Tasty Baking Co. - Executive Summary |
|
Tasty Baking Co. manufactures cakes, snack foods and bakery specialties at our plant in Philadelphia, PA. We have a strong commitment from both our management and operating personnel to operate and maintain our facility in both a safe and responsible manner. Ammonia is used at our facility as the cooling medium in our central plant refrigeration system in a similar way or function as "Freon" acts in a home or automobile air conditioning system. Ammonia is used to cool our product in both heat exchangers and cooling tunnels and maintains our raw ingredients at proper temperatures in walk-in coolers. Ammonia is also used to cool glycol that in turn cools our packaging rooms giving our product improved shelf life and firm texture. The ammonia at our facility is contained in a closed loop system; it is designed to remain inside our steel piping, coils, exchangers and vessels. We believe that ammonia provides the most environmentally friendly, safest and efficient cooling choice for our op eration. A. Describe the accident release prevention and emergency policy. Tasty Baking Co. takes many precautions to prevent or minimize accidental releases from our ammonia refrigeration system. These precautions include safety controls (alarms and automatic shutdown devices) which are designed to identify and prevent potentially unsafe conditions such as pressure increases that could cause a system failure, We also have implemented a PM or preventative maintenance program designed to maintain the overall integrity of the system. Additionally, we have on-going training programs for both safe operating and emergency procedures to ensure that our facility is operated by qualified personnel who when called upon will respond quickly and knowledgeably to system upsets. The Superintendent of Maintenance is responsible for the management of these ammonia safety programs. B. Stationary source and regulated substances handled. The Philadelphia facility operates a refrigeration system wit h an inventory of approximately 28,000 lbs. of ammonia. This ammonia used in our refrigeration system represents the only substance covered by the Accidental Release Prevention Regulations handled at the Philadelphia facility. C. Summary of worst-case and alternative release scenarios. The worst case scenario from the Philadelphia, PA plant, as defined by the EPA, is the release of all the ammonia from the largest vessel on site. At our Philadelphia plant, this release would be 5,800 lbs. of ammonia over a ten (10) minute period due to the failure of one of our two (2) high pressure receivers. The 5,800 lbs. represents the maximum allowable amount of ammonia that would be contained in the receiver at any time. It is important to note that in normal operation this receiver would be operating at approximately 20% of this level. This scenario as defined by EPA also requires us to assume that the weather conditions during a worst case scenario release would have almost no wind and no mix ing in the atmosphere. The alternative release scenario at the Philadelphia plant would involve the release of 2,430 lbs. of ammonia over a thirty (30) minute period due to the rupture of a 3/4" high pressure vapor tube/pipe located in or on one of condensers. The duration of the alternative release scenario was estimated by the amount of time required to identify the source of the leak, isolate the unit and stop the leak. Once again, the impact of this release also assumes the release occurs under both low wind and stable weather conditions per EPA requirements. The two (2) above release scenarios are extremely unlikely for many reasons. Our equipment and system were designed using industry standards specifically for ammonia refrigeration. We have taken precautions to protect our equipment from obvious threats such as vehicular traffic. We have a PM program to maintain the on-going integrity of the refrigeration equipment and system. Training programs are in place and monitored to ensure that only qualified personnel operate and work on/repair the system and our emergency response procedures provide for quick and decisive responses in the event of an accident. Finally, the weather conditions used in estimating the extent of a release are uncommon at best. D. Description of the accidental release prevention program. The facility has an accident release prevention plan that complies with the Occupational Safety and Health Act's (OSHA), Process Safety Management Standard and EPA's Risk Management Program Regulation. The prevention program consists of the following elements: - Employee Participation Program - Process Safety Management - Process Hazard Analysis - Operating Procedures - Training Program - Contractor Safety Program - Pre-Startup Safety Review Procedures - Mechanical Integrity Program - Hot Work Permit Procedures - Management of Change Procedures - Incident Investigation Procedures - Compli ance Audit Procedures E. Five Year Accident History In the past five (5) years there have been no ammonia related accidents at the Philadelphia, PA plant. F. Description of the Emergency Response Program An emergency response program has been implemented at the Philadelphia plant. This program contains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures. The plant response team utilizes trained employees to enter and stop an accidental ammonia release. G. Planned Changes to Improve Safety Tasty Baking Company is committed to operating our ammonia refrigeration system in a safe, efficient and responsible manner. We are continually evaluating our equipment and procedures to meet this objective. Planned improvements include; (1) replacement of ammonia cooling coils with glycol cooling coils to reduce the plants operating charge and reduce the number of load devices where potential releases could occur, (2) in stalling additional leak detection equipment to monitor systems where limited direct supervision occurs and (3) installing rupture disks on relief valves during their normal replacement period. |