Good Humor Corporation Henderson - Executive Summary

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EXECUTIVE SUMMARY 
 
This report contains the Risk Management Plan (RMP) for the two ammonia refrigeration systems located at the Good Humor - Breyers Ice Cream (GHB) facility in Henderson, NV.  The RMP was prepared by Primatech in accordance with the requirements of the EPA's Risk Management Program (RM program) regulation (Risk Management Programs for Chemical Accidental Release Prevention, 40 CFR Part 68). 
 
The information presented in this report reflects the data element requirements and numbering sequence of the final EPA RMP submission.  The Henderson facility has two distinct ammonia refrigeration system loops.  These are designated as the 'east system' and the 'west system'.  Many of the components and processes are similar in the two systems, however they do not intermingle. 
 
A.   Accidental Release Prevention and Emergency Response Policies 
 
Good Humor - Breyers recognizes management's responsibility in protecting it's employees, equipment, property, and the environment.  The  
safety and health of all personnel are very important.  The control of accidents has been and will continue to be a basic responsibility of all personnel in the Henderson facility. 
 
To accomplish the Company's goal in controlling accidental losses, the facility has established a Plant Safety Program and a Plant Safety Team.  The objectives of the Plant Safety Program are to: achieve maximum efficiency and safety performance, reduce losses associated which damage of property, and the economic  burden resulting from injuries and accidents. 
 
One of the activities associated with the Plant Safety Program has been the development and implementation of accidental release prevention and emergency response programs which are designed to comply with OSHA's Process Safety Management (PSM) standard (Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119),  Nevada's Chemical Catastrophic Prevention Act (Senate Bill No. 641), and EPA's Risk Management Program (RM program) regulati 
on (Risk Management Programs for Chemical Accidental Release Prevention, 40 CFR Part 68).  The Utilities Supervisor is responsible for the management of the accidental release prevention and emergency response programs. 
 
The purpose of the accidental release prevention and emergency response programs is to prevent the occurrence, and minimize the consequences, of significant releases of toxic substances as well as fires, explosions, and other types of catastrophic accidents.  Overall, these programs prevent accidental fatalities, injuries and illnesses and avoid physical property damage. 
 
The accidental release prevention and emergency response programs help prevent accidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment.  These rules are detailed and improved as necessary.  They are also communicated to and accepted by all employees at the facility. 
 
B.   Stationary Source and Regulated Substances Handl 
ed 
 
Good Humor - Breyers operates an ice cream production facility at 1001 Olsen Street in Henderson, NV.  The facility operates two ammonia refrigeration systems to provide cooling and freezing capabilities.  The amount of anhydrous ammonia (CAS #7662-41-7) contained in each system is in excess of 10,000 pounds.  The maximum combined inventory for both systems is 86,000 pounds.  Since ammonia releases from both systems could pose a risk of offsite public impact and both systems are regulated under the OSHA PSM standard (29 CFR 1910.119), the systems are subject to the Program 3 requirements of the EPA's RM program. 
 
In the two ammonia refrigeration systems, ammonia vapor is fed from vessels operating at low pressures to low stage compressors.  The compressed vapors from the low stage compressors are fed to vessels operating at intermediate pressures and then to the high stage compressors.  The high pressure ammonia vapor flows from the high stage compressors to the condensers where he 
at is removed, turning the vapor into a high pressure liquid.  The high pressure liquid from the condensers is collected in high pressure receivers. 
 
The high pressure liquid collected in the high pressure receivers is circulated to the units (freezers, air units, silos, storage tanks, and chillers) located in the production area.  The ammonia liquid flows across heat exchanger surfaces (coils, tubes, or freezer barrels) where it picks up heat, changing from a liquid to a vapor.  The low pressure ammonia vapor is then sent back to the appropriate vessel via vapor headers. 
 
C.   Summary of Worst-Case and Alternative Release Scenarios 
 
The worst-case release scenario at the Henderson facility involves the release of 9,450 pounds of ammonia over a 10 minute period due to the failure of one of the high pressure receivers.  The maximum level in each high pressure receiver is limited to 75% of the vessel capacity during pump-down operations by facility procedures. The scenario has been devel 
oped based on the method provided in the Risk Management Program (40 CFR 68) Guidance for Ammonia Refrigeration. 
 
