Campbell Soup Supply Company L.L.C. - Maxton Plant - Executive Summary
A. Describe the Accident Release Prevention and Emergency Policies |
The Campbell Soup Supply Company has a deep concern for the protection of the environment, since through our daily operations we know the importance of clean surroundings. The company has always made an honest effort to preserve the natural environment and will continue to strive towards improving our efforts in all forms of pollution control; be it water, air, solids, or noise. We are dedicated to making improvements where we know they will provide positive results. The environment is a natural resource that should be used, but not abused. Our experience indicates environmental benefits can only be achieved by actions that have been preceded by scientific thought and facts, trying to avoid emotionalism.
Campbell Soup Supply Company's goal is to form a union with our environment that will benefit all of life. We are dedicated to using the earth's resources efficiently both to avoid waste and limit pollution in al
l our food processing operations. We will continue to pursue every reasonable means to preserve the environment for the present and future generations.
Ammonia safety is a key item in the Plant Safety Plan. Campbell Soup Supply Company takes many precautions to prevent or minimize accidental releases of ammonia. These precautions include safety controls (alarms and automatic shutdown devices) which are designed to identify and prevent potentially unsafe conditions like pressure increases that could cause a system failure, a preventive maintenance program designed to maintain the on-going integrity of the system, a training program designed to ensure that the system is operated by qualified personnel, and emergency response procedures which enable trained personnel to respond quickly to system upsets.
The Manager of the Maintenance & Power areas is responsible for the management of the ammonia safety program.
B. Stationary Source and Regulated Substances Handled
Supply Company's Maxton Plant produces canned food products for sale to the public. The facility operates an ammonia refrigeration system to provide freezing and cooling for the food products produced. The maximum ammonia inventory at the facility is approximately 25,000 pounds. Ammonia is the only regulated substance handled at the Maxton Plant.
C. Summary of Worst-Case and Alternative Release Scenarios
The worst-case release scenario at the Maxton Plant involves the release of 12,000 pounds of anhydrous ammonia over a 10 minute period due to the failure of the ammonia receiver. This maximum inventory reflects the written administrative procedures in place at the plant to limit the amount of ammonia stored in the receiver during pump down conditions to 85% of its capacity. Under worst-case conditions, the resulting vapor cloud could have off-site consequences.
The alternative release scenario at the Maxton Plant involves the release of 4,000 pounds of ammonia over a 3 minu
te period due to the rupture of a 1" liquid line that feeds ammonia to a product freezer. The amount of ammonia released would be limited by the amount of liquid ammonia in the liquid line connected to the freezer. Under alternative release conditions, the resulting vapor cloud could have off-site consequences.
The worst-case and alternative release scenarios for toxic materials are unlikely for the following reasons:
o The weather conditions that were used for the worst-case release scenario do not occur, while those used for the alternative case are uncommon;
o Industry standards are followed for the design and manufacture of the equipment in the ammonia refrigeration system;
o The ammonia receiver and the liquid lines are located in enclosed areas that should help to contain any ammonia releases;
o The engine room contains an ammonia detector and ventilation fans that should detect and mitigate the effects of any ammonia releases;
o The ammonia receiver is typically only half fu
ll during normal operations;
o Ammonia is not corrosive in this service;
o The facility has a preventive maintenance program in place to maintain the on-going integrity of the ammonia refrigeration equipment;
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 that enable trained personnel to respond quickly to isolate any potential releases.
D. Description of the Accidental Release Prevention Program
The facility has a program level 3 accident release prevention program for the ammonia system that complies with OSHA's Process Safety Management Standard and EPA's Risk Management Program Regulation. The ammonia prevention program consists of the following elements:
o Employee Participation Program
o Process Safety Information
o Process Hazard Analysis
o Operating Procedures
o Training Program
o Contractor Safety Program
o Pre-Startup Safety Review Procedures
o Mechanical In
o Hot Work Permit Procedures
o Management of Change Procedures
o Incident Investigation Procedures
o Compliance Audit Procedures
E. Five-Year Accident History
One ammonia-related accident occurred at the Maxton Plant during the previous five years. This accident resulted in a minor on-site injury to an employee who had an existing respiratory condition. 465 pounds of ammonia were released, but there were no offsite consequences associated with the accident.
F. Description of the Emergency Response Program
An emergency response program has been implemented at the Maxton Plant. This program contains procedures describing how the facility will respond to fires and other emergencies, including evacuation procedures.
The emergency response program includes the following elements:
o Emergency Response Organization
o Evacuation Plan
o Response Activities
G. Planned Changes to Improve Safety
Twenty-two changes were recommended to improve the equipment a
nd the system operating procedures when the ammonia system was analyzed in October 1997. The recommended changes have been evaluated and will be implemented as required.