Nestle Chocolate and Confections - Executive Summary |
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A. Describe the Accident Release Prevention and Emergency Policies Nestle has made a commitment to provide all employees with a safe work environment and to protect them from injury and illness resulting from unsafe acts or conditions during the hours of employment. Nestle's goal as a company is to comply with federal, state and local laws and regulations. The Plant Manager has overall responsibility for the leadership of the safety, health and environmental programs. The Plant Manager in conjunction with the entire management team has the responsibility to provide the necessary resources and environment conducive to an atmosphere of safety. Ammonia safety comprises a key portion of the facility safety and health program. Nestle takes many precautions to prevent or minimize accidental releases of ammonia. These precaustions include safety controls (alarms and automatic shutdown devices) which are designed to identify and and prevent potentially unsafe conditions such as pres sure increases which could cause system failure, a preventative maintenance program designed to maintain the on-going integrity of the system, a training program designed to ensure that the system is operated by qualified personnel, and emergency response procedures which enable trained personnel to respond quickly to system upsets. The Environmental/Energy Engineer is responsible for management of the PSM/RMP program including those portions dedicated to system safety. B. Stationary Source and Regulated Substances Handled Nestle's Fulton Plant produces chocolate and confectionary products for sale to both the public and other confectionary companies. The facility uses ammonia in its refrigeration system as a heat transfer medium to provide cooling to the confectionary products and selected production areas. The maximum ammonia inventory at the plant is approximately 26,400 pounds. Ammonia is the only regulated substance handled at the Fulton Plant. C. Summary of Worst Case an d Alternative Release Scenarios The worst-case toxic release scenario at the Fulton Plant involves the release of 26,400 pounds of ammonia to the atmosphere over a 10-minute period due to the failure of our high pressure receiver. This maximum inventory reflects written administrative procedures which limit the amount of ammonia stored in the receiver to the 8th sight glass (bullseye monitor) from the bottom of the vessel. Under worst case conditions, the resulting vapor cloud could have off-site consequences. The alternative toxic release scenario at the Fulton Plant involves the release of release of 4630 pounds of ammonia over a 10 minute period due to the breach of a 1/2 inch diameter liquid ammonia pipe. The release was assumed to be limited by the response of the Mechanics to the ammonia detectors in the area of the plant where the selected pipe was located. 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: 1. The weather conditions that were used for the worst case release scenario do not occur, while those used for the alternative case are uncommon; 2. The high pressure receiver is an ASME Code pressure vessel and has been installed in accordance with industry standards. This vessel is also located inside a closed room containing a dike and ammonia containment system; 3. Industry standards are followed for the design and manufacture of the equipment in the ammonia refrigeration system; 4. The ammonia receivers and the ammonia piping is well protected from vehicular traffic; 5. Pressure safety valves on the high pressure receiver should limit any pressure increase inside the tank; 6. Ammonia is not corrosive in this environment; 7. The facility has a preventative maintenance program in place to maintain the on-going integrity of the ammonia refrigeration equipment; 8. The facil ity has a training program designed to ensure that qualified personnel operate the system; and, 9. The facility has emergency response procedures and a trained emergency response team which has the ability to respond quickly to isolate any potential release. D. Description of Accidental Release Prevetion Program The facility has a program level 3 accident release prevention program for the ammonia system corresponding to OSHA's Process Safety Management Standard and EPA's Risk Management Program Regulation. The ammonia release prevention program consists of the following elements: 1. Employee Participation Program 2. Process Safety Information 3. Process Hazard Analysis 4. Operating Procedures 5. Training Programs 6. Mechanical Integrity Program 7. Hot Work Permit Procedure 8. Management of Change Procedures 9. Incident Investigation 10. Compliance Audit Procedure 11. Pre-Startup Safety Procedure E. Five-Year Accident History There have not been any ammonia-related incidents at the Fulton Facility during the previous five years that have resulted in significant on-site or off-site consequences. F. Description of Emergency Response Program An emergency response program has been implemented at the Fulton Plant. This program contains procedures describing how the facility will respond to fires, ammonia leaks and other emergencies, including evacuation procedures for the plant. The emergency response program includes the following elements: 1. Ammonia Leak Procedures 2. Evacuation Procedures 3. Fire Plan 4. Responsibilities of the Emergency Response Team 5. Emergency Shutdown Procedures The program has been coordinated with the Fulton Fire Department and the County of Oswego Hazardous Materials Response Team. G. Planned Changes to Improve Safety Numerous changes were recommended to improve the system operating procedures when the ammonia system was reviewed in April, 1999. The recommend ed changes will be evaluated and implemented as necessary |