Edy's Grand Ice Cream - Fort Wayne, IN - Executive Summary |
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Edy's Grand Ice Cream is proud to inform all interested parties that our company is complying with OSHA's Process Safety Management Standard (PSM), Title 29 Code of Federal Regulations 1910.119, and EPA's Risk Management Program regulations (RMP), Title 40 CFR Part 68. In addition to other state and local codes applicable to our facility and process. We have undertaken this process to deal with the risks involved with the storage, handling, and use of Anhydrous Ammonia in our facility. Our goal is to promote overall worker, public, and plant safety. Edy's Grand Ice Cream is located at 3426 Wells Street, Fort Wayne, Indiana. We manufacture some of the finest ice cream in the world. The facility includes processing tanks, piping, packaging equipment, raw materials warehousing, finished goods refrigerated storage, an Ammonia refrigeration engine room, boilers, and miscellaneous utilities. Also located at the facility is raw milk processing equipment, shipping and receiving docks, an d a waste water treatment equalization tank. The facility produces and ships approximately 240 million pounds of finished product each year. The refrigeration system required for our production process necessitates the submission of this Risk Management Plan. The refrigeration system contains in excess of 69,000 pounds of anhydrous ammonia. This surpasses the threshold quantity of 10,000 pounds outlined in Process Safety Management and Risk Management Program regulations. Edy's Grand Ice Cream has implemented numerous policies and procedures to enable our facility to prevent the occurrence, and minimize the consequences of significant releases of Anhydrous Ammonia as well as other hazardous substances, fires, explosions, and other types of catastrophic accidents. Overall these programs prevent accidental fatalities, injuries, and illnesses and avoid property damage. Our safety programs prevent accidents because they focus on the rules, procedures, and practices that govern indiv idual 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 our facility. Edy's Grand Ice Cream has organized the information and polices pertaining to the process into a complete library consisting of nine numbered volumes, some volume numbers are assigned to sets of reference manuals, such as Operation and Maintenance manuals. This library also incorporates the use of videos and computerized tests. Volume I of the PSM/RMP Library incorporates mainly policies, the following policies are included in Volume I: Employee Participation Guidelines: This policy outlines the commitment between management and employees to establish a program for a successful (safe) program. Process Safety Information: This includes information on the ammonia inventory at the facility, applicable codes, design standards, and information pertaining to the hazards of ammonia (referenced from the IIAR ammonia Data Book). Process Hazard Analysis Program: This program outlines a thorough, orderly, systematic approach for identifying, evaluating, and controlling potential hazards within a process involving potentially hazardous chemicals such as ammonia. Contractor Qualification Guidelines: This guideline has been established to verify that the contractors working in the facility are qualified to work on the system, trained in the hazards associated with their work, and made aware of the hazards presented by the facility to the employees of the contractor. Management of Change and Pre-Startup Safety Review Programs: These programs have been developed to monitor and provide a "checks and balances" system to monitor changes in the facility and to verify that changes are safe and consistent with company policy. Many more specific programs and policies (Hot Work, Confined Space, Lockout / Tagout, Employee training, etc..) have been developed. For information specific to these see the Risk and Reliability Manager. Volume II incorporates information on the specific system components of the production area equipment. This information is used as a reference source for the operator to positively identify system components. This manual also provides a checklist for performing the yearly Mechanical Integrity Inspection. Volume III incorporates a complete valve list, process and instrumentation diagrams, flow schematics, and other drawing pertinent to the production area equipment. The valve list contains information on the type, port size, identifying number, use, location, model, manufacturer, drawing reference, and normal operating position of