Ice Cream Division, Nestle USA - Food Group, Inc. - Executive Summary |
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A. Describe the Accident Release Prevention and Emergency Policies At Nestle, safety is everyone's job. 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 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 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 Engineering Maintenance Supervisor is responsible for the management of the ammonia safety program. B. Stationary Source and R egulated Substances Handled Nestle's Laurel Plant produces ice cream and frozen desert products for sale to the public. The facility operates an ammonia refrigeration system to cool and freeze the products. The maximum ammonia inventory at the plant is approximately 50,000 pounds. Ammonia is the only regulated substance handled at the Laurel Plant. C. Summary of Worst-Case and Alternative Release Scenarios The worst-case toxic release scenario at the Laurel Plant involves the release of 10,300 pounds of ammonia due to the failure of a high pressure ammonia receiver. This maximum inventory reflects the written administrative procedures in place at the plant to limit the amount of ammonia stored in the receiver to 85% of its capacity. Under worst-case conditions, the resulting vapor cloud explosion could have off-site impacts. The alternative toxic release scenario at the Laurel Plant involves the release of 3,600 pounds of ammonia over a 60 minute period from a pressure relie f valve. 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 ammonia receivers are protected from vehicular traffic; o Pressure safety valves on the ammonia receivers should limit any pressure increases inside the receivers; 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 t rained 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 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 Proceduress E. Five-Year Accident History There have not been any ammonia-related incidents at the Laurel Plant during the previous five years that resulted in significant on-site or offsite consequences. F. Description of the Emergency Re sponse Program An emergency response program has been implemented at the Laurel 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 Evacuation Plan o Procedures to Address Serious Accidents o Ammonia Leak Procedures o Emergency Medical Procedures The program has been coordinated with the Howard County Fire Department. G. Planned Changes to Improve Safety 52 changes were recommended to improve the equipment and the system operating procedures when the ammonia system was analyzed in 1997. The recommended changes have been evaluated and will be implemented as required. |