Rich Products Corporation - Hilliard Facility - Executive Summary

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Rich Products Corporation - Hilliard Facility produces donuts which are frozen for shipment by using an ammonia refrigeration system (system).  The system contains approximately 44,000 pounds of anhydrous ammonia which is liquified under pressure. 
 
Rich Products Corporation - Hilliard Facility endeavors to eliminate accidents and health hazards to our 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. Rich Products Corporation - Hilliard Facility's 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 approach 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 coul 
d expose Associates and the community to serious hazards is of primary concern.    
 
Rich Products Corporation - Hilliard Facility 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.  
 
Rich Products Corporation - Hilliard Facility has performed a worst case release scenario and an alternative release scenario to determine the potential impact of an unmitig 
ated release on the surrounding community.  The worst case release scenario would impact approximately a 1.2 mile radius from the facility and the alternative release scenario would impact approximately a 0.4 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 receiver which contains approximately 9,322 pounds of liquid ammonia.  The alternative release scenario dealt with a potential release from the high pressure receiver which contains approximately 6,115 pounds of liquid ammonia.  USEPA's RMP Guidance for Ammonia 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:  Rich Products Corporation - Hilliard Facility Associates perform routine visual inspections and maintenance on all components which comprise the system,  
the system is computer controlled and has automatic system shutdown capabilities, the low temperature receiver has liquid level alarms which result in the automatic shutdown of the system and includes liquid level sight glasses which are inspected hourly and must lie in a safe operating range or the system is shutdown, the high pressure receiver also has liquid level alarms which result in the automatic shutdown of the system and includes liquid level sight glasses which are inspected hourly and must lie in a safe operating range or the system is shutdown, the low temperature recirculator and the high pressure receiver are monitored for pressure and will result in a system shutdown if a high pressure situation is reached, the low temperature recirculator 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 emergency response program was written to comply with OSHA 29 CFR 1910.119 (n), and USEPA 40 CFR 68.95.  These regulations establish the parameters to be included in the ammonia refrigeration emergency response program.  All Associates receive training under the incident command system (OSHA 29 CFR 1910.120) at the first responder awareness level.  First responder awareness level are Associates who discover an ammonia release and who have been trained to intiate the emergency response procedures by notifying the proper authorities.  The operators of the ammonia refrigeration system (i.e., maintenance technicians, engineering technicians, and refrigeration technicians) will be trained as Hazardous Materials (HAZMAT) technicians under the incident command system.  HAZMAT technicians are Associates who are trained to respond to a potential ammonia release in order to contain or stop the release.   
The Manager Engineering Maintenance, the Maintenance Supervisor, and Refrigeration Technician will be trained as incident commanders.  Incident commanders assume control of an emergency and manage the actions to be taken to control a potential release.  Rich Products Corporation - Hilliard Facility's emergency response plan includes:  pre-emergency planning and coordination with outside parties (i.e., the Norwich Fire Department and Rich Products Coporation - Hilliard Facility have held discussions on coordination of 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 e 
mergency response plan, and personal protective equipment and emergency equipment to be maintained at the facility(e.g., self contained breathing apparatus).  Rich Products Corporation - Hilliard Facility schedules two emergency response exercises per calendar year to practice the emergency response plan and identifies any inadequacies and areas for improvements.
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