Farmland Dairies Inc. - Executive Summary
A. Describe the Accident Release Prevention and Emergency Policies |
Farmland Dairies is committed to safety. We believe all injuries can be prevented and expect all employees to assume the responsibility for working safely.
Ammonia safety is a key item in our safety program. We take many precautions to prevent or minimize accidental releases of ammonia. These precautions include safety controls (alarms and automatic shutdown devices) which are designed to identify and prevent potentially unsafe conditions like pressure increases that could cause a system failure, a preventive 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 Director of Engineering is responsible for the management of the ammonia safety program.
B. Stationary Source and Regulated Substance
The Farmland Dairies facility in Wallington, NJ processes milk and other dairy products. The plant uses an ammonia refrigeration system to provide cooling for the dairy products and the production area. The maximum ammonia inventory at the plant is approximately 16,000 pounds. Ammonia is the only regulated substance handled at the plant.
C. Summary of Worst-Case and Alternative Release Scenarios
The worst-case toxic release scenario at the Farmland Dairies Plant involves the release of 9,700 pounds of ammonia due to the failure of the main receiver. This maximum inventory reflects the written administrative procedures in place at the plant to limit the amount of ammonia stored in the main receiver to 80% of its capacity. Under worst-case conditions, the resulting vapor cloud could have off-site impacts.
The alternative toxic release scenario at the plant involves the release of 775 pounds of ammonia over a 2 minute period due to the rupture of a >" liquid line beca
use of a vehicular accident. Under alternative release conditions, the resulting vapor cloud could have off-site impacts.
The worst-case and alternative toxic release scenarios are unlikely for the following reasons:
o The weather conditions that were used for the worst-case release scenario do not occur, while those used for the alternative case are uncommon;
o Industry standards are followed for the design and manufacture of the equipment in the ammonia refrigeration system;
o The ammonia receivers are protected from vehicular traffic;
o Pressure safety valves on the main receiver should limit any pressure increases inside the receiver;
o Ammonia is not corrosive in this service;
o The facility has a preventive maintenance program in place to maintain the on-going integrity of the ammonia refrigeration equipment;
o The facility has a training program designed to ensure that the systems are operated by qualified personnel; and,
o The facility emergency response procedures that e
nable trained personnel to respond quickly to isolate any potential releases.
D. Description of the Accidental Release Prevention Program
The facility has a program level 3 accident release prevention program for the ammonia system that complies with OSHA's Process Safety Management Standard, EPA's Risk Management Program Regulation, and New Jersey's Toxic Catastrophe Prevention Act (TCPA). The ammonia prevention program consists of the following elements:
o Employee Participation Program
o Process Safety Information
o Process Hazard Analysis
o Operating Procedures
o Training Program
o Contractor Safety Program
o Pre-Startup Safety Review Procedures
o Mechanical Integrity Program
o Hot Work Permit Procedures
o Management of Change Procedures
o Incident Investigation Procedures
o Compliance Audit Procedures
E. Five-Year Accident History
One ammonia-related incident was identified for the plant during the previous five years that resulted in significant on-site or offsite con
sequences. This incident resulted in one on-site injury. Additional training has been provided to prevent a reoccurrence of this incident.
F. Description of the Emergency Response Program
An emergency response program has been implemented at the plant. This program contains procedures describing how the facility will respond to ammonia leaks and other emergencies, including evacuation procedures.
The emergency response program includes the following elements:
o Pre-Emergency Planning and Coordination
o Personnel Roles and Duties
o Emergency Response Procedures
o Evacuation Routes and Procedures
o First Aid Procedures
The program has been coordinated with the Wallington Fire Department.
G. Planned Changes to Improve Safety
Several items were recommended to improve the equipment and the system operating procedures when the ammonia system was analyzed in 1998. The recommended changes have been evaluated and will be implemented as required.