Brockport Operations - Executive Summary |
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Risk Management Plan Brockport Facility Executive Summary This is to inform all interested persons, including employees that Agrilink Foods is complying with OSHAs Process Safety Management Standard called (Process Safety Management or PSM), Title 29 Code of Federal Regulations (CFR) 1910.119, and EPAs Risk Management Program regulation called (RMP), Title 40 CFR Part 68, manage the risks involved with the storage, handling, and processing of hazardous chemicals. Our compliance promotes overall plant, worker, and public safety. Our programs enable this 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, illnesses, and avoid physical property damage. Our safety programs are applicable to any activity involving hazardous chemicals including their 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 pieces of equipment. These programs are detailed and improved as necessary. They are 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. This occurs within a closed system. The systems operation is very similar to that of a household refrigerator, though on a much larger scale. The total ammonia inventory on site is 35,000 pounds. The ammonia is used as a refrigeration agent for the frozen storage of bulk and repackaged veget ables. Worst-Case Scenario(s) Failure of the high pressure receiver containing 35,000 pounds of ammonia with the receiver quantity limited to 35,000 pounds of the vessel capacity by facility procedures resulting in an estimated 10 minute release. Worst case weather patterns for this geographic area would allow fugitive emissions to travel up to 2.3 miles before dispersing enough to no longer pose a hazard to the public or environment. There are an estimated 14,000 persons residing within this 2.3 mile radius. All of these persons have the potential to be effected by a release of this magnitude. This scenario is unlikely for the following reasons: Worse weather conditions are uncommon; the vessel is enclosed in a building that would withstand and help to contain such a release; 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 preve ntion program in place at the facility including the mechanical integrity program for regular maintenance, inspection, testing, and replacement of equipment if necessary; installed ammonia sensors in the system to warn of leaks; alarms and the auto dialing system in place to warn operating personnel of process upsets; the emergency response plan and equipment in place at the facility. Alternative Release Scenario(s) A breech or failure of a < inch diameter pipe would result in the release of approximately 6,000 pounds of ammonia over a time period of 60 minutes, given high pressure receiver conditions at a release rate of 100 pounds per minute. Under common weather conditions, ammonia could travel up to .10 mile(s) before dispersing enough to no longer pose a hazard to the public or environment. There are an estimated 83 off site residents who would have the potential of being effected in the event of a release of this nature. A < inch pipe was chosen because it is used to temp orarily bleed off a liquid 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 which would allow only a few pounds of ammonia to 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 stipulate having trained personnel present at all times during the maintenance of a pump; a mechanical integrity program for regular maintenance of a pump(s) is in place at the facility; routine inspection and testing of valves is conducted; defective equipment is replaced as 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 was developed as required and complies with OSHA PSM Standard 29 CFR 1910.119 and EPA RM Program regulations 40 CFR Part 68 . Facility accident prevention program(s) and procedure(s) are as follows: 7 Process Safety Information 7 Process Hazard Analysis 7 Standard Operating Procedures 7 Training 7 Mechanical Integrity Program 7 Management of Change 7 Pre Start-Up 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 one (1) incident involving the release of ammonia in the past five years. This incident took place on April 7, 1996 at 5:30 am. when it was discovered that the structural failure of a globe valve resulted in the release of 3,500 pounds of ammonia into a sealed refrigerated warehouse. Facility, local, and county emergency responders collaborated to perform a controlled venting of the ammonia to the atmosphere. Atmospheric concentrations were closely monitored to insure safety of community residents and property. There were no injuries sustained, and no negative environme ntal impact(s). All applicable reporting to local, county, state, and federal regulatory agencies was completed. Emergency Response Program The Brockport 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 maintain trained employees for emergency response, and have a written program in place. This plan is coordinated with the Monroe County Local Emergency Planning Committee, (LEPC) and the Brockport Fire Department. We conduct and attend annual drills onsite, and at those of our "sister" Agrilink locations. We conduct these drills to practice our implementation of facility(s) emergency response plan(s), and to practice our coordination with LEPC(s) and fire department(s). |