each valve in the system. Process and Instrumentation Diagrams are included for the individual system components. Flow schematics are included showing the entire system. A Block flow diagram provides a brief overview of the system. Drawings are included showing symbol and abbreviation descriptions. Plan views are included to all ow the operator to physically locate equipment in the building. Volume IV incorporates a complete set of standard operating procedures for the production area equipment, describing the proper steps for preparing components for start-up, starting components, monitoring normal operation, shutting down as part of normal operation, restarting equipment as part of normal operation, shutting down equipment for maintenance, restarting equipment after maintenance, shutting down equipment in emergency situations, restarting equipment after an emergency situations shutdown, and pumpout procedures. Also included as a part of each Standard Operating Procedure is the Technical Operating Specifications for the associate system component. This information includes consequences of deviation from standard operating procedures. Volume V contains Operation and Maintenance Information for the production area equipment including manufactures information, spare parts list, maintenance procedures, and prev entative maintenance procedures. Volume VI incorporates information on the specific system components of the warehouse equipment (similar to volume II). Volume VII incorporates a complete valve list, process and instrumentation diagrams, flow schematics, and other drawing pertinent to the warehouse area equipment (similar to volume III). Volume VIII incorporates a complete set of standard operating procedures for the warehouse area equipment (similar to volume IV). Volume IX contains Operation and Maintenance Information for the warehouse area equipment including manufactures information, spare parts list, maintenance procedures, and preventative maintenance procedures (similar to volume V). Process Hazard Analysis were performed in June 1995 for the production area and in December 1998 for the warehouse area. These PHAs highlighted some deficiencies in the system. These items were addressed as part of the continuous improvement of the facility. These items were addressed on th e basis of priority (Injuries to personnel). Items of a low priority (Process improvements) were budgeted for completion in 1996 and 1999 respectively. Edy's Grand Ice Cream ammonia refrigeration system also incorporates additional safety items such as tagging of all valves and components, and a PC / PLC based control system with a graphical operator interface that controls mitigating devices such as emergency exhaust fans and alarms. DESCRIPTION OF THE PRODUCTION AREA REFRIGERATION SYSTEM The Edy's Grand Ice Cream production system operates separately from the warehouse system described below. The production facility incorporates a standard evaporation and Compression Style Ammonia Refrigeration system. Ammonia vapor from the Intercoolers is routed to the suction inlet of the High Stage Compressors. At the High Stage Compressors, ammonia vapor is compressed to a super heated vapor. The super heated vapor is fed to the Evaporative Condensers. At the Condensers the super heat ed vapor rejects heat and converts to high pressure Condensed Liquid Drain. The condenser accomplishes this by using a combination of air and water flow across ammonia coils. The condensers are equipped with Hydrostatic Relief valves that relieve around the isolation valves. Airflow is supplied to the condensers via fans internal to each condenser. Water from the Condenser Water Sump is pumped via the Condenser Pumps to the Evaporative Condensers. At the Condenser the water is forced through spray nozzles over the ammonia coils. Water is collected at the bottom of the Condenser in a sump pan where it gravity drains back to the Condenser Water Sump. From here it is recirculated back to the condensers. As the water level of the Condenser Water Sump lowers it trips a Water Makeup Float which opens allowing water makeup to refill the Condenser Sump Tank. The Condenser Water Sump is also equipped with a Ozone Generator for the control of contaminates in the water system. A Sight Gla ss mounted on the Water Sump Tank allows the operator to see the correct water level in the sump tank. The Condensed Liquid Drain from the Evaporative Condensers gravity drains to the Thermosyphon Vessels. High Pressure Liquid gravity drains from the Thermosyphon Vessels to Thermosyphon Supply Headers which supply liquid to the Thermosyphon