.
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