The Dannon Company, Inc. - Executive Summary

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    The Dannon Company is proud to inform all interested parties that our company is complying with OSHA's Process Safety Management Standard (PSM), Title 29 Code of Federal Regulations 1910.119, and EPA's Risk Management Program regulations (RMP), Title 40 CFR Part 68. In addition to other state and local codes applicable to our facility and process. We have undertaken this process to deal with the risks involved with the storage, handling, and use of Anhydrous Ammonia in our facility. 
    Our goal is to promote overall worker, public, and plant safety. The Dannon Company facility is located at 216 Southgate Drive, Minster, Ohio. We manufacture some of the finest cultured dairy products (yogurt) in the world. The facility covers approximately 300,000 square feet and includes processing tanks, piping, packaging equipment, raw materials warehousing, finished goods refrigerated storage, an Ammonia refrigeration engine room, boilers, and miscellaneous utilities. Also located at the fac 
ility are a raw milk processing plant, shipping and receiving docks, and a waste water treatment plant. The facility produces and ships approximately 360 million pounds of finished product each year.  The refrigeration system required for our production process necessitates the submission of this Risk Management Plan. The refrigeration system contains in excess of 35,000 pounds of anhydrous ammonia. This surpasses the threshold quantity of 10,000 pounds outlined in Process 
Safety Management and Risk Management Program regulations. 
    The Dannon Company has implemented numerous policies and procedures to enable our facility to prevent the occurrence, and minimize the consequences of significant releases of Anhydrous Ammonia as well as other hazardous substances, fires, explosions, and other types of catastrophic accidents. Overall these programs prevent accidental fatalities, injuries, and illnesses and avoid property damage.  Our safety programs prevent accidents because they focus o 
n the rules, procedures, and practices, which govern individual processes, activities, or pieces of equipment. These rules are detailed and improved as necessary. They are also communicated to and accepted by all employees at our facility. 
    The Dannon Company has organized the information and polices pertaining to the process into a complete library. This library also incorporates the use of videos and computerized tests. 
    Volume 1 of the PSM/RMP Library incorporates several policies. Many policies are included in Volume 1, the remaining are referenced from other training manuals maintained in the facility. 
    A policies included in volume 1 is a Plan of Employee 
Participation. This policy outlines the commitment between management and employees to establish a program for a successful (safe) program. 
    The Written Process Safety information includes information on the ammonia inventory at the facility, applicable codes, design standards, and information pertaining to the h 
azards of ammonia (referenced from the IIAR ammonia Data Book). 
    A Policy for Opening the Ammonia Refrigeration System has been included. It incorporates procedures for working on the ammonia refrigeration system in the few areas not covered by a standard operating procedure (new equipment tie-ins, isolation and removal of existing equipment, evacuation and abandonment of refrigeration mains, etc.) 
    The Support Personnel Entry policy establishes a program that 
covers the entrance and exit of the facility by employees, management, contractors, and visitors. 
    An extensive Contractor Qualification Program has been established to verify that the contractors working in the facility are qualified to work on the system, trained in the hazards associated with their work, and made aware of the hazards presented by the facility to the employees of the contractor. 
    A Management of Change and Pre-Startup Safety review program has been developed to monitor and provide a "checks and  
balances" system to monitor changes in the facility and to verify that changes are safe and consistent with company policy. 
    Procedures for conducting Compliance Audits, Mechanical Integrity Inspections, and Process Hazard Analyses have also been developed. 
    Many more specific programs and policies (Hot Work, Confined Space, Lockout / Tagout, etc.) have been developed. For information specific to these see the Site Safety Coach. 
    Volume 2 incorporates information on the specific system components (Pumps, vessels, compressors, evaporators, evaporative condensers, purgers, piping systems, heat exchangers, the emergency ventilation system, and general safety). This information is used as a reference source for the operator to positively identify system components. This manual also provides a checklist for performing the yearly Mechanical Integrity Inspection. 
    Volume 3 incorporates a complete valve list. The valve list 
contains information on the type, port size, identifyi 
ng number, use, location, model, manufacturer, drawing reference, and normal operating position of each valve in the system. 
    Also included in volume 3 is the Process and Instrumentation 
Diagrams for the individual system components. Flow schematics are included showing the entire system. A Block flow diagram provides a brief overview of the system. Drawings are included showing symbol and abbreviation descriptions. Plan views are included to allow the operator to physically locate equipment in the building. 
    Volume 4 incorporates a complete set of standard operating procedures, describing the proper steps for preparing components for start-up, starting components, monitoring normal operation of system components, shutting down components as part of normal operation, restarting equipment as part of normal operation, shutting down equipment for maintenance, restarting equipment after maintenance, shutting down equipment in emergency situations, restarting equipment after an emer 
gency situations shutdown, and pumpout procedures. Also included as a part of each Standard Operating Procedure is the Technical Operating Specifications for the associate system component. This information includes consequences of deviation from standard operating procedures. 
    Volume 5 contains Operation and Maintenance Information including manufactures information, spare parts list, maintenance procedures, and preventive maintenance procedures. 
