Dean Foods - Rochester, IN - Executive Summary |
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Dean Foods 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. Dean Foods in Rochester, Indiana manufactures some of the finest dairy products in the world. The facility covers approximately 100,000 square feet and 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 are raw milk processing equipment and shipping and receiving docks. The facility produces and ships approximately 280 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 14,000 pounds of anhydrous ammonia. This surpasses the threshold quantity of 10,000 pounds outlined in Process Safety Management and Risk Management Program regulations. Dean Foods 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 individual processes, activities, or pieces of equipment. These r ules are detailed and improved as necessary. They are also communicated to and accepted by all employees at our facility. Dean Foods has organized the information and polices pertaining to the process into a complete library consisting of nine volumes. 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. Employee Training Program: This program provides employees with a basic working knowledge of an ammonia refrigeration system. Areas covered are hazards of ammonia, understanding MSDS sheets, refrigeration cycles, normal system operation, emergency system operation, and an individuals place in the emergency response plan. 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 polic ies (Hot Work, Confined Space, Lockout / Tagout, etc.) have been developed. For information specific to these see the Plant Safety Coordinator. Volume II incorporates information on the specific system components of the production area equipment (Compressors, purgers, vessels, heat exchangers, evaporators, condensers, pumps, piping systems, the emergency ventilation system, safety relief valves, and general safety). 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 Ins trumentation Diagrams 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 allow the operator to physically locate equipment in the building. Volume IV incorporates a complete set of Standard Operating Procedures (SOPs) for the ammonia refrigeration system equipment. These SOPs describe the proper steps for preparing components for start-up and starting components. Monitoring normal operation of system components. Shutting down components as part of normal operation and restarting equipment as part of normal operation. Shutting down equipment for maintenance and restarting equipment after maintenance. Shutting down equipment in emergency situations and restarting equipment after an emergency situation shutdown. SOPs also discuss pumpout procedures for equipment. Also included, as a part of each SOP, are the Technical Operating Specifications (TOS) for the associate system component. This information includes consequences of deviation from standard operating procedures. Volume V contains Operation and Maintenance Information for the ammonia refrigeration system equipment including manufactures information, spare parts list, maintenance procedures, and preventative maintenance procedures. A Process Hazard Analysis (PHA) is scheduled for July 1999. Dean Foods also incorporates additional safety items such as tagging of all ammonia system valves and components. DESCRIPTION OF THE REFRIGERATION SYSTEM Dean Foods incorporates a standard evaporation and Compression Style Ammonia Refrigeration system. Ammonia vapor, High Stage Suction (HSS), from the Suction Accumulator (VS102) is routed to the suction inlet of eight High Stage Compressors (CP101 through CP108). At the High Stage Compressors (CP101 through CP108), ammonia vapor (HSS) is compressed to a super heated vapor (HSD). The super heated vapor (HSD) from the High Stage Compressors is routed from the engine room to the three Condensers (CD101, CD102 and CD103) at the condenser platform. At the Condensers the super heated vapor (HSD) rejects heat and converts to high pressure Condensed Liquid Drain (CLD). The condenser accomplishes this by using a combination of air and water flow across ammonia coils. The condensers are equipped with Safety Relief Valves which vent directly to a common relief header and then to atmosphere. Airflow is supplied to the condensers via fans internal to the condenser and water is supplied via condenser water pumps. Water from the condenser water sump is pumped via condenser water pumps to the Condensers (CD101, CD102 and CD103). At the Condensers the water is sprayed via a spray header 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 r ecirculated 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 water sump. A sight glass mounted on the