Papetti's Hygrade Egg Products, Inc. - Executive Summary

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Papetti's Hygrade Egg Products, Inc. manufacturers frozen egg products at our plant in Klingerstown, PA.  We have a strong commitment from both our management and operating personnel to operate and maintain our facility in both a safe and responsible manner. 
 
Ammonia is used at our facility as the cooling medium in our central plant refrigeration system in a similar way or function as "Freon" acts in a home or automobile air conditioning system. Ammonia is used to cool our product in spiral and  blast freezers and maintains our raw ingredients at proper temperatures in cold storage rooms. Ammonia is also used to cool our packaging and shipping rooms giving our product improved shelf life. The ammonia at our facility is contained in a closed loop system; it is designed to remain inside our steel piping, coils, exchangers and vessels. The ammonia refrigeration system has been expanded in three phases with the initial or first phase of the system installed  in 1995 and the most recent or  
third phase of installation was completed in 1998.  The entire ammonia refrigeration system is monitored and controlled by a computer based control system. We believe that ammonia provides the most environmentally friendly, safest and efficient cooling choice for our operation. 
 
A. Describe the accident release prevention and emergency policy. 
 
Papetti's Hygrade Egg Products, Inc. takes many precautions to prevent or minimize accidental releases from our ammonia refrigeration system. These precautions include safety controls (alarms and automatic shutdown devices) which are designed to identify and prevent potentially unsafe conditions such as pressure increases that could cause a system failure, We also have implemented a PM or preventative maintenance program designed to maintain the overall integrity of the system. Additionally, we have on-going training programs for both safe operating and emergency procedures to ensure that our facility is operated by qualified personnel and to re 
spond quickly and knowledgeably to system upsets. 
 
The Safety Compliance Officer is responsible for the management of these ammonia safety programs. 
 
B. Stationary source and regulated substances handled. 
 
The Klingerstown facility operates a refrigeration system with an inventory of approximately 24,182 lbs. of ammonia. This ammonia used in our refrigeration system represents the only substance covered by the Accidental Release Prevention Regulations handled at the Klingerstown facility. 
 
C. Summary of worst-case and alternative release scenarios. 
 
The worst case scenario from the Klingerstown, PA plant, as defined by the EPA, is the release of all the ammonia from the largest vessel on site. At our Klingerstown plant, this release would be 13,270 lbs. of ammonia over a ten (10) minute period due to the failure of the high pressure receiver. The lbs. represents the maximum allowable amount of ammonia that would be contained in the receiver at any time. This scenario as defined by EPA  
also requires us to assume that the weather conditions during a worst case scenario release would have almost no wind and no mixing in the atmosphere. 
 
The alternative release scenario at the Klingerstown plant would involve the release of 2,430 lbs. of ammonia over a thirty (30) minute period due to the rupture of a 3/4" high pressure vapor  tube/pipe located in or on one of condensers. The duration of the alternative release scenario was estimated by the amount of time required to identify the leak,  isolate the equipment and stop the leak or evacuate the ammonia from the piece of equipment. Once again, the impact of this release also assumes the release occurs under both low wind and stable weather conditions per EPA requirements. 
 
The two (2) above release scenarios are extremely unlikely for many reasons.  Our equipment and system were designed using industry standards specifically for ammonia refrigeration. We have taken precautions to protect our equipment from obvious threats s 
uch as vehicular traffic. We have a PM program to maintain the on-going integrity of the refrigeration equipment and system. Training programs are in place and monitored to ensure that only qualified personnel operate and work on/repair the system and our emergency response procedures provide for quick and decisive responses in the event of an accident. Finally, the weather conditions used in estimating the extent of a release are uncommon at best. 
 
D. Description of the accidental release prevention program. 
 
The facility has an accident release prevention plan that complies with the Occupational Safety and Health Act's (OSHA), Process Safety Management Standard and EPA's Risk Management Program Regulation. The prevention program consists of the following elements: 
 
   -  Employee Participation Program 
   -  Process Safety Management 
   -  Process Hazard Analysis 
   -  Operating Procedures 
   -  Training Program 
   -  Contractor Safety Program 
   -  Pre-Startup Safety Review Pr 
ocedures 
   -  Mechanical Integrity Program 
   -  Hot Work Permit Procedures 
   -  Management of Change Procedures 
   -  Incident Investigation Procedures 
   -  Compliance Audit Procedures 
 
E. Five Year Accident History 
 
In the past five (5) years there have been no ammonia related accidents at the Klingerstown, PA plant. 
 
F. Description of the Emergency Response Program 
 
An emergency response program has been implemented at the Klingerstown plant. This program contains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures. The plan has been reviewed with our local fire department and Hazmat team and we have incorporated suggested changes or additions where feasible. 
 
Our plant response team utilizes trained employees to identify risks,  enter affected areas safely and with properly maintained protection equipment and stop/limit the effects of  an accidental ammonia release. 
 
G. Planned Changes to Improve Safet 

 
Papetti's Hygrade Egg Products, Inc. is committed to operating our ammonia refrigeration system in a safe, efficient and responsible manner. We are continually evaluating our equipment and procedures to meet this objective. Planned improvements include the installation of  rupture disks up stream of pressure relief valves during their normal replacement period.
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