Frozen Division, Nestle USA, Food Group Inc. - Executive Summary

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Executive Summary                                                                 5/20/99 
Nestle has made a commitment to provide all employees with a safe work environment and take whatever steps necessary to prevent injuries and illnesses resulting from unsafe acts or conditions during the hours of operation. Our goal as a company is to comply with federal, state and local laws. The entire management team has the responsibility of providing our employees with an environment conducive to an atmosphere of safety. 
Ammonia safety is a priority within our facility. Our goal is to prevent problems, through the use of our preventive maintenance program that we enforce. The purpose is to identify and prevent potentially unsafe conditions and make necessary modifications before problems develop. Our on going program is designed to maintain the integrity of the system and assure that all employees are properly trained and meet the requirements to operate our equipment within the boundaries o 
f our PSM/RMP program. 
The PSM/RMP Coordinator is responsible for the management of the ammonia safety program. 
Stationary Source and Regulated Substances Handled 
Nestle Solon Plant produces and packages frozen prepared foods. The facility uses ammonia in its refrigeration system as a heat transfer medium. Ammonia is supplied to various end users in the processing of frozen foods. The maximum inventory at the plant is approximately 257,000 pounds. Ammonia is the only regulated substance handled at the Solon Plant. 
Summary of Worst Case and Alternative ReleaseScenarios 
The worst-case toxic release scenario at the Solon Plant involves the release of 26,060 pounds of ammonia to the atmosphere over a 10-minute period due to the failure of a low-pressure receiver. The amount released reflects written administrative procedures in place at the plant to limit the amount of ammonia stored in the vessel to 78% of its capacity.  The release rate in an enclosed room would limit the amount of  
ammonia released to the atmosphere. Under worst case conditions, the resulting vapor cloud could have off-site consequences.  
The alternative toxic release scenario at the Solon Plant involves the release of 5800 pounds of ammonia over a 60-minute period from a pressure relief device. Under alternative release conditions, the resulting vapor cloud could have off-site consequences. 
The worst case and alternative toxic release scenarios are unlikely for the following reasons: 
7 The weather conditions that were used for the worst-case release scenario do not occur, while those used for the alternative case are uncommon; 
7 Industry standards are followed for the design and manufacture of the equipment in the ammonia refrigeration system; 
7 The low-pressure ammonia vessel is located in an enclosed room, well protected from vehicular traffic, the room also contains a dike and the facility has an ammonia containment system. 
7 Pressure safety valves on the low-pressure vessel should limit an 
y pressure increase inside the tank; 
7 Ammonia is not corrosive in this service; 
7 The facility has a preventative maintenance program in place to maintain the ongoing integrity of the ammonia equipment;  
7 The facility has a training program designed to ensure qualified personnel operate the systems;  
7 The facility has emergency response procedures that enable trained personnel to respond quickly to isolate any potential release. 
Description of the Accidental Release Prevention Program 
The facility has a level 3 accident release prevention program for the ammonia system that complies with OSHA's Process Safety Management Standard, EPA's Risk Management Program Regulations. The ammonia prevention program consists of the following elements: 
7 Employee Participation 
7 Process Safety Information 
7 Process Hazard Analysis 
7 Operating Procedures 
7 Training Programs 
7 Mechanical Integrity Program 
7 Hot Work Permit Procedure 
7 Management of Change Procedures 
7 Incident Investigation 
7 Co 
mpliance Audit Procedure 
7 Pre-Startup Safety Procedure 
Five Year Accident History  
There have not been any ammonia-related incidents at the Solon Facility during the previous five years that have resulted in significant on-site or off-site consequences. 
Description of the Emergency Response Program 
An emergency response program has been implemented at the Solon Plant. This program contains procedures describing how the facility will respond to fires, ammonia leaks and other emergencies, including evacuation procedures for the plant and hi-rise freezer. 
The emergency response program includes the following elements: 
7 Ammonia Leak Procedures  
7 Emergency Evacuation Plan (Plant) 
7 Fire Plan 
7 Emergency Response Team Responsibilities 
7 High-Rise Evacuation Plan 
Planned Changes to Improve Safety  
Numerous changes were recommended to improve the equipment and the system operating procedures when the ammonia system was analyzed in 1999. The recommended changes will  
be evaluated and implemented as necessary.
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