Nestle USA - Beverage Division, Inc-Freehold Plant - Executive Summary |
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A. Describe the Accident Release Prevention and Emergency Policies We at the Freehold facility of the Nestle Beverage Company recognize our need and responsibility to the environment. It is our policy to ensure facility operations promote environmental preservation by implementation of pollution prevention and control, energy and water conservation, and recycling and solid waste management practices. We are strongly committed to employing sound environmental operating practices while assuring a cost effective and competitive approach to our business. This is achieved and maintained through the following activities: o Implementation of ongoing management systems that emphasize pollution prevention, recycling, waste minimization, and water/energy conservation; o Maintain strict adherence to all applicable federal, state and local environmental regulations; o Implementation of proactive capital and manufacturing practices which reflect sound environmental and good manufacturing pract ices; o Foster and maintain amicable and effective working relationships with the regulatory community; o Compliance with Nestle USA environmental policies and long-term strategies, and continued participation in the Nestle USA environmental audit program; and, o Continued examination of our product, process, packaging, and operations for environmental improvement opportunities. Ammonia safety is a key item in the plant safety and environmental program. Nestle 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 per sonnel to respond quickly to system upsets. The Plant Manager is responsible for the management of the ammonia safety program. B. Stationary Source and Regulated Substances Handled Nestle's Freehold Plant produces and packages instant coffee and tea. The facility uses ammonia in its refrigeration system as a heat transfer medium. Ammonia is supplied to various end users in the processing of coffee and tea. The maximum ammonia inventory at the plant is approximately 72,000 pounds. Ammonia is the only regulated substance handled at the Freehold Plant. C. Summary of Worst-Case and Alternative Release Scenarios The worst-case toxic release scenario at the Freehold Plant involves the release of 50,500 pounds of ammonia to the atmosphere over a 35 minute period due to the failure of a high pressure ammonia vessel. The amount released reflects written administrative procedures in place at the plant to limit the amount of ammonia stored in the vessel to 80% of its capacity durin g shutdown conditions. The release rate also assumes that the enclosed engine room would limit the amount of ammonia released to the atmosphere. Under worst-case conditions, the resulting vapor cloud could have off-site impacts. The alternative toxic release scenario at the Freehold Plant involves the release of 6,500 pounds of ammonia over a 15 minute period. The release duration was assumed to be limited by the response of the Operators to an ammonia detector in this line. Under alternative release conditions, the resulting vapor cloud could have off-site consequences. The worst-case and alternative toxic release scenarios 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 high pressure ammonia vessel is located in an enclo sed engine room, well protected from vehicular traffic; o Pressure safety valves on the high pressure vessel should limit any pressure increases inside the tank; o Ammonia detectors should readily detect releases from the pressure relief valves in the system; 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 systems are 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, EPA's Risk Management Program Regulation, and New Jersey's Toxic Catastrophe Prevention Act (TCPA). 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 Integrity Program o Hot Work Permit Procedures o Management of Change Procedures o Accident Investigation Procedures o Compliance Audit Procedures E. Five-Year Accident History There have not been any ammonia-related incidents at the Freehold Plant during the previous five years that resulted in significant on-site or offsite consequences. F. Description of the Emergency Response Program An emergency response program has been implemented at the Freehold Plant. This program contains procedures describing how the facility will respond to fires, ammonia leaks and other emergencies, including evacuation procedures. The emergency response program includes the following elements: o Facility Desc ription o Emergency Response Organization o Emergency Response Procedures o Notification Procedures o Evacuation Procedures o Mitigation Scenarios and Procedures o Incident Termination Procedures o Emergency Preparedness and Training The program has been coordinated with the Freehold Borough Emergency Planning Committee (LEPC). G. Planned Changes to Improve Safety 22 changes were recommended to improve the equipment and the system operating procedures when the ammonia system was analyzed in 1994. The recommended changes have been evaluated and those changes that the facility felt was necessary to improve the safety of the refrigeration system were implemented. |