Keebler- Macon, Georgia - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

TABLE OF CONTENTS 
 
0    INTRODUCTION    0-1 
1    RELEASE PREVENTION AND EMERGENCY RESPONSE   POLICIES    1-1 
  1.1    AMMONIA PROCESS    1-1 
  1.2    PROPANE PROCESS    1-1 
2    PROCESS DESCRIPTION AND REGULATED  
   SUBSTANCES     2-1 
   2.1    AMMONIA PROCESS    2-1 
  2.2    PROPANE PROCESS    2-1 
3    WORST-CASE AND ALTERNATIVE RELEASE  
   SCENARIOS    3-1 
3.1    AMMONIA WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS    3-1 
   3.1.1  Worst-case Release Scenario    3-1 
   3.1.2  Alternative Release Scenario    3-1 
3.2    PROPANE WORST-CASE AND ALTERNATIVE RELEASE  
   SCENARIOS    3-1 
   3.2.1  Worst-case Release Scenario    3-1 
   3.2.2  Alternative Release Scenario    3-2 
4    GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS    4-1 
   4.1    AMMONIA PROCESS    4-1 
   4.2    PROPANE PROCESS    4-1 
5    FIVE-YEAR ACCIDENT HISTORY    5-1 
   5.1    AMMONIA PROCESS    5-1 
   5.2    PROPANE PROCESS    5-1 
6    EMERGENCY RESPONSE PROGRAM    6-1 
   6.1    AMMONIA PROCESS    6-1 
   6.2    PROPANE PROCESS    6-1 
7    PLANNED CHANGES TO IMPROVE SAFETY    7-1 
   7. 
1    AMMONIA PROCESS    7-1 
   7.2    PROPANE PROCESS    7-1 
 
 
 
0    INTRODUCTION 
 
This document contains all the information necessary to meet 40 CFR 68 "Risk Management Program" requirements including the executive summary and registration data elements (68.155 through 68.185).  
 
Section 1.0 describes the release prevention policies and emergency response policies at the plant.  Section 2.0 gives a brief description of the plant and of the ammonia and propane systems.  Section 3.0 defines the worst-case and alternative release scenarios for both of the regulated chemicals at the plant.  The general accidental release prevention program and chemical-specific prevention steps are described in Section 4.0.  A summary of the plant's five-year accident history is presented in Section 5.0.  Section 6.0 discusses the plant's Emergency Response Program.  Section 7.0 contains the changes to the system to improve safety for the ammonia and propane processes.  The Registration Data Elements are locate 
d in Section 8.0. 
1    RELEASE PREVENTION AND EMERGENCY RESPONSE  POLICIES 
 
The Keebler Foods Company senior management is committed to process safety and the implementation of safe operating procedures as evidenced by the Prevention Programs for ammonia and propane meeting 40 CFR 68 requirements. 
 
1.1    AMMONIA PROCESS 
 
The Macon facility complies with all applicable Federal, state and local rules and regulations to protect the health and safety of the plant's employees and surrounding community.   
 
The Macon facility has developed an Emergency Response Program (ERP).  The facility has implemented an ERP (HAZWOPER plan) which is designed to ensure the safety of its employees, the community, and the environment.  The emergency response program includes emergency response procedures, an action plan, and a list of employees who are trained to respond to a hazardous release (HAZMAT team).  To ensure the health and safety of its employees the facility has established a hazardous response train 
ing program.  The plant also requires medical surveillance of the HAZMAT team prior to and after an incident. The plant allows only mechanics that are part of the HAZMAT team and are certified operators for the ammonia system to perform maintenance on the system. 
 
The facility emergency response policies were developed to provide emergency response coverage 24 hours per day.  The plant also coordinates with the Macon Fire Department and the Local Emergency Planning Committee (LEPC) in the event of an emergency. 
 
1.2    PROPANE PROCESS 
 
This plant adheres to all applicable Federal, state, and local rules and regulations to ensure a safe working environment and safe environment for the community.  Access to the propane system is restricted to certified propane operators, authorized contractors, and the Macon Fire Department. 
 
The emergency response policies for propane include procedures for notification of the Macon Fire Department, the primary responder in the event of a propane release. 
 
 
 
2    PROCESS DESCRIPTION AND REGULATED SUBSTANCES 
 
The Keebler plant in Macon, Georgia is a producer of cookies and crackers.  The North American Industry Classification System (NAICS) code for this process is 311821.    
 
Keebler uses only one regulated substance above threshold under 40 CFR 68: propane.   Propane is used as a stand-by fuel for the baking ovens.  The plant does use ammonia in a refrigeration system but the inventory is only 3,653 pounds.  Keebler has elected to undertake RMP development for ammonia as if the plant was subject to 40 CFR 68 for ammonia at the Program 3 level.  This was done to comply with the intent of the "General Duty" clause under Section 112 r of the Clean Air Act. 
 