Oil Coolers of the High Stage and the Low Stage Compressors. At the Thermosyphon Oil Coolers on the Compressors the High Pressure Liquid absorbs heat from the oil pumped through the Compressor. As it absorbs heat it changes from a liquid to a Liquid/Vapor Combination. This Liquid Vapor Combination is returned from the Thermosyphon Oil Cooler on each Compressor to the Thermosyphon Return Header where it returns to the Thermosyphon Vessels. In the Thermosyphon Vessels the liquid and vapor is separated. The liquid being recirculated back out to the Compressors. The Vapor is fed to the Evaporative Condensers, where it is re-condensed and ret urned to the Thermosyphon Vessels. As liquid accumulates in the Thermosyphon Vessels it will gravity drain into the Receiver where it is stored. As Ammonia Liquid is needed in the system, it is fed from the Receiver through Liquid Filters to several Evaporators and as Liquid Makeup to several vessels. High Pressure Liquid is fed to the Purgers. Purged Gas is piped from the Purge Points to the Purgers. This system has several Purge Points. The Evaporative Condensers Purge Points on the Condensed Liquid Drain Outlets. Any non-condensables in the Vapor Stream are removed periodically by the Purgers. The Purge Gas is separated by Purgers. It separates ammonia from the non-condensables by condensing the ammonia into a liquid. Any non-condensables are piped to a Water Bubbler to remove any traces of ammonia. Condensed Vapor is piped back to a Vessel. High Pressure Liquid is also fed through a coil in the Intercooler. While circulating through the coil inside the Intercooler, the liquid rejects heat into the surrounding vapor thus cooling the liquid. The Sub-Cooled Liquid from the Intercooler is fed into the Low Temperature. High Pressure Liquid is also fed to Intercooler for liquid make-up. The Intercooler receives Booster Discharge from the Low Stage Compressors and cools the discharge before going to the High Stage Compressors. High Pressure Liquid from the Filter Assembly is also fed to several evaporators throughout the production area. As the liquid passed through the coil it absorbs heat from the air, changing from a liquid to a vapor. The vapor from these evaporators is piped back to the intercoolers or the Suction Trap. The system is equipped with two Heat Exchangers which, utilizing high stage discharge, heat a glycol solution which is then piped under the freezer floors to prevent a buildup of permafrost. In the Heat Exchangers the vapor rejects heat thus condensing to a liquid where it collects on the bottom of the Heat Exchangers and drains back into the High Stage Suction Main. The Liquid from the Low Temp. Recirculators is pumped via Refrigerant Pumps to the Low Temperature Recirculated Evaporators. Low Temperature Recirculated Suction returns from the Low Temperature Evaporators to the Low Temp. Recirculators where the liquid/vapor separates. The liquid is pumped back to the Evaporators. The vapor is compressed in the Low Stage Compressors. The compressed vapor from the Low Stage Compressors is discharged into a Common Low Stage Discharge Main where it is returned to the inlet of the Intercoolers. DESCRIPTION OF THE WAREHOUSE AREA REFRIGERATION SYSTEM The Edy's Grand Ice Cream warehouse system operates separately from the production system described above. The facility incorporates a standard evaporation and Compression Style Ammonia Refrigeration system. Ammonia vapor, High Stage Suction, from the Intercooler is routed to the suction inlet of the High Stage Screw Compressors. At the High Stage Compressors , ammonia vapor is compressed to a super heated vapor and fed to an Evaporative Condenser, where the vapor rejects heat and converts to high pressure Condensed Liquid. The condenser accomplishes this by using a combination of air and water flow across ammonia coils. The condensers are equipped with Hydrostatic Relief valves that relieve around the isolation valves. Airflow is supplied to the condensers via fans internal to the condenser. Water is supplied to Condenser via a Water Pump. At the Condenser the water is forced through spray nozzles over the ammonia coils and then collected in a sump pan where it gravity drains back to the Condenser Water Sump and is recirculated back to the condensers. As the water level of the Condenser Water Sump lowers it trips a Water Makeup Float which opens allowing water makeup to refill the Condenser Sump Tank. The Condenser Water Sump is also equipped with an Ozone Generator for the control of contaminates in the water system. A Sight Glass m ounted on the Water Sump Tank allows the