Home Juice Company - Executive Summary |
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Ammonia, which is a standard in the refrigeration industry, provides a source of industrial cooling for our fruit-juice production facility and has minimal impact on the environment when compared to the ozone-depleting chlorofluorocarbons (i.e. Freon) that are used in other refrigeration applications. It is much more energy-efficient than other types of cooling systems and works to decrease our dependence on fossil fuels. The refrigeration is indispensable in keeping our food products fresh and sanitary. It does this, in part, by severely inhibiting the proliferation of unwelcome microorganisms. We have used anhydrous ammonia in our completely self-contained refrigeration system at our facility since it began operation. We have had three accidental releases of ammonia in the past five years. The smallest release was approximately 3 pounds and the greatest 280 pounds. During this time, we have not had an incident in which any ammonia release has resulted in serious injuries to our employees or members of the surrounding community. We presently engage an outside consultant to develop our Process Safety Management and other plant safety programs so that we can improve on this record. In addition, we use a highly-respected refrigeration company to advise us on all mechanical modification to our system. As part of our accidental release prevention policy we are presently undergoing a series of programs for upgrading and modernizing our refrigeration system. As part of these programs, we are improving our facility to minimize potential problems with our refrigeration system and help mitigate any problems that we may have. We have located our equipment in areas that are isolated from incidental contact. We are reducing the total ammonia charge to the minimum required for safe and efficient operation. We are employing documented management-of-change procedures to guide us in this process so that we proceed in a logical and safe manner. We are training our employees to be aware of the refrigeration equipment throughout plant and to be cognizant of associated safety issues. Associated with this is an upgrade of labeling of all piping and vessels to further minimize the possibility of errors. As part of our refrigeration system, a number of small reservoirs are employed to accumulate the ammonia before it is pumped to our chiller units. The level in certain of these tanks is monitored and controlled, with a mechanical float backup, to maintain a safe operating level of ammonia. Schedule 40 seamless piping is used throughout most of the system, to transport the refrigerant to the cooling units. This piping, which is rated 11 times stronger than normal operating pressure, is insulated to maintain energy efficiency and assure long operating life. As required by the Clean Air Act we have modeled the effects of "worst-case" and "alternate release" scenarios. We used EPA-supplied software to perform this modeling. The worst case sce nario that we modeled is a ten minute leak in our biggest ammonia-containing vessel. The alternative-case scenario is a 15 minute leak from an evaporator. Concerning both the worst-case and alternate case calculation we found that the buildings in which the system is housed provides passive mitigation of environmental impact. This mitigation is deriving from the effect that enclosing the ammonia-containing vessels partially contains the release. The effect of this containment is a reduction of an affected area surrounding the plant to 44% of the area calculated had there been no containment. Furthermore, expansion valves installed on the lines leading to each of the evaporators (the cooling units in each of the rooms) present an effective flow reduction should an evaporator fail. The effect of these valves reduces the calculated potentially-affected area surrounding the plant to only 2.8% of the area calculated to be potentially affected had there been no flow reduction. Our conclusion from this modeling is that there is sufficient refrigerant present in the vessels and piping of the refrigeration system for its vapor to affect the neighboring community if the vessels or piping were to lose their integrity. Because of this, we are working to maintain the highest degree of safety of our system. As an additional level of safety, we have a plant-wide alarm system to aid us in a rapid evacuation of plant personnel. We also have hand-held ammonia detection equipment to determine the actual level of ammonia and aid us in making informed decisions. Our emergency action plan has been placed into effect and our personnel trained so that all individuals are aware of their rolls in an emergency situation. Since we do not have a fully certified emergency response team on site, all responses requiring such a team are handled by the Fire Department with input from Dual-Temp Companies Inc.. In our compliance with the Emergency Planning and Community Right to K now Act, our Facility Emergency Coordinator and staff have been coordinated with the Village's Fire Department and their Hazardous Materials Response Team. Training and coordination between our operators and maintenance people and the Fire Department is planned to maintain the highest level of community safety. We are continuously analyzing and improving our system, policies and procedures by means of detailed internal audits. We are further developing a strong safety and prevention program and are committed to be an industry leader in these areas. |