Reiter Dairy, INC - Executive Summary |
|
6/8/99 RMP Reporting Center C/o Computer Based Systems, Inc. Suite 300 4600 North Fairfax Drive Arlington, VA 22203 To Whom It May Concern: RE: U.S. EPA's "Risk Management Program" Rule Reiter Dairy, Inc. / Barberton, Ohio facility Anhydrous Ammonia-Refrigeration Process Certification Letter Enclosed is a copy of the Risk Management Plan prepared electronically on disk. This has been prepared using EPA's RMP*SUBMIT. To the best of the undersigned's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete. Signature Plant Manager Printed Name 6/8/99 If you have any questions, please call at your convenience. Sincerely, Larry Brown, Plant Manager Reiter Dairy, Inc. Enclosure Certification Letter Document Prepared by Jerry Nappi, Environmental / Safety Coordinator for Reiter Dairy. EXECUTIVE SUMMARY Description of Facility and Regulated Substance Handled: Reiter Dairy, Barberton facility processes Fluid Milk and I ce Cream. The facility utilizes Anhydrous Ammonia as a refrigerant to maintain the proper temperature of Fluid Milk and Ice Cream within the facility. Anhydrous Ammonia is an effective refrigerant that has been used for many years by most food processing facilities. Ammonia is normally a gas at ambient temperatures but is handled as a gas liquefied under pressure. The refrigeration system consists of a high-pressure receiver, evaporators, compressors, piping, and valves. Accidental Release Prevention and Emergency Response Policies: Reiter Dairy, Barberton Facility is committed to promoting safety for the plant, its employees and the surrounding area. The facility is complying with OSHA's Process Safety Management Standard (PSM), Title 29 Code of Federal Regulations (CFR) 1910.119, and EPA's Risk Management Program regulations (RMP), Title 40 CFR Part 68. The purpose of these programs is to ensure that the refrigeration system is operated safely in order to prevent releases of ammonia from the system. In addition, these programs serve to develop procedures to minimize releases in the event that they do occur and to outline appropriate emergency response steps to take in the event of a release. Worst Case Release Scenario: EPA's "Risk Management Program Guidance for Ammonia Refrigeration" (November 1998) and the International Institute of Ammonia Refrigeration's (IIAR) Risk Management Guidelines (1998) were the primary documents used to develop the worst case release scenario. The worst case release is one that is unlikely to occur. The purpose of the worst case release analysis is to support a dialogue with the community on release prevention. It is a conservative analysis and is not to serve as a rational basis for actual emergency response planning. The worst case release scenario (as defined by EPA) is the release of the largest quantity of ammonia from a vessel or process line failure that results in the greatest distance to a toxic endpoint. The worst case rel ease scenario for the refrigeration process is assumed to be a case where the total quantity of ammonia in the largest vessel is released. The release scenario was performed assuming that the vessel was filled to 100% capacity (the greatest amount that would ever be placed in the vessel). The vessel, however, is normally filled to 50% capacity. There are no passive mitigation systems (dikes, berms, drains, sumps or enclosures) considered in the analysis since the vessel is located outdoors. I The toxic endpoint used for this scenario must be where the ambient concentration of ammonia is 0.14 mg/L or less. This endpoint is a concentration below which nearly all individuals could be exposed to for one hour without serious health effects. Based on Exhibit 4-4 in EPA's guidance, a release from the vessel would result in a situation where public receptors would be within the distance to the toxic endpoint. In addition, Dean Foods has installed a sophisticated system of ammonia sensors th at can remotely close certain isolation valves in the event of a small release and thereby limit an accidental release of ammonia. These sensors are capable of detecting releases of ammonia at low levels, and are connected to a computer that will shut certain valves to the system if ammonia is detected. In this way, potential releases of ammonia are minimized. Alternative Case Release Scenario: The alternative case release scenario selected is one in which an Ammonia Process Pipe acquires a leak. EPA's "Risk Management Program Guidance for Ammonia Refrigeration" (November 1998) and the International Institute of Ammonia Refrigeration's (IIAR) Risk Management Guidelines (1998) were the primary documents used to develop the alternative release scenario. The alternative release scenario is one that is more likely to occur than the worst case release scenario. 2 The alternative release scenario must meet two criteria: 1) Must be more likely to occur than the worst case scenario, and 2) Must reach an endpoint off site, unless no such criteria exist. The Alternative case release scenario (as defined by EPA) is a scenario that is more likely to occur than the worst case scenario. The Alternative case release scenario for the refrigeration process is a scenario in which an Ammonia Process Pipe forms a leak. The release scenario was performed assuming 10-minute release duration. Ammonia could be released to the atmosphere. There are no passive mitigation systems (dikes, berms, drains, sumps or enclosures) considered in the analysis, However this facility is equipped with Ammonia sensors and emergency air evacuation fans. The toxic endpoint used for this scenario must be where the ambient concentration of ammonia is 0.14 mg/L or less. Based on EPA's guidance, the alternative release scenario would result in a situation where public receptors would be within the distance to the toxic endpoint. Accidental Release Prevention Program and Chemical-Specific Prevention Ste ps: As a part of its PSM Program, Reiter Dairy, Barberton facility has established numerous programs that serve to prevent accidental releases of ammonia. These programs include: *Training *Mechanical Integrity *Management of Change *Pre-Startup Review *Contractor Safety *Process Safety Information *Process Hazard Analysis *Operating Procedures *Compliance Audits *Incident Investigations *Employee Participation *Hot Work Permits In the event of an emergency involving the ammonia system, it is the policy of the facility to request assistance as necessary by calling 330-745-2181 which will notify the Summit County LEPC, Barberton EMS (Police, Fire, and Hazmat). In addition, the Summit County LEPC has included Reiter Dairy in its local emergency response planning. Steps to Improve Safety: Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Ammonia detectors are calibrated and tested annually, All Ammonia safety relief valves are replaced and tested on the manufacturer's recommended preventative maintenance schedules. All recommendations made by the accident review committee are implemented immediately. These are some of the major steps taken to improve safety at our facility. In addition, the facility will continue to operate and maintain the system in accordance with IIAR Guidance and will continue to implement its OSHA PSM Program in conjunction with the Risk Management Program. Emergency Response Information: As a part of the PSM Program, the facility maintains an Emergency Response Plan that was prepared in order to improve responsiveness to an emergency incident, and to increase the reliability of actions taken during an incident. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations,notification of local emergency response agencies as well as the public. Five-Year Accident History: R eiter Dairy has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. |