operator to see the correct water level in the sump tank. The Condensed Liquid Drain from the Evaporative Condenser gravity drains to the thermosyphon portion of the High Pressure Receiver. High Pressure Liquid gravity drains from the thermosyphon portion of the Receiver the Thermosyphon Oil Coolers of the Compressors. At the Thermosyphon Oil Coolers on the Compressors the Liquid absorbs heat from the oil pumped through the Compressor. As it absorbs heat it changes from a liquid to a Liquid/Vapor Combination, which is returned from the Thermosyphon Oil Coolers to the Thermosyphon Portion of the High Pressure Receiver, where the liquid and vapor is separated. The liquid being recirculated back out to the Compressors. The Vapor is returned to the Evaporative Condenser, where it is re-condensed. As liquid accumulates in the Thermosyphon Portion of the Receiver it will overfill and gravity drain into the Receiver Portion of the Receiver whe re it is stored until needed. As Ammonia Liquid is needed in the system, it is fed (by pressure) from the Receiver through Liquid Filters and then used to feed several Evaporators and as Liquid Makeup to several vessels. High Pressure Liquid is fed to the Purger. Purged Gas is piped from the Purge Points at Evaporative Condenser to the Purger. The Automatic Gas Purger separates the ammonia from the non-condensable by condensing the ammonia into a liquid. Any non-condensable are piped to a Water Bubbler to remove any traces of ammonia. Condensed Vapor is piped back to the Low Temperature Recirculator. High Pressure Liquid is also fed to Intercooler as liquid make-up. The Intercooler receives Booster Discharge from the Low Stage Compressors and cools the discharge before going to the High Stage Compressors. The liquid from the Intercooler is fed into the Low Temperature Recirculator. High Pressure Liquid from the Filter Assembly is also fed to the Charging Room Evaporators. As t he liquid is passed through the coil it absorbs heat from the air, changing from a liquid to a vapor. The Vapor from these Evaporators is piped back to the Intercooler. High Pressure Liquid is also fed to a Munters Unit located on the Dock where it absorbs heat changing from a liquid to a vapor. The vapor is also returned to the Intercooler. Each Ammonia Compressor, the Low Temperature Recirculator, the Receiver, and the Intercooler is equipped with dual safety relief valves which are piped to Common Relief System. The Oil Pots, and transfer vessel is equipped with a single relief valve which is piped into the common Relief System. The Common Relief System is piped through the roof and is equipped with a rain cap. Each Thermosyphon Oil Cooler is equipped with a single hydrostatic relief valve which is piped from the Oil Cooler into the Oil Separator. The Thermosyphon Oil Coolers are also protected on the ammonia side by hydrostatic relief valves. Several vessels are equipped wi th Oil Pots, which allow oil to be removed from the system. The system is equipped with a Heat Exchanger which, is then piped under the freezer floors to prevent a buildup of permafrost. In the Heat Exchanger the vapor rejects heat thus condensing to a liquid where it collects on the bottom of the Heat Exchanger and is returned to Intercooler. The Liquid from the Recirculator is pumped via Pumps to Evaporators. Low Temp. Recirculated Suction is returned to the Recirculator where the liquid vapor separates. The liquid is pumped back to the Evaporators. The vapor is drawn into the Low Stage Compressors, where it is compressed. The compressed vapor is returned to the inlet of the Intercooler. The Dry Suction from the Intercooler is compressed in the High Stage Compressors, and then discharged to the Condenser. Low Temp. Recirculated Liquid is pumped from the Recirculator to the Evaporators in Storage Box 4, the Warehouse Shipping Dock, the Warehouse Storage Box, the Staging Area, and Storage Box 6. While in the evaporator it absorbs heat from the air and changes from a Liquid to a Liquid/Vapor Combination. The Liquid/Vapor Combination returns to the recirulator. These Evaporators are equipped with a hot gas circuit. The Hot Gas is used for defrost. The defrost condensate to be pumped back into High Stage Suction Main where it is returned to the Intercooler. The Transfer Vessel is used when there is a high liquid level in the Intercooler. Upon demand the liquid returned to the Thermosyphon Vessel/Receiver, via hot gas pressure. DESCRIPTION OF THE WORST CASE RELEASE SCENARIO In the worst case scenario the piping between the Receiver and the King Solenoid Valve is penetrated. There are ammonia