condenser water sump allows the operator to see the correct water level in the condenser water sump. The Condensed Liquid Drain (CLD) from the Condensers (CD101, CD102 and CD103) gravity drains to the High Pressure Receiver (VS101). The High Pressure Receiver (VS101) is used as a storage vessel for High Pressure Liquid (HPL). As HPL is needed in the system, HPL is fed by pressure differential from the High Pressure Receiver to the Auto Purger (PU101), several evaporators, storage silos and serves as liquid makeup to several vessels. High Pressure Liquid (HPL) is fed to the Auto Purger (PU101). Purged Gas (PUR) is piped from the purge point at the piece of equipment to the Auto Purger. This system has several purge point: the Condensers (CD101, CD102 and CD103 ) and the High Pressure Receiver (VS101). Each purge point consists of a solenoid valve with shutoff valves on either side for isolation. Any non-condensables in the Vapor Stream are removed periodically by the Auto Purger. The Auto Purger separates the Purged Gas (PUR). 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 (LSS) is piped back to the Suction Accumulator (VS102). High Pressure Liquid is also fed to the Pumped Recirculator (VS104). The liquid is fed through a solenoid valve associated isolation valves and into the Pumped Recirculator (VS104). Liquid from the Pumped Recirculator (VS104) is fed via recirculation pumps to two evaporators in Box #4. As the liquid passes through the evaporator it absorbs heat from the air changing to a liquid/vapor mix. The liquid/vapor mix from evaporators through a suction regulator as it exits. The liquid/vapor mix from these evaporators is piped back to the Pumped Recirculator (VS104). High Pressure Liquid from High Pressure Receiver (VS101) is also fed to several evaporators and storage silos throughout the facility. The High Pressure Liquid (HPL) which is fed to the evaporators and silos typically passes through a solenoid valve and then an expansion valve at each unit. As the High Pressure Liquid (HPL) passes through the expansion valve it undergoes a deliberate change in pressure which acts to expand part of the liquid to a vapor and sub-cools remainder of the liquid. As the liquid passed through the evaporator or silo it absorbs heat, from the air or the material within the silo, changing from a liquid (HPL) to a vapor (HSS). The vapor (HSS) from evaporators and silos passes through a suction regulator as it exits. The vapor (HSS) from these evaporators is piped back into the High Stage Suction Header (HSS) and thus back to the Suction Accumulator (VS102). DESCR IPTION OF THE WORST CASE RELEASE SCENARIO In the worst case scenario the piping between the High Pressure Receiver (R-1) and the King Solenoid Valve is penetrated. The E-Stop circuit is tripped. This action shuts down the compressors and closes the King Solenoid Valve stopping the flow of ammonia through the refrigeration system. The amount of ammonia that can continue to be expelled is the liquid that drains from the Condensers (CD101, CD102 and CD103) and Thermosyphon Vessel (VS109) to the High Pressure Receiver (VS101). The calculated amount of this release is approximately 4,568 lbs. EPA's RMP*COMP calculated a release rate of 457 lbs. per minute with 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 0.90 miles with some public receptors. DESCRIPTION IF THE ALTERNATE RELEASE SCENARIO In the alternate case scenario a >" l iquid supply pipe in Cooler #3 is penetrated. RMP*COMP calculated the amount of this release to be approximately 9,430 lbs. The Atmospheric Stability Class is D and the wind speed is 3.0 meters per second. The topography around the facility is urban. Since the release occurred inside of Cooler #3, the cooler acted as a mitigating device with 8,540 ft2. RMP*COMP calculated a toxic radius of 0.10 miles with some public receptors. The use of active mitigation devices include: Emergency shutdown systems. SUMMARY OF THE FIVE-YEAR ACCIDENT HISTORY Dean Foods has had no reportable accidents in the past five years involving ammonia. DESCRIPTION OF THE EMERGENCY RESPONSE PLAN In the event that an ammonia leak is detected employees are to notify the receptionist. The receptionist makes an announcement over the public address system for the onsite Emergency Response Team to assemble in a designated location. The Emergency Response Team then evaluates the situation and takes furt her actions. Additionally piping has been removed from this location in the cooler. CONCLUSION Dean Foods is committed to continuous improvement of our policies, procedures, and facility. It is the intention of Dean Foods to remain an industry 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 and a complete Mechanical Integrity Inspection. |