    A Process Hazard Analysis was performed in 1997, which highlighted some deficiencies in the system. These items were addressed as part of the continuous improvement of the facility. These items were addressed on the basis of priority (Injuries to personnel). Items of a low priority (Process improvements) were budgeted for completion in 1998 and 1999. 
    The Dannon Company also incorporates additional safety items such as tagging of all ammonia system valves and components, a PC / PLC based control system with a graphical operator i 
nterface.      The ammonia refrigeration system at The Dannon Company actually consists of two systems, which are standard compression and evaporation style systems.  These systems are linked together via crossover valves, which are kept closed at all times.  
System 1 
    Ammonia vapor from Pump Recirculators, Accumulator, and Surge Drum is routed to the High Stage Compressors.  Vapor from the Economizer suction vessels is used to feed gas to the High Stage Compressors' Economizer ports.  If the pressure of this gas should rise to 135#, the gas would be diverted through a regulator to a Pump Recirculator.  The High Stage Compressors compress the vapor.  The compressed vapor is then fed to the Evaporative Condensers.  Compressed Vapor is also fed to the cooler evaporators for hot gas defrost. 
    At the Evaporative Condensers, heat is removed from the compressed vapor converting it to high pressure liquid.  The high pressure liquid is then collected in the high pressure receiver. 
High pressure liquid is fed from the high pressure receiver to the sub-cooling coil in an Economiser Vessel.  High pressure liquid is also fed to this vessel as liquid make-up. As the liquid is fed through the cooling coil, it becomes colder than it normally would at that pressure.  The high pressure, sub-cooled liquid is then fed to another Economizer vessel and another sub-cooling coil to reduce liquid temperature even more.  The high pressure sub-cooled liquid is then fed to the Pump Recirculators as liquid make-up.  This maintains the liquid level in these vessels.  High pressure liquid is also fed to a common high pressure liquid header which feeds Ice Builder #1, the Chester Jensen Wing chiller, Hansen Auto-Purger, Batching Evaporator, and New Process Evaporator.   
    High Pressure sub-cooled liquid is fed to the Auto-Purger as is purge gas from purge points at the Evaporative Condensers.  Any non-condensables in the vapor streams are removed periodically by the Auto-Purger.   
The Purger separates ammonia from the non-condensables by condensing the ammonia.  Any non-condensables are piped to the water bubbler to remove any trace quantities of ammonia.  Condensed Vapor from the Purger is then transferred to the Pump Recirculator. 
    High pressure liquid is also fed to the Chester Jensen Wing Chiller by way of a surge drum.  At the Wing Chiller ammonia flows through plates where it absorbs heat from water which is cascading over the outside of the plates.  The ammonia will absorb heat, changing from a liquid to a liquid/vapor.  The liquid/vapor is returned to the surge drum where it is separated.  The liquid is returned to the Wing Chiller and the vapor is returned to the High Stage Compressors.  
    High pressure sub-cooled liquid is fed to Ice Builders #1, #2, #3, and #4 where it is circulated through coils while water floods the outside of the coils.  The ammonia absorbs heat, changing from a liquid to a liquid/vapor combination.  As heat is absorbed fro 
m the water, ice is formed.  The ice continues to collect until the Ice Thickness Control stops the process or the ice is harvested.  The liquid/vapor from the Ice Builders is discharged to an accumulator.  The vapor is separated and fed to the High Stage Compressor and the liquid is returned to a Receiver.  The Receiver serves as a storage vessel for the system.   
    High pressure sub-cooled liquid is also fed to evaporators in Processing, Batching, the Northwest Cooler, Process Area, Milk Receiving, New and Old Coolers and the East Fruit Room.  In these Evaporators the liquid flows through coils where it absorbs heat from the air, changing from a liquid to a liquid/vapor.  High temperature recirculated suction from these units is returned to the pump recirculator.  
    The system contains an ammonia recharging system which is used for the charging of ammonia into the refrigeration system.  The recharging system consists of a liquid header which is piped from outside the engine roo 
m to the High Pressure Liquid return header from the transfer system. 
    The system also contains several oil pots which are used to remove excess oil from the system and an oil supply system which provides a constant supply of oil to the compressors.  An operator is required to perform charging operations. 
System 2 
     System 2 is similar in operation to System 1.  Most differences lie in the areas and equipment being cooled.   
     Ammonia vapor from the Pump Recirculator is routed to the High Stage Compressors where it is compressed and then fed to the Evaporative Condensers.  At the Evaporative Condensers heat is removed from the compressed vapor converting it to high pressure liquid.  The high pressure liquid is then passed to the Thermosyphon vessel.  Liquid ammonia is gravity fed from this vessel to the thermosyphon oil coolers on the high stage compressors.  At the oil coolers the ammonia liquid is circulated through tubes while oil from the compressor is cascaded over the 
tubes.  The ammonia absorbs heat which is rejected by the oil.  As the ammonia absorbs heat it changes from its liquid state to a liquid/vapor mixture.  The mixture returns to the thermosyphon vessel where it separates.  The vapor passes through the equalizer line to the top of the evaporative condensers where it condenses.  The liquid is recirculated back to the oil coolers.  The thermosyphon vessel is equipped with a gravity drain stand pipe that allows ammonia liquid to gravity drain to the high pressure receiver once the thermosyphon vessel has accumulated liquid to the stand pipe. 
