Maplehurst Bakeries, Inc - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Maplehurst Bakeries, Carrollton, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: * A description of our facility and use of substances regulated by EPA's RMP regulation * A summary of results from our assessment of the potential offsite consequences from accidental chemical releases * An overview of our accidental release prevention programs * A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule * An overview of our emergency respon se program * An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment * The certifications that EPA's RMP rule requires us to provide * The detailed information (called data elements) about our risk management program Our Risk Management Program mirrors our facility's Process Safety Management (PSM) Program prepared in compliance with 29 CFR 1910.119. Where appropriate, the facility's PSM program is referenced to meet RMP compliance criteria. The two programs function together. STATIONARY SOURCE AND REGULATED SUBSTANCES Our manufacturing facility is a bakery which produces various baked goods including cakes, cupcakes, brownies, and jelly rolls. These baked goods are frozen prior to shipment from the facility. We use using a anhydrous ammonia as the refrigerant in our warehouse refrigeration system and propane as a supplemental fuel for heating our ovens and boiler. EPA has identified anhydrous ammonia and propane as chemicals having the potential to cause significant offsite consequences in the event of a substantial accidental release: Toxics At Maplehurst Bakeries in Carrollton, we use anhydrous ammonia as a refrigerant. The refrigeration system includes: a high pressure receiver vessel, a thermosyphon receiver, compressors, associated piping, valves, pumps, recirculators, condensers, heat exchangers, purgers, a subcooler, and freezers. Flammables We use propane as an auxiliary fuel source in case natural gas supplies are curtailed. Liquid propane is piped to a vaporizer prior to entering the facility's gas system. Gas is used as a fuel to heat water and the baking ovens. Because the propane storage vessel is within 100 yards of the ammonia receiver, a propane release and subsequent vapor cloud explosion could impact the ammonia receiver and nearby refrigeration system components. Our accidental release prevention p rograms and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario(s) - Regulated Toxic Chemicals The anhydrous ammonia falls under Program 3 requirements. Failure of our largest ammonia vessel would be the worst case scenario for our facility. Approximately 12,700 pounds of anhydrous ammonia, released over a 10-minute period, could impact population up to 1.8 miles from our site (toxic endpoint: 0.14 mg/l, 200 ppm). This assumes a neutrally buoyant plume and uses the EP OCA default lookup table for this scenario. Based on the 1990 US Census and LandView III software from the US Bureau of the Census, approximately 1,900 people live within 1.8 miles of our facility. Within that distance are residences, businesses and business parking lots, schools, recreation areas, and churches. Alternative Release Scenario(s) - Regulated Toxic Chemicals The alternative release scenario for our facility is based on a more likely event than the worst case scenario above. We have assumed a relief valve opens (lifts) and the release goes undetected for 10 minutes before employees manually isolate the problem. The potential release results in a distance to toxic endpoint (200 ppm) at 0.19 miles (1,000 feet). There are approximately 20 people living within that distance of our facility according to the 1990 US Census and LandView III software from the US Bureau of the Census, businesses, and business parking areas. Worst-case Release Scenario(s) - Regulated Fl ammable Chemicals The propane process falls under Program 2 requirements. The "worst case" failure of our propane storage vessel would release approximately 111,000 pounds of propane in 10 minutes. Company policy limits filling the 30,000 gallon tank to 88% of capacity in accordance with National Propane Gas Association guidance. Assuming the propane finds a source of ignition, the resulting vapor cloud explosion (VCE) could impact an area up to approximately 0.40 miles (2,050 feet) from the vessel. Defined as 1 psi overpressure, this limit would be characterized by broken windows. We used the EPA OCA guidance lookup tables for this determination. The propane vessel is about 100 yards from our ammonia receiver (see above) and a VCE could disrupt the receiver and nearby refrigeration piping and equipment and lead to a major ammonia release comparable to the worst case ammonia release above. According to the 1990 US Census data in LandView III, approximately 100 people live withi n 0.40 miles of the site. There are residences, businesses and business parking within this distance. Alternative Release Scenario(s) - Regulated Flammable Chemicals We developed an alternative case release scenario and used the EPA OCA lookup tables to determine a distance to 1 psi overpressure endpoint (broken glass windows). This scenario involved a pipe rupture on the discharge of a pump during loading. The results yielded a loss of about 5,000 pounds of propane over an 8-minute period. The resulting vapor cloud reached a source of ignition and exploded. We used 1990 US Census data from LandView III databases for population to estimate approximately 10 people live within this 0.10 mile distance to endpoint. There are residences and businesses within this distance. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: * Process safety information * Process hazard analysis * Operating procedures * Training * Mechanical integrity * Management of change * Pre-startup review * Compliance audits * Incident investigation * Employee participation * Hot work permit * Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: Key steps for preventing accidental chemical releases include: employee participation and training, preventive maintenance, equipment operating procedures, and daily inspections. These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these managemen t systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. FIVE-YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occur at our facility. Within the last five years, we have not had an accident involving ammonia or propane that caused deaths, injuries, property, or environmental damage, evacuations or shelterings in place. EMERGENCY RESPONSE PROGRAM We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan. In the event of an emergency involving our ammonia or propane systems, it is our polic y to notify the Carrollton Fire Department and request that they respond to the emergency. We have discussed this policy with the fire department and members of the fire department have been asked to inspect our ammonia and propane systems. PLANNED CHANGES TO IMPROVE SAFETY We have no plans at the present time to change our safety processes and procedures. CERTIFICATIONS Based on the criteria in 40 CFR 68.10, the distance to the specified endpoint for the worst-case accidental release scenario for the following processes reach public receptors: a. Anhydrous Ammonia -- refrigeration b. Propane -- auxiliary fuel Within the past five years, the processes have had no accidental releases that caused offsite impacts provided in the RMP rule (40 CFR 68.10(b)(1)). In the event of fire, explosion, or a release of a regulated substance from the processes, entry within the distance to the specified endpoints may pose a danger to public emergency responders. Therefore, public emerge ncy responders should not enter this area except as arranged with the emergency contact indicated in the RMPlan. For the covered processes, to the best of the undersigned's knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate, and complete. Thomas Nummerdor Plant Manager RMP DATA ELEMENTS The following pages present additional information about our risk management program that EPA's RMP rule has asked us to provide. This information is categorized as follows: * Registration * Offsite consequence analysis * Five-year accident history * Program 2 prevention program * Program 3 prevention program * Emergency response program |