Rich Products Manufacturing Corp.-Buffalo Facility - Executive Summary |
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Rich Products Corporation - Buffalo Facility (RPC-BF) produces non-dairy creamers, pudding, frozen dough, and food products which are frozen for shipment by using an ammonia refrigeration system. The RPC-BF has two distinct and separate ammonia refrigeration systems at the facility and are referred to as the old and new ammonia refrigeration system. The old refrigeration system and the new refrigeration system contain approximately 29,000 and 25,000 pounds of anhydrous ammonia which is liquified under pressure, respectively. RPC-BF endeavors to eliminate accidents and health hazards to our fellow Associates, customers, and the community by providing our Associates educational training, safe working conditions, and the means to increase awareness of potential dangers both on and off the job. RPC-BF objective is to prevent unwanted releases of ammonia into locations that could potentially expose Associates and others to serious hazards. An effective program requires a systematic ap proach to evaluating the entire system. Workplace and process safety are major concerns to management and Associates alike. The prevention and mitigation of unwanted releases of ammonia into locations that could expose Associates and the community to serious hazards is of primary concern. RPC-BF has developed this program in accordance with OSHA Title 29 CFR 1910.119, and the USEPA Title 40 CFR Part 68. The program is designed to inform all Associates of the hazards of ammonia, procedures for the safe use of ammonia, and the steps taken for the safety of Associates in the event of a release or spill (i.e., emergency response plan, management of change procedures, preventative maintenance program, associate training, etc.). In addition, Rich Products Corporation has generated "The 15 Point Plus Health and Safety Program" which outlines the corporate policy for safety policies, safety procedures, and sample programs to be implemented at each Rich Products Corporation Facility. T he RPC-BF facility has experienced and well trained operators that have worked with the ammonia refrigeration system, in some cases, in excess of twenty years. Training of Associates is well documented and implemented at the RPC-BF. RPC-BF has performed a worst case release scenario and an alternative release scenario to determine the potential impact of an ammonia release on the surrounding community. The worst case release scenario would impact approximately a 0.6 mile radius from the facility and the alternative release scenario would impact approximately a 0.2 mile radius from the facility. Therefore, each scenario has a potential offsite impact. The worst case release scenario looked at a potential release from the low temperature accumulator which contains approximately 2,000 pounds of ammonia. The alternative release scenario dealt with a potential release from the high pressure receiver which contains approximately 1,000 pounds of ammonia. USEPA's RMP Guidance for Ammoni a Refrigeration reference tables and equations were used in determining the worst case and alternative release scenarios offsite impacts. A release of either nature is unlikely due to the following: RPC-BF associates perform routine visual inspections and maintenance on all components which comprise each system. Each system has computer generaed work orders for maintenance activities that are time dependant. The low temperature accumulator has liquid level cut outs which would minimize the amount of ammonia released and includes liquid level sight glasses which are inspected periodically and must lie in a safe operating range or the system is shutdown. The high pressure receiver also has liquid level cut outs which would minimize the amount of ammonia released and includes liquid level sight glasses which are inspected periodically and must lie in a safe operating range or the system is shutdown. The low temperature accumulator and the high pressure receiver are monitored for pre ssure and will result in a system shutdown if a high pressure situation is reached. The low temperature accumulator and the high pressure receiver have solenoid valves which control the flow to each device and will open and close dependant upon the liquid levels detected and thereby minimize the potential of a release, and both vessels have pressure relief valves which will vent to the roof if a high pressure situation is encountered. The RPC-BF has had five accidental releases of ammonia in the past five years. None of the releases has impacted the surrounding community, and no associates have been injured or required hospitalization. The release amounts have been minimal and have not reuired the implementation of the emergency response plan, or the notification of offsite responders. The emergency response program was written to comply with OSHA 29 CFR 1910.119 (n), OSHA 29 CFR 1910.120, and USEPA 40 CFR 68.95. These regulations establish the parameters to be included in the am monia refrigeration emergency response program. The RPC-BF has an onsite HAZMAT response team and incident command system in place with well defined roles. All Associates participating on the HAZAMT Team are trained to at least the twenty-four hour HAZMAT Technicians First Responders Level. First responder awareness level training provides the Associates with the training required to recoginize an ammonia release and to intiate the emergency response procedures by notifying the proper authorities. In addition, all emergency reponse activities have been coordinated with the City of Buffalo Fire Department and HAZMAT Team. Table top emergency drills and evacuation drills are conducted periodically under the supervision of the RPC-BF and the City of Buffalo Fire Department and officials. RPC-BF's emergency response plan includes: pre-emergency planning and coordination with outside parties (i.e., the City of Buffalo Fire Department, the City of Buffalo HAZMAT Team, the Erie Count HAZMAT Team, and the Erie County Local Emergency Planning Committee), drills and preparedness acitivities to respond to a potential ammonia release, associates roles, lines of authority, training and communication, emergency recognition and prevention, safe distances and places of refuge, site security and control, evacuation routes and procedures, decontamination, emergency medical treatment and first aid, emergency alerting and response procedures, critique of response and follow-up reports to improve the efficiency and execution of the emergency response plan, and personal protective equipment and emergency response equipment maintained at the facility (e.g., self contained breathing apparatus). |