Good Humor Corporation Hagerstown - 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 Hagerstown, MD. 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 - Breyers-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 Hagerstown facility. To accomplish the Company's g oal 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), 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 purposes of the accidental release prevention and emergency response programs are to p revent 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 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-Breyers operates an ice cream production facility in Hagerstown, MD. 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 th e system is $54,000 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, the system is subject to the Program 3 requirements of the EPA's RM program. C. Summary of Worst-Case and Alternative Release Scenarios The worst-case release scenario at the Hagerstown facility involves the release of 17,840 pounds of ammonia over a 10-minute period due to the failure of the high-pressure receiver. The scenario has been developed based on the method provided in the Risk Management Program (40 CFR 68) Guidance for Ammonia Refrigeration. 7 The worst-case weather conditions which were used for this scenario are not typical; 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 an exte rnal monitoring system is located near the high pressure receiver in the receiving bay; 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 designed 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 Hagerstown 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 used for cooling the compressors. 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: 7 The high-pressure liquid lines are located in enclosed area that could help to contain such a release; 7 Industry standards were followed for the manufacturer 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 forklifts; 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, 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: 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 complete 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 details 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 the system and identify potential hazards. 7 Operating Procedures: Written, detailed procedures have been developed which describe the steps to be followed to ensure that the ammonia refrigeration system is operated safely. 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 evalua ted 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 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. 7 Mechanically Integrity: This program ensures that the ammonia refrigeration system have been properly installed and is 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 documen ted 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 Two ammonia-related incidents were identified for the Hagerstown facility in the previous five years. On October 12, 1998, less than sixty (60) pounds of liquid ammonia was released from a valve leak over a two (2) minute time period. Four (4) employees received medical treatment. This incident did not result in property damage or offsite impacts. On June 7, 1995, a vapor release occurred from a piping leak. Less than one hundred (100) pounds of ammonia vapor was released over a five (5) minute time period. Eighteen (18) employees received medical treatment and approximately sixty- (60) people sheltered-in-place offsite. This incident did not result in property damage or offsite injuries. F. Description of the Emergency Response Program An emergency response program has been implemented at the Hagerstown facility. This program contains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures. The program has been coordinated with the Washington County 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 Two (2) changes to improve safety were recommended for the equipment and procedures when the ammonia refrigeration system was most recently analyzed during revalidation of the PHA in November 1998. The recommended changes will be evaluated and implemented as required. |