Good Humor Corporation Framingham - Executive Summary |
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EXECUTIVE SUMMARY This report contains the Risk Management Plan (RMP) for the ammonia refrigeration system located at the Good Humor-Breyers Ice Cream facility in Framingham MA. The RMP was prepared by Primatech in accordance with the requirements of the U.S. Environmental Protection Agency (EPA) 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. A. Accidental Release Prevention and Emergency Response Policies Good Humor recognizes management's responsibility in protecting its 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 Framingham 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 with 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), and EPA's Risk Management Program (RM program) regulation (Risk Management Programs for Chemical Accidental Release Prevention, 40 CFR Part 68). The Engineering Services Manager, is responsible for implementation of the Risk Management Program. The purpose of the accidental released prevention and emergency response programs is to prevent the occurr ence, 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 Handled Good Humor operates an ice cream production facility in Framingham, MA. The facility operates an ammonia refrigeration system to provide cooling and freezing capabilities. The amount of anhydrous ammonia (CAS #7662-41-7) contained in the system is in excess of 10,000 pounds. The maximum inventory in the system is 50,0 00 pounds. Since an ammonia release from the system could pose a risk of offsite public impact and the system is regulated under the OSHA PSM standard (29 CFR 1910.119), the system is subject to the Program 3 requirements of the EPA's RM program. In the ammonia refrigeration system, liquid ammonia (High Pressure Liquid: HPL) is fed to the Silos, Glycol Chillers, Ice Cream Freezers, King Units, Compressors, and Intercooler from the High Pressure Vessel. C. Summary of Worst -Case and Alternative Release Scenarios The worst-case release scenario at the Framingham facility involves the release of 16,190 pounds of ammonia over a 10-minute period due to the failure of the high-pressure receiver. The maximum quantity in the high-pressure receiver is represented by the entire vessel capacity, normally this vessel is maintained at a level much lower than full capacity. The scenario has been developed based on the method provided in the Risk Management Program (40 CFR 68) Guidance for Ammo nia Refrigeration. The worst-case release scenario is unlikely for the following reasons: 7 The worst-case weather conditions which were used for this scenario are uncommon; 7 The high pressure receiver is located in an enclosed area that could help to contain such a release and minimize traffic near the receiver; 7 Industry standards were followed for the manufacture and quality control of the receiver; 7 Ammonia is not corrosive in this service and the vessel is relatively new; 7 Pressure safety valves limit operating pressure in the receiver; 7 An ammonia detector which is tied to emergency ventilation fans and an external monitoring system is located near the high pressure receiver in the ammonia refrigeration system; 7 The high pressure receiver in the ammonia refrigeration system is located on a pad away from forklift traffic areas; 7 The facility has a preventive maintenance program in place to maintain the on-going integrity of vessels; 7 The facility has a training program d esigned to ensure that the system is operated by qualified personnel; and, 7 The facility emergency response procedures which enable trained personnel to respond quickly to isolate any potential releases. The alternative release scenario at the Framingham facility involves the release of 3,850 pounds of ammonia over a 10 minute period due to the rupture of a =" high-pressure liquid pipe. There are =" liquid feed lines to the silos and ice cream freezers. This 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: 7 The high pressure liquid line is located in enclosed areas that could help to contain such a release; 7 Industry standards were followed for the manufacture and quality control of these lines; 7 Ammonia is not corrosive in this service; 7 Most of the lines are elevated to minimize potential damage from fork lifts; 7 The facility has a preventive maintenance program in place to maintain the on-going integrity of the system; 7 The facility has a training program designed to ensure that the system is operated by qualified personnel; and, 7 The facility emergency response procedures 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: 7 Employee Participation: This program involves the employees in establishing and implementing the program. Employees are also to be involved when a process hazard analysis is conducted. The program also ensures that all employees have completed access to the program. 7 Process Safety Information: Written information has been collected which enables the employees to identify and understand the potential hazards in the system. The written information includes the ammonia MSDS and a description of the design of the ammonia refrigeration system. 7 Process Hazard Analysis: Formal studies using the What-If Technique have been conducted to look at that system and identify potential hazards. 7 Operating Procedures: Written, detailed procedures have been developed which describe the steps which should be followed to safely operate the ammonia refrigeration system. 7 Training: A training program has been developed which ensures that employees are trained on all aspects of the system and on the duties which they should perform to ensure the safe operation of the ammonia refrigeration system. 7 Contractors: All contractors are screened and evaluated before they perform work on or near the ammonia refrigeration system. The contractors are also periodically evaluated to ensure that they perform work by following safe work practices. 7 Pre-Startup Safety Review: A pre-startup safety review is completed for all new ammonia projects to verify that all safety program s are in place, training has been performed, and construction has been completed according to design standards before the project is put into use. 7 Mechanical Integrity: This program ensures that the ammonia refrigeration systems are built and maintained using preventive maintenance procedures to minimize unexpected breakdowns or failures. 7 Hot-Work Permit: These procedures ensure that a signed permit is obtained prior to any cutting, welding, or burning. 7 Management of Change: The procedures are designed to ensure that all changes made to the ammonia refrigeration system are properly reviewed. 7 Incident Investigation: The procedures ensure that any incidents (and near misses) are investigated, reviewed, and documented using an investigation team. 7 Compliance Audits: There are procedures to conduct regular audits of the program to ensure that the program is in place and working properly. E. Five-Year Accident History One ammonia-related incident was identified for the Fra mingham facility in the previous five years. On February 12, 1997, approximately 6.8 pounds of liquid ammonia was released over a three to four second time period. The event was initiated as a result of improper removal of the cap on a level float for an ice cream freezer during verification of the float steam position. The event was reported to the Framingham Fire Department and Framingham Emergency Medical Services. Two employees received first-aid treatment from a physician and were released to return to work. One employee received medical treatment for a freeze burn due to skin contact with liquid ammonia and was hospitalized overnight and then released. This incident did not result in property damage or offsite impacts. As a result of this incident, the operating procedures were revised for removal of caps on level controllers. F. Description of the Emergency Response Program An emergency response program has been implemented at the Framingham facility. This program cont ains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures. The program has been coordinated with the Framingham Fire Department and the Town of Framingham LEPC. The emergency response program consists of the following elements: 7 Organization Plan and Responsibilities 7 Communications Procedures 7 Detailed Action Plans 7 First Aid Procedures 7 Emergency Medical Treatment Procedures 7 Evacuation Plans 7 Description of Outside Assistance Available 7 Site Re-Entry Procedures 7 Training Programs and Drills G. Planned Changes to Improve Safety Three changes to improve safety were recommended to the equipment (hardware recommendations) when the ammonia refrigeration system was most recently analyzed during revalidation of the process hazard analysis (PHA) in July 1998. The recommended changes will be evaluated and implemented as required. |