The Dannon Company, Inc. - Executive Summary |
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THE DANNON COMPANY, INC. RISK MANAGEMENT PROGRAM EXECUTIVE SUMMARY 1. General accidental release and prevention policy of The Dannon Company. In this yogurt processing facility we utilize anhydrous ammonia as a refrigerant. Anhydrous ammonia is considered hazardous by the Environmental Protection Agency. The same properties that make ammonia a valuable refrigerant also makes it necessary to observe certain safety precautions during it's use to prevent exposure to our workers, the surrounding community and the environment. It is our policy at The Dannon Company to implement the requirements of the Risk Management Program by managing and operating this facility in full compliance with all applicable federal and state regulations that we are governed by. The objective is to minimize the risk of an accidental release of hazardous materials. Safety depends directly on our proper ha ndling of ammonia. Our plant personnel have been trained on the equipment operating procedures and the various safety devices that are incorporated in our facility to prevent the possibility of accidental releases. 2. Stationary source and regulated substance handled. The Dannon Company, Inc., 1300 Petersmith Street, Fort Worth, Texas, operates a refrigeration system utilizing anhydrous ammonia as the primary refrigerant. Mechanical refrigeration is a thermodynamic process where the refrigerant, ammonia, is used as a heat exchanging fluid to maintain a desired temperature in an enclosed environment. The refrigeration cycle consists of evaporation, compression, condensation and expansion. Evaporation and condensation are designed to alter the quantity of energy associated with the refrigerant. Compression and expansion are designed to change the availability of the associated energy. The refrigeration cycle is a closed loop process. The ammonia cycle utilizes fluid temperature, press ure and latent heat of vaporization for cooling. The refrigeration system uses this phenomenon to remove heat from a desired space, and then to discard that heat through condensation, to an area where it is of no consequence. The Dannon Company facility uses ammonia refrigeration to maintain processing, storage room and product tank temperatures required for the processing and storage of our product. There are approximately 350 employees at this facility, including hourly and salary personnel, that manufacture and prepare shipment of refrigerated dairy products via truck approximately 24 hours a day, seven days a week. The refrigeration system contains 65,000 pounds of aggregate ammonia. The potential hazards that could lead to an accidental release of the ammonia include, but are not limited to, equipment failure, damage to piping, damage to equipment, human error, etc. Although ammonia is a colorless, tasteless liquid, it's dominant characteristic is it's pungent, distinct o dor. Persons exposed to ammonia will not voluntarily stay in areas of even small concentrations, although these levels would not normally result in any health risks. Risks from accidental exposure to ammonia in a vapor state are irritations to the eyes, nose and throat. The extent of irritation depends on the exposure amount and length of time exposed. Ammonia is classified non-flammable by the Department of Transportation. Ammonia will burn, but only in a very narrow concentration level when accompanied with a constant ignition source. 3. Worst case and alternate case release scenarios including administrative and engineering controls to limit/ prevent accidental release. Worst case scenario depicts continuous source leak from the High Pressure Receiver (HPR) located inside the screw machine room. This vessels normal operating level is 16,000 pounds of liquid ammonia, approximately 35% of it's total capacity. Although the high pressure receiver is capable of holding 45,000 po unds, this exceeds engineering controls which limit the liquid level to a maximum of 80% at any time. Considering the "catastrophic" possibility does exist for this vessel to release it's entire contents, engineering controls incorporated into the system would normally prevent such a release. Worst case release scenario criteria for The Dannon Company facility: Ammonia Quantity: 16,000 pounds Rate of Release: 1600 lbs / min. (10 min. release) LOC (Level of Concern): 200 ppm (EPA ERPG-2) Physical State: Gas Type of Area: Urban Wind Speed: 1.5 m/sec Distance to Endpoint 2.2 miles Alternate release scenario is represented by the release of ammonia vapor from a safety relief valve (SRV) due to an overpressurization condition on the pump recirculator vessel located within the screw machine room. The indicated rel ief valve would be performing exactly as it is designed to do during an overpressurization condition. Valve would open to relieve the over- pressure and vent into the atmosphere via the roof vent pipe. Alternate case release scenario criteria for The Dannon Company facility: Ammonia Quantity: 230 pounds Rate of Release: 21 pounds/min. (20 min. release) Wind Speed: 3.0 m/sec. Distance to Endpoint: .1 miles The following administrative and engineering controls are in place at The Dannon Company. These controls are designed to eliminate, or reduce the possibilities of an accidental release from the refrigeration system. * Electronic ammonia detection installed in compressor rooms, coolers, processing areas and receiving. Alarm system activates a local audible alarm to alert plant personnel of the potential ammonia leak in the monitored areas. * High liqu id level switches are configured to accumulators and recirculators. High level switches will shut down associated compressor operation during a high level condition. * All compressors are configured with critical safety controls (high pressure, low pressure, high oil temp cut-outs, etc.) to shut down the respective compressor in the event of an abnormal operating condition. * Safety Relief Valves are configured to all pressure vessels, condensers and compressor oil separators to eliminate over pressurization conditions in those associated pieces of equipment. * Periodic Maintenance Program is contracted through a reputable refrigeration company to ensure the refrigeration system and it's components are kept in optimum mechanical and operating status. Weekly inspections are conducted by the refrigeration contractor. Daily rounds are made by plant personnel to verify proper equipment operation. * Security personnel on premises 24 hours a day, seven days a week to m onitor facility access as well as make rounds to detect malfunctions within the refrigeration equipment. 4. Five-year accident history. The Dannon Company facility at Fort Worth has had zero accidental releases to report. 5. Emergency Action Program The purpose of The Dannon Company Emergency Action Plan is to: 1. Minimize exposure to our employees and the surrounding community in the event of a hazardous material release or spill. 2. Assure the safe emergency evacuation of the plant in the instance that it is required. 3. Provide for prompt medical attention to any employees who become seriously injured or ill at work. 4. Facility management has developed an Emergency Response Plan to ensure a fast and efficient response in the event of an accidental release of hazardous materials. Our Emergency Action Plan currently meets requirements as set forth in OSHA 29 CFR 1910.38, Employee Emergency and Fire Prevention Plans. |