Blue Bell Creameries - Brenham - Executive Summary |
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Executive Summary This is to inform all interested persons, including employees, that Blue Bell Creameries, L.P. located at 1101 South Horton, Brenham, Texas 77833-4413 is complying with OSHA's Process Safety Management of Highly Hazardous Chemicals Standard (called Process Safety Management or PSM) and EPA's Risk Management Plan regulations (called Risk Management Program or RM Program) to deal with the risks involved in the storage, handling, and processing of highly hazardous materials such as ammonia. In this way we promote overall plant and worker safety. Our PSM/RM programs enable our facility to prevent the occurrence, and minimize the consequences, of significant releases of highly hazardous materials as well as fires, explosions, and other types of catastrophic accidents. Overall, the PSM/RM Programs prevent accidental fatalities, injuries, and illnesses and avoid physical property damage. Our PSM/RM programs prevent accidents because they focus on the rules, procedures, and practices that govern individual processes, activities, or pieces of equipment. These rules are improved as necessary. They are also communicated to and accepted by all employees at the facility. Our ammonia refrigeration system consists basically of a cycle where liquid ammonia is evaporated while removing heat from the air or liquid surrounding it. The ammonia is always contained inside tubes, pipes or vessels. The vapor is then compressed and condensed so that liquid ammonia returns back to the coolers to initiate the cycle again. Worst Case Release Scenario: Failure of the high-pressure receiver containing 15,500 lbs. of ammonia resulting in a ten minute release. Under worst case scenario conditions, ammonia could travel 1.2 miles before dispersing enough to no longer pose a hazard to the public. This scenario is unlikely to occur for the following reasons: worst case scenario conditions are uncommon; compliance with industry standards for the manufacture and quality con trol of pressure vessels; ammonia is not corrosive; pressure safety valves limit operating pressure in this vessel; the accident prevention program in place at the facility including the mechanical integrity program for regular maintenance, inspection and testing, and replacement of equipment, if necessary. Also ammonia sensors are installed in the system to warn of leaks with alarms and an auto dialing system is in place to warn operating personnel of process upsets. Finally, we have an emergency response plan and equipment in place at the facility. Alternative Case Release Scenario: Corrosion of the pipe connection to the air cooler unit during defrost results in a release of 151 lbs./min for 5 minutes. Under common weather conditions, ammonia could travel 0.1 miles before dispersing enough to no longer pose a hazard to the public. This scenario is unlikely for the following reasons: the preventative maintenance program in place regularly maintains and inspects the piping and t here are pressure relief valves and pressure regulators that prevent sudden pressure increase. We regularly have personnel present around this equipment, besides the ammonia sensors in the system to warn of leaks. Finally we have an emergency response plan and equipment in place at the facility. Our general accidental release prevention program complies with OSHA PSM Standard 29 CFR 1910.119, EPA RM Program regulations in 40 CFR Part 68, ANSI/IIAR 2-1992 Standard for Equipment, Design and Installation of Ammonia Mechanical Refrigerating Systems as follows: Employee Participation: To involve the employees in establishing the PSM program. Employees have complete access to the PSM program. Process Safety Information: To enable the employees to identify and understand the potential hazards in the system. It includes the ammonia MSDS and a description of the ammonia refrigeration system design. Process Hazard Analysis (PHA): To review and study the Process to identify potentially haza rdous events or possible problems in operations. Analyzes potential deviations from design conditions. Operating Procedures: Detailed description of the steps to be followed to operate safely the ammonia refrigeration system. Training: To train the employees on all aspects of operation of the system and their respective duties to ensure the safety of the ammonia refrigeration system operation. Contractors: To screen and evaluate the contractors before they perform work on or near the ammonia refrigeration system. Periodic evaluation should be done to ensure that they follow safe work practices. Pre-Start Up Review: To complete a pre start up safety review for all new or modified ammonia projects to verify that all safety programs are in place, before the project is put into use. Mechanical Integrity: To ensure that the ammonia refrigeration system is well maintained, minimizing unexpected breakdown or failures. Hot Work Permit: To ensure that a signed permit is obtained prior t o any cutting, welding or burning on the plant premises. Management of Change (MOC): To ensure that all changes made to the ammonia refrigeration system are properly reviewed and documented. Incident Investigation: To ensure that any incident is investigated, reviewed and documented using an investigation team. Emergency Planning and Response: To describe how our facility will respond to ammonia spills and other emergencies, including evacuation procedures. Compliance Audits: To conduct regular audits to the program to ensure that the program is in place and working properly. Trade Secrets: To ensure that employees are provided with information while still protecting the company secrets. Hazard Assessment: To conduct, document, and update the hazard assessment of the plant's ammonia refrigeration system for the public and the environment. Five-Year Accident History: To determine, identify and document ammonia accidents in the last five-year accident history of the company. Risk Management Plan: To prepare, submit and update the Risk Management Plan document. It includes the most useful information for the public and local agencies in case of an ammonia accidental release. Our facility had no reportable accidents in the last five years (Five-Year Accident History) involving accidental releases of ammonia. This facility's emergency response program is based upon the OSHA requirements for Emergency Action Plans (29 CFR 1910.38 and 1910.119) and HAZWOPER (29 CFR 1910.120). We have trained employees for emergency response and maintain a written emergency response plan. This plan is coordinated with the local fire department. We conduct annual drills for implementation of the emergency response plan at the facility with the participation of the fire department, police and EMS. We are committed to the safety of our employees, the public and the environment. We plan to continue improving our operation safety through training, quality of our equipment, and employ ee participation. |