Jones Dairy Farm - Executive Summary
1. THE ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES: |
Jones Dairy Farm (JDF) utilizes anhydrous ammonia as a refrigerant in a closed system refrigeration system. JDF is committed to protecting its employees, the public and the environment from potential releases of ammonia. JDF has given utmost consideration to safety in the design and operation of the refrigeration system. We have conducted a formal Hazard and Operability (HAZOP) study of the refrigeration system and spent over $1,000,000 in improving and upgrading the ammonia refrigeration system. JDF refrigeration system maintenance and operations personnel receive ongoing training on the safe operation of the system.
JDF has a dedicated emergency response team to handle emergencies involving ammonia. The team is equipped with special "Level A" protection and is specially trained to detect, isolate and mitigate potential releases. The emergency plan has been coordinated with the Jefferson County Emergency
2. FACILITY DESCRIPTION AND THE REGULATED SUBSTANCE
Jones Dairy Farm is a meat processor. We cook, cure, smoke and package pre-processed meats. We use a
refrigeration system to provide cooling and freezing in processing areas of the plant. The refrigeration system uses anhydrous ammonia, which is the RMP regulated substance. The maximum quantity of ammonia in the system is approximately 26,000 pounds.
3. THE WORST-CASE RELEASE SCENARIO AND ALTERNATIVE RELEASE SCENARIO:
The Worst-Cast Release Scenario (WCRS) is mandated by 40 CFR 68.25 to be the amount of ammonia in the largest storage tank, 26,000 pounds, released over a 10 minute time period. The largest storage tank is the high pressure accumulator tank located immediately adjacent to the north side of the Engine Room. This tank has the capacity to store 77,000 pounds of ammonia, however, administrative controls limit the amount stored to 34% of the total, or 26,000 pounds. There are written
operating procedures, level controls and high level alarms that prevent more than 26,000 pounds in the 77,000 pound tank. The catastrophic failure of this tank is highly unlikely, since the tank is an ASME rated steel vessel and such failures are extremely rare. The EPA's Risk Management Program Guidance For Ammonia Refrigeration was used to determine that the WCRS affected area is a circle, with a radius of 3 miles. The 3 mile radius represents the distance to the endpoint for ammonia, which is 0.14 mg/liter. There are public receptors and environmental receptors within this area (residences, schools, hospitals and commercial buildings).
The Alternate Release Scenario (ARS) is defined as a scenario that is more likely to occur than the WCRS, that reaches an off-site receptor. Several ARS's were considered, based on the Process Hazard Analysis, past incidents in similar installations, and operator experience. The scenario chosen is a break in a 3 inch ammonia liquid discharge pi
pe outside of the ammonia compressor room. The facility has an on site, trained and equipped HAZMAT team experienced in controlling ammonia leaks. Under worst conditions, the team could deploy and shut off the leak in 20 minutes or less. The release rate in this scenario was computed, using the EPA's Risk Management Program Guidance For Ammonia Refrigeration, to be 16,000 pounds per minute. The ARS impacted area is a circle, centered on the release point with a radius of 2 miles. The 2 mile radius is the distance to the endpoint (0.14 mg/liter for ammonia).
4. THE GENERAL ACCIDENTAL RELEASE PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS:
This facility complies with OSHA's Process Safety Management (PSM) rule (29 CFR 1910.119) and the USEPA's Accidental Release Prevention Rule (40 CFR 68). The entire ammonia system has been designed and installed according to guidelines provided by the American Society of Heating Refrigerating and Air-Conditioning Engineers, Inc. (ASHRAE) an
d the International Institute of Ammonia Refrigeration (IIAR). The ammonia refrigeration system is operated and maintained by trained and experienced operators.
5. THE FIVE-YEAR ACCIDENT HISTORY
Jones Dairy Farm has not experienced an RMP reportable release or accident involving ammonia in the last five years.
6. THE EMERGENCY RESPONSE PROGRAM
The JDF emergency response program is based on and is in compliance with OSHA's HAZWOPER regulation, 29 CFR 1910.120. We have discussed this program with the local fire department. We have coordinated with the Local Emergency Planning Commission (LEPC). The LEPC has prepared a site specific plan for JDF.
7. PLANNED CHANGES TO IMPROVE SAFETY
While JDF makes a continuing effort to improve safety, we have no immediate improvement plans at this time.