Gorton's - Executive Summary

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                         RISK MANAGEMENT PROGRAM 
                                                    EXECUTIVE SUMMARY 
1.  General accidental release and prevention policy of Gorton's. 
Gorton' is a frozen seafood processing facility that utilizes 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 Gorton's 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 handling of am 
monia. 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. 
Gorton's, 127 Rogers Street, Gloucester, Massachusetts 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, pressure and latent heat of vap 
orization 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. 
Gorton's facility adjoins an Americold Cold Storage facility that receives finished product from 
Gorton's.  The refrigeration system is actually a spilt system that is operated by Americold. 
Americold operates the machine room (compressors, condenser, receivers) while Gorton's 
operates and maintains the low side of the system, (pump receivers, coil evaporators, water 
chillers and coolers) to maintain processing, freezer and holding room temperatures required for 
the processing and storage of our product. There are approximately 400 employees at this facility, 
including hourly and salary personnel, that manufacture and prepare shipment of frozen seafood 
products via truck approximately 24 hours a day, five days a week. 
The refrigeration system contains 40,000 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 odor.  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 Low Pressure Pump Receiver 
located in a yard area adjacent to the Americold machine room. The receivers normal operating 
level is 4,400 pounds of ammonia. Although the receivers total capacity is 8,800 pounds, 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 Gorton's facility: 
    Ammonia Quantity:                  4,400 pounds 
    Rate of Release:                   440 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                    
1.3 miles 
Alternate release scenario is represented by the release of ammonia vapor from a safety relief 
valve (SRV) due to an over-pressurization condition on the pump recirculator vessel located in 
the yard area. The indicated relief valve would be performing exactly as it is designed to do during 
an over-pressurization 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 Gorton's facility. 
    Ammonia Quantity:                  225 pounds 
    Rate of Release:                         16 pounds/min. (25 min. release) 
    Wind Speed:                        3.0 m/sec. 
    Distance to Endpoint:                   .1 miles 
    The following administrative and engineering controls are in place at Gorton's. 
These controls are designed to eliminate, or reduce the possibilities of an accidental release 
from the refrigeration system. 
    *  Electronic ammonia detec 
tion installed in +20 Room on second floor. Alarm system 
activates a local visual and audible alarm to alert plant personnel of the potential ammonia leak in 
the monitored area. Detection system is monitored 24 hours a day. Security company monitoring 
system will alert proper personnel in the event of a detection.  
    *  High liquid level switches are configured to pump recirculators. High level switches will 
shut down associated compressor operation during a high level condition. 
    * All compressors (Americold monitored) 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 in place within Gorton's and Americold' 
s maintenance 
department to ensure the refrigeration system and it's components are kept in optimum mechanical 
and operating status. Weekly rounds are made by plant personnel to verify proper equipment 
    *  Security personnel on premises 24 hours a day, seven days a week to monitor facility 
access as well as make rounds to detect malfunctions within the refrigeration equipment. 
4.  Five-year accident history. 
The Gorton's facility  has had zero accidental releases to report.  
5.   Emergency Action Program 
The purpose of Gorton's 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.  
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