The worst-case release scenario is unlikely for the following reasons: 
 
o The worst-case weather conditions which were used for this scenario are uncommon; 
o The high pressure receivers are located in enclosed areas that could help to contain such a release and minimize traffic near the receivers; 
o Industry standards were followed for the manufacture and quality control of these receivers; 
o Ammonia is not corrosive in this service and the vessels are relatively new; 
o Pressure safety valves limit operating pressures in these receivers; 
o An ammonia detector which is tied to emergency ventilation fans and an outside monitoring system is located near the high pressure receiver in the west ammonia refrigeration system; 
o The high pressure receiver in the east ammonia refrigeration system is protected by concrete-filled pipes; 
o  The facility has a preventive maintenance prog 
ram in place to maintain the on-going integrity of the vessels;  
o The facility has a training program designed to ensure that the system is operated by qualified personnel; and, 
o The facility emergency response procedures which enable trained personnel to respond quickly to isolate any potential releases. 
 
The alternative release scenario at the Henderson facility involves the release of 6,630 pounds of ammonia over a 10 minute period due to the rupture of a 1/2" high pressure liquid pipe.  There are 1/2" liquid feed lines to the silos and ice cream freezers. The scenario has been developed based on the method provided in the Risk Management Program (40 CFR 68) Guidance for Ammonia Refrigeration. 
 
The alternative release scenario is unlikely for the following reasons: 
 
o The high pressure liquid lines are located in enclosed areas that could help to contain such a release; 
o Industry standards were followed for the manufacture and quality control of these lines; 
o Ammonia is not corr 
osive in this service; 
o Most of the lines are elevated to minimize potential damage from fork lifts; 
o  The facility has a preventive maintenance program in place to maintain the on-going integrity of the system;  
o The facility has a training program designed to ensure that the system is operated by qualified personnel; and, 
o The facility emergency response procedures which enable trained personnel to respond quickly to isolate any potential releases by closing isolation valves in the liquid lines. 
 
D.   Description of the Accidental Release Prevention Program 
 
The prevention program consists of the following elements: 
 
Employee Participation:  This program involves the employees in establishing and implementing the program.  Employees are also be involved when a process hazard analysis is conducted.  The program also ensures that all employees have complete access to the program. 
 
Process Safety Information: Written information has been collected which enables the employees to iden 
tify and understand the potential hazards in the systems. The written information includes the ammonia MSDS and a description of the design of the ammonia refrigeration systems. 
 
Process Hazard Analysis: Formal studies using the What-If Technique have been conducted to look at the systems and identify potential hazards. 
 
Operating Procedures:  Written, detailed procedures have been developed which describe the steps which should be followed to safely operate the ammonia refrigeration systems. 
 
Training: A training program has been developed which ensures that employees are trained on all aspects of the systems and on the duties which they should perform to ensure the safe operation of the ammonia refrigeration systems. 
 
Contractors: All contractors are screened and evaluated before they perform work on or near the ammonia refrigeration systems.  The contractors are also periodically evaluated to ensure that they perform work by following safe work practices. 
 
Pre-Startup Safety Review: 
A pre-startup safety review is completed for all new ammonia projects to verify that all safety programs are in place, training has been performed, and construction has been completed according to design standards before the project is put into use. 
 
Mechanical Integrity:  This program ensures that the ammonia refrigeration systems are built and maintained using preventive maintenance procedures to minimize unexpected breakdowns or failures. 
 
Hot Work Permit: These procedures ensure that a signed permit is obtained prior to any cutting, welding, or burning. 
 
Management of Change: The procedures are designed to ensure that all changes made to the ammonia refrigeration systems are properly reviewed. 
 
Incident Investigation: The procedures ensure that any incidents (and near misses) are investigated, reviewed, and documented using an investigation team. 
 
Compliance Audits: There are procedures to conduct regular audits of the program to ensure that the program is in place and working pro 
perly. 
 
 
E.   Five-Year Accident History 
 
No ammonia-related incidents were identified for the Henderson facility in the previous five years which resulted in significant on-site or offsite consequences. 
 
 
F.   Description of the Emergency Response Program 
 
An emergency response program has been implemented at the Henderson facility.  This program contains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures.  The program has been coordinated with the Emergency Management Division of the Henderson Fire Department. 
 
The emergency response program consists of the following elements: 
 
o Organization Plan and Responsibilities 
o Communications Procedures 
o Detailed Action Plans 
o Fire Aid Procedures 
o Emergency Medical Treatment Procedures 
o Evacuation Plans 
o Description of Outside Assistance Available 
o Site Re-Entry Procedures 
o Training Programs and Drills 
 
 
G.   Planned Changes to Improve Safety 
 
Eight (8) changes  
to improve safety were recommended to either the equipment (hardware recommendations) or the system operating procedures (procedural recommendations) when the east ammonia refrigeration system was analyzed in February, 1998.  Twenty-eight (28) changes to improve safety were recommended to either the equipment (hardware recommendations) or the system operating procedures (procedural recommendations) when the west expansion was analyzed in September, 1997.  The recommended changes have been evaluated and will be implemented in a timely manner.
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