    The High Pressure Receiver serves as a storage vessel for liquid in the system.  High pressure liquid is fed from the High Pressure Receiver to the Hansen Auto where non-condensibles are separated from the ammonia as in System 1.   
    System #2 services the Northwest Cooler, Cooling Tunnels 1,2,3, and 4,and the Cooling Cell.  Liquid ammonia flows through the coils in the evaporators at each of th 
ese areas where it absorbs heat from the air, changes from liquid to liquid/vapor mixture and is returned to the pump recirculator. 
    System #2 also contains an ammonia charging system for adding ammonia to the system and an oil pot to remove excess oil from the system.  Additionally, this system contains and emergency dump station located directly outside the engine room.  The station is composed of several headers linking together the Thermosyphon Vessel, High Pressure Receiver, and Pump Recirculator via normally closed cross-over valves.  In an emergency these valves may be opened to equalize pressures or dump the charge to the atmosphere. 
    Dannon has determined that the worst case release scenario would be the sudden and complete release of the ammonia contained in one of the High Pressure Receivers and its associated Evaporative Condenser.  This would release 7200 pounds of ammonia into the atmosphere.  The area of concern if this were to happen is a one mile radius around  
the facility.  RMP Comp software was used to determine the area of concern.  Total population within the area of concern is calculated to be approximately 527 with one school and a portion of a State Park within the radius.  Prevailing winds at the site would most likely leave the school and Park unaffected by a release and greatly reduce the number of people affected. 
    There are two likely causes which would predicate the Worst Case Scenario.  The first is that the equipment would experience external corrosion.  The corroded equipment weakens and leaks/ruptures, resulting in an ammonia release.  To prevent such and occurrence, a Preventive Maintenance Program is in place along with regular Mechanical Integrity Inspections.  The second cause would be if the vessel were impacted by a vehicle, causing a rupture and resulting in an ammonia release.  To prevent such an occurrence, Engineering/Administrative Controls in place include forklift training, a King Solenoid Valve, contractor  
qualifications, and warning signs. 
    A more likely release event would be caused by the failure of a sealing component such as packing, O-rings, gaskets, mechanical seals, etc. This type of failure is estimated to release approximately 250 lbs. of ammonia over a period of twenty minutes.  Based on RMP Comp calculations, ammonia would reach an endpoint 0.10 miles from the engine room.  The population affected by such an event is estimated to be two with no public receptors within the radius of concern.  To minimize the possibility of this occurrence a Preventive Maintenance Program and schedule of Daily Rounds has been implemented. 
    We have had three accidental releases of anhydrous ammonia which were large enough to be reportable.  The three releases were of 2,000 pounds, 1,000 pounds, and 250 pounds.  No off-site impacts were reported, no injuries occurred off-site, and no evacuations were necessary.  After each incident, an investigation took place and recommendations were mad 
e and implemented to minimize future incidents. 
    The Dannon Company has an Emergency Response Plan to establish procedures and guidelines to provide prompt and orderly response to emergencies involving the release of hazardous materials to prevent or minimize the potential health or environmental effects caused by such a release. 
    The Plan establishes lines of authority for conducting safe response operations, personnel roles and training, and communication procedures.  All employees, including business area coaches and managers are expected to comply with the plan in order to assure its effectiveness. 
    The plan provides guidelines for determining emergency recognition, proper levels of response, emergency communication, selection of response personnel, security and control, decontamination, emergency equipment and personal protective equipment.   
    The Emergency Response Team is made up of personnel selected from the Maintenance Staff.  Personnel selected must complete  
the required OSHA 24 hour HAZWOPER training.  Incident Commanders receive an additional 8 hours of Incident Command Training.  All team members must receive an annual 8 hour refresher training to remain on the team.  Additional training includes monthly meetings, quarterly training sessions and an annual training session in coordination with the Minster Fire Department and Life Squad. 
    A communication chain of command has been established to assure prompt and efficient response to any hazardous material spill or leak and effective coordination with the Minster-Jackson Township Fire Department.  The Fire Department will then notify the Auglaize County and/or Shelby County HAZMAT Team as necessary and the Auglaize County Emergency Management Agency if it appears neighbors and/or the environment will be affected by an incident. 
    The Dannon Company is committed to continuos improvement of our policies, procedures, and facility. It is the intention of The Dannon Company to remain an 
industry leader. New technology, training techniques, and equipment are continuously being added to our system. 
    Among the improvements slated for completion in 1999 is an 
extensive operator training program, policy updates, additional emergency responder training, the addition of more safety equipment, cross training of maintenance and utility personnel, modifications to the ammonia detection system, and a complete Mechanical Integrity Inspection.
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