Culinary Division, Nestle USA, Inc.(Delaware Corp) - Executive Summary |
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A. Describe the Accident Release Prevention and Emergency Policies Nestle's most important asset is its people. Our employees are the source of our competitive advantage and the key to a successful and productive organization. We recognize the importance of a safe work environment and make every reasonable effort to provide employees with a safe and healthy workplace. We also expect each employee to work safely. The Nestle USA Safety Manual has been developed by a cross-company team of employees to provide a guide to safe behavior. By committing to these guidelines we all contribute to our vision to be the premier diversified food company in the U.S. Ammonia safety is a key item in the plant safety program. Nestle takes 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 coul d 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 Facility Engineer is responsible for the management of the ammonia safety program. B. Stationary Source and Regulated Substances Handled Nestle's Danville Plant produces food products for sale to the public. The facility operates an ammonia refrigeration system to cool and freeze the food products and the production areas. The maximum ammonia inventory at the plant is approximately 65,000 pounds. Ammonia is the only regulated substance handled at the Danville Plant. C. Summary of Worst-Case and Alternative Release Scenarios The worst-case toxic release scenario at the Danville Plant involves the release of 35,000 pounds of ammonia over a 10 minute period due to th e failure of the dump tank. This maximum inventory reflects the written administrative procedures in place at the plant to limit the amount of ammonia stored in the dump tank to 85% of its capacity. Under worst-case conditions, the resulting vapor cloud could have off-site impacts. The alternative toxic release scenario at the Danville Plant involves the release of 35,000 pounds of ammonia over a 38 minute period from a pressure relief valve on the dump tank. Under alternative release conditions, the resulting vapor cloud explosion 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 dump tank is located in a fenced area, well protected from veh icular traffic; o Pressure safety valves on the dump tank should limit any pressure increases inside the tank; 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 enable 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 and EPA's Risk Management Program Regulation. 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 Progr am 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 Proceduress E. Five-Year Accident History There have not been any ammonia-related incidents at the Danville Plant during the previous five years that resulted in significant on-site or offsite consequences. F. Description of the Emergency Response Program An emergency response program has been implemented at the Danville Plant. This program contains procedures describing how the facility will respond to fires, ammonia leaks and other emergencies, including evacuation procedures. The emergency response program includes the following elements: o Notification Procedures o Evacuation Plan o Emergency Shutdown Procedures o Specific Action Plans for Emergencies (Including Ammonia Leak Procedures) o Emergency Medical Procedures The program has been coordinated w ith the Danville Fire Department. G. Planned Changes to Improve Safety 26 changes were recommended to improve the equipment and the system operating procedures when the ammonia system was analyzed in 1994. The recommended changes have been evaluated and will be implemented as required. |