2.1    AMMONIA PROCESS 
 
The Macon facility has one ammonia refrigeration process for the preservation of the food products.  The main components of the ammonia refrigeration process are: a high pressure receiver, one condenser, four liquid chillers, two scrape surface heat exchangers, nine a 
ir cooling evaporators, one ice machine, four compressors, one inter-cooler, one Vaporitor, and piping.  Piping throughout the plant is labeled "ammonia". 
 
The majority of the pressurized vessels for the ammonia system are located within the plant structure in the machine room.  Access to the machine room is limited to employees who have been certified in the plant's Ammonia Operator Training Program and authorized contractors.  Visitors are not allowed in the machine room unless the individual has been HAZMAT trained or is accompanied by a certified employee. 
 
The ammonia system is continually monitored to ensure the system is operating within specified control limits. 
 
The ammonia inventory is approximately 3,653 pounds.  The process does not exceed the threshold quantity of 10,000 pounds as set by 40 CFR 68.     
 
2.2    PROPANE PROCESS 
 
The facility has one propane process to provide stand-by fuel.  The main components of the propane process are: four 30,000 gallon water capacity stora 
ge tanks, two pumps, a water-bath vaporizer, three regulators, and piping.  The piping located outside of the plant is buried to prevent contact with heavy machinery and condensation in the propane lines.  The piping to the ovens through the plant is anchored to the ceiling and labeled "propane".   
 
The propane storage tanks and pumps are surrounded by a locked chain link fence to prevent access by employees who are not trained on the use of the propane system.  The vaporizer is similarly contained within a locked fence area. A security camera monitors the propane system to ensure that unauthorized personnel do not have access to the process equipment.  
 
The propane threshold for triggering applicability under 40 CFR 68 is 10,000 pounds.  The plant administratively limits the amount of propane stored in the four storage tanks to 83% of capacity.  The maximum quantity of propane stored in each of the four storage tanks is 104,580 pounds.  The maximum amount of propane stored onsite is 4 
18,320 pounds. This exceeds the threshold limit, which results in the Macon Keebler plant being regulated under 40 CFR 68 as a Program 2 facility. 
 
3    WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS 
 
3.1    AMMONIA WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS 
 
Ammonia is classified as a Group 2 Refrigerant per ASHRAE Standard 34-1989.  The dominant characteristic of this chemical is its toxicity. Ammonia is flammable in a very narrow and high range of concentration with a high ignition temperature.  Three release scenarios are possible for an ammonia release: 1) gas, 2) gas-liquid, and 3) liquid.  
 
3.1.1    Worst-case Release Scenario  
 
The EPA definition of the worst-case release is a failure of the largest tank, causing the release of the entire contents of the tank.  The worst-case release for the ammonia system would result from a puncture in the liquid portion of the high pressure receiver located in the machine room.  The machine room is located at the south end of the plant.  The total q 
uantity of ammonia that can be stored in the high pressure receiver is 3,653 pounds.  It is assumed that all 3,653 pounds is released in 10 minutes.  Mitigation by the machine room enclosure is assumed per EPA's Risk Management Program Guidance for Ammonia Refrigeration (November, 1998).  Since this facility is located in a populated area, the toxic cloud formed by the evaporating ammonia would reach off-site endpoints and nearby public receptors. 
 
3.1.2    Alternative Release Scenario 
 
The alternative release scenario is more likely to occur than the worst-case scenario.  The alternative release scenario is an ammonia release from a < inch hole in a high pressure pipe on a pump.  The release occurs near ground level as a horizontal jet release.  There are no applicable administrative controls.  Active mitigation of the release is human intervention (the system is shut down approximately 10 minutes from the start of the release). As with the worst-case scenario, mitigation by the enclosur 
e is assumed.  Since this facility is located in a populated area, the toxic cloud formed by the evaporating ammonia would reach off-site endpoints and nearby public receptors. 
 
3.2    PROPANE WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS 
 
Propane is a flammable regulated substance capable of causing off-site consequences in the event of an accidental release.  Several release scenarios are possible including vapor cloud fires (flash fires), a pool fire with radiant heat effects, boiling liquid expanding vapor explosion (BLEVE) leading to a fireball producing intense heat, a vapor cloud explosion, and a jet fire from a hole in a tank.  
 
 
 
 
3.2.1    Worst-case Release Scenario 
 
The EPA definition of the worst-case release is a failure of the largest storage tank, causing the release of the entire contents of the tank.  The plant has four 30,000 gallon propane tanks.  The tank closest to the property line was used for the worst-case scenario since it will have the greatest impact on the surroun 
ding area.  The contents of the tank find an ignition source resulting in a vapor cloud explosion.  A ten percent yield factor is assumed from the TNT-equivalency formula.  Thus, ten percent of the released quantity will participate in a resulting explosion.  Company policy limits filling the four 30,000 gallon propane tanks to 83% of the capacity at 60oF.  The total released quantity of propane is 104,580 pounds. Since this facility is located in a populated area, the explosion would reach off-site endpoints and nearby public receptors. 
 