detectors in the engine room and will shut down the compressors and stop the flow of ammonia through the refrigeration system. The amount of ammonia that can continue to be expelled is the liquid that can gravity drain from the Evaporative Condensers to the Thermosyphon Vessels to the High Pressure Receiver. The calculated amount of this release is approximately 6,300 lbs. The Receiver is located in the production engine room, which provides a mitigating effect by slowing the migration of the released ammonia to the atmosphere. EPA's RMP*COMP calculated a release rate of 347 lbs. per minute and a release duration of ten minutes. The Atmospheric Stability Class is F and the wind speed is 1.5 meters per second. The topography around the facility is urban. RMP*COMP calculated a toxic radius of 0.70 miles. Using LandView III it was determined that approximately 3,600 people live within this radius. Also it was determined by the map generated using LandView III that the following public receptors are within the radius: a school, residences, a youth correction facility, recreation areas, offices, and a zoo. The use of passive mitigation devices include: enclosures, drains and sumps. DESCRIPTION OF THE ALTERNATE CASE RELEASE SC ENARIO In the alternate case scenario a surge drum on the roof is penetrated. RMP*COMP calculated the amount of this release to be approximately 1,120 lbs. EPA's RMP*COMP also calculated a release rate of 93.1 lbs. per minute and a release duration of 12 minutes. The Atmospheric Stability Class is D and the wind speed is 3.0 meters per second. The topography around the facility is urban. RMP*COMP calculated a toxic radius of 0.10 miles. Using LandView III it was determined that approximately 49 people live within this radius. Also it was determined by the map generated using LandView III that the following public receptors are within the radius: residences and offices. The use of active mitigation devices include: Emergency shutdown systems. SUMMARY OF THE FIVE-YEAR ACCIDENT HISTORY Edy's Grand Ice Cream has had one accident in the past five years involving ammonia. The accident occurred on the morning of June 23, 1997 at approximately 0900 hours. An employee mista kenly loosened the seat assembly on a thermal expansion valve instead of the dust cap. As a result the internal apparatus of the valve fell out and high pressure liquid ammonia was released into the space. This release was estimated to continue for ten minutes with a total release of 2,500 lbs. and was reported to the EPA. Injuries include the individual that loosened the seat assembly and two other maintenance operators that responded to help. All three victims received minor injuries and were treated at a local hospital and released. There were no deaths. The estimated damage included loss of finished product valued a $5,000,000. An investigation resulted in the following conclusions. The cause of the incident was human error while performing a maintenance activity. As a result there has been additional training of employees and changes in maintenance procedures to prevent a reoccurrence of this particular incident. DESCRIPTION OF THE EMERGENCY RESPONSE PLAN In the event t hat an ammonia leak is detected employees are to notify the onsite Engineer and Emergency Response Facilitator. The facilitator takes an ammonia level reading using a detection device. If the facilitator determines that the ammonia level is above 25 ppm an evacuation of the exposure area is ordered. The engineer determines if the leak is serious enough that outside assistance is needed. If outside assistance is needed the local HAZMAT organization is contacted. Also Edy's Grand Ice Cream Emergency Response Team is contacted. The engineers then take appropriate procedures, such as Emergency Shutdown Standard Operating Procedures, to control the leak with personal protective devices in place. Once the Incident Commander arrives on scene, a report is given and the Incident Commander takes control of the situation. Edy's Grand Ice Cream is committed to continuous improvement of our policies, procedures, and facility. It is the intention of Edy's Grand Ice Cream to remain an industr y leader. New technology, training techniques, and equipment are continuously being added to our system. Among the improvements slated for completion in 1999 is an extensive operator training program, policy updates, additional emergency responder training, the addition of more safety equipment, cross training of maintenance and utility personnel, modifications to the ammonia detection system, and a complete Mechanical Integrity Inspection. |