Lender's Bagel Bakery - Mattoon Plant - Executive Summary |
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Lender's Bagel Bakery manufactures a variety of bagels at our bakery in Mattoon. We have produced bagels in Mattoon since 1986. We have a strong commitment to operate our facility in a safe and responsible manner. Ammonia is used at our facility as the cooling medium in our refrigeration systems. Similar to the function Freon plays in a home or car air conditioning system, ammonia is used to cool the air in our industrial freezers and product coolers. The ammonia is contained in a closed loop system; it is designed to remain inside the piping and vessels in our facility. We believe that ammonia provides the safest and most efficient cooling choice for our operation. A. Describe the Accident Release Prevention and Emergency Policies Lender's takes many precautions to prevent or minimize accidental releases of ammonia from the refrigeration systems. These precautions include safety controls (alarms and automatic shutdown devices) which are designed to identify and prevent p otentially unsafe conditions like pressure increases that could cause a system failure. We also have a preventive maintenance program designed to maintain the on-going integrity of the systems, a training program designed to ensure that the systems are operated by qualified personnel, and emergency response procedures which enable trained personnel to respond quickly to system upsets. The Technical Manager is responsible for the management of these ammonia safety programs. B. Stationary Source and Regulated Substances Handled Lender's Bagel Bakery produces frozen bagels for sale to the public. The facility operates two ammonia refrigeration systems, the north system and the south system. The combined ammonia inventory for both systems is approximately 80,000 pounds. Ammonia is the only substance covered by the Accidental Release Prevention Regulations handled at the Mattoon Plant. C. Summary of Worst-Case and Alternative Release Scenarios EPA requires us to define the wo rst case release scenario from the Mattoon plant as the release of 20,000 pounds of ammonia aver a 10 minute period due to the failure of the high pressure receiver in the north refrigeration system. The 20,000 pounds represents the maximum amount of ammonia that would be contained in the receiver at any time. We have written procedures in place to assure that this is so. EPA also requires us to assume that the weather conditions are such that there is almost no wind and no mixing in the atmosphere. The alternative release scenario at the Mattoon Plant would involve the release of 13,500 pounds of ammonia over a 30-minute period due to the rupture of a 1/2" high pressure liquid line in the north refrigeration system. The duration of the release was estimated for the alternative release scenario by estimating the amount of time required to stop the leak. Again, EPA required us to estimate the impacts of this release under low wind and stable weather conditions. Both of these rele ases are unlikely for many reasons. Our equipment and system were designed using industry standards for ammonia refrigeration. We have taken precautions to protect our equipment from obvious threats, like vehicular traffic. We have a preventive maintenance program to maintain the on-going integrity of the refrigeration equipment. Training programs are in place to ensure that qualified personnel operate the systems, and our emergency response procedures allow us to respond quickly in the event of an accident. D. Description of the Accidental Release Prevention Program The facility has an accident release prevention program that complies with Occupational Safety and Health Act's Process Safety Management Standard and EPA's Risk Management Program Regulation. The prevention program consists of the following elements: - Employee Participation Program - Process Safety Information - Process Hazard Analysis - Operating Procedures - Training Program - Contractor Safety Progra m - Pre-Startup Safety Review Procedures - Mechanical Integrity Program - Hot Work Permit Procedures - Management of Change Procedures - Incident Investigation Procedures - Compliance Audit Procedures E. Five-Year Accident History Three ammonia-related incidents have occurred at the Mattoon Plant during the past five years. Two of these incidents resulted in on-site injuries. The third incident resulted in the discharge of ammonia to the local wastewater treatment plant. Changes have been made at the plant to prevent the reoccurrence of these incidents. F. Description of the Emergency Response Program An emergency response program has been implemented at the Mattoon Plant. This program contains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures. The plant has an on-site employee response team, trained to enter and stop an accidental ammonia release. This team meets monthly for training and practice drills. We conducted an emergency drill with the Mattoon fire department and other local response agencies in October of 1997. G. Planned Changes to Improve Safey Lender's Bagel Bakery is committed to operating our ammonia refrigeration system in a safe and responsible manner. We are continually evaluating our equipment and procedures to meet this objective. Planned improvements include revisions to our preventive maintenance program and a modified operator training program. |