3.2.2    Alternative Release Scenario  
 
The alternative release scenario examined involves the release of propane during a "pull-away" during tank loading operations.  The pull-away consists of a failure of a 25 foot length of 4 inch diameter hose.  The excess flow valve stops the flow from the tank resulting in the release of the hose contents.  The hose contents, 69 pounds of propane, finds an ignition source resulting in a vapor cloud explosion. Since 
this facility is located in a populated area, the explosion would reach off-site endpoints and nearby public receptors. 
 
4    GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS 
 
4.1    AMMONIA PROCESS 
 
This facility complies with EPA's Accidental Release Prevention Rule, Occupational Safety & Health Administration's (OSHA) Process Safety Management (PSM) Standard, and all Federal, state and local codes and regulations.  The plant conducts inspections on the ammonia process to ensure the integrity of the system.  The inspections provide the ammonia process engineers with valuable information that helps to prevent the worst-case release scenario and alternative release scenario from occurring.  
 
The Macon plant has developed an OHSA PSM program for ammonia.  A process is in compliance with EPA's RMP Program 3 if it is in compliance with OSHA's PSM.  Keebler's ammonia PSM program documentation has been reviewed and determined to be complete.  
 
4.2    PROPANE PRO 
CESS 
 
This facility complies with EPA's Accidental Release Prevention Rule and with all Federal, state and local codes and regulations.  The system was originally designed and constructed in 1953.  The system was modified in 1972 to increase flow capacity and in 1985 when the vaporizer was replaced.  The original system and later modifications were designed in accordance with the NFPA-58 code. The plant conducts inspections during operation of the propane system to ensure the system is intact and operating correctly. An outside propane contractor conducts an annual inspection of the propane system.  During these inspections the contractor notifies the plant of any deviations from the NFPA code and the plant corrects these deviations prior to the next inspection. The plant inspections during propane system operations in conjunction with the contractor's annual inspections and upgrades ensure that the worst-case and alternative scenarios have a minimal chance of occurring. 
 
The plant has 
developed a prevention program for propane to meet the Program 2 requirements of the RMP rule.  The prevention program was written to be in compliance with 40 CFR 68, to ensure the safety of the employees, and to ensure the safety of the surrounding community. Keebler developed a training program for the propane system personnel.  The program discusses: (1) the potential hazards associated with propane, (2) the proper operating and maintenance procedures for the propane system, and (3) certification of employees for operation of the propane system.  The plant also uses vendors who are NFPA-58 compliant. 
 
5    FIVE-YEAR ACCIDENT HISTORY 
 
5.1 AMMONIA PROCESS 
 
The review of this facility's accident history for ammonia includes the following range of dates: June 22, 1994 - June 21, 1999.  The plant has had one ammonia release during the five-year accident history review.  The accident occurred on February 28, 1997.  Approximately 300 pounds of ammonia was released.  The plant developed a mo 
re stringent work policy to ensure the health and safety of the employees.  The plant has incorporated these policies into their Program 3 documentation, maintenance procedures, and operating procedures.   
 
5.2    PROPANE PROCESS 
 
The review of this facility's accident history for propane includes the following range of dates: June 22, 1994 - June 21, 1999.  There have been no propane releases at this facility as defined in 40 CFR Part 68.42(a). 
6    EMERGENCY RESPONSE PROGRAM 
 
6.1    AMMONIA PROCESS 
 
The Keebler facility has developed a hazardous substance emergency response program under the OSHA HAZWOPER Standard. The HAZWOPER document contains detailed procedures for: pre-emergency planning and coordination; personnel roles and lines of authority; training; communication; emergency recognition and prevention; safe distances and places of refuge; site security and control; emergency alerting and response; ammonia decontamination; emergency medical treatment and first aid; critique of respon 
se and follow-up; personal protective and emergency equipment; and medical surveillance. 
 
Keebler's emergency response plan is a detailed document, which discusses the role of employees and management in an emergency situation.  All emergency response personnel undergo training and records of this training are maintained and updated on site.  The plan outlines specific procedures for evacuations, incident alarms and alerting.  Depending on the emergency situation, the Macon Fire Department will be contacted to provide back-up emergency responders and equipment.  The fire department is notified by calling 911. 
 
6.2    PROPANE PROCESS     
 
The Macon plant does not have an internal emergency response team to address a propane release.  The Macon Fire Department is notified in the event of an emergency by calling 911. 
 
The Macon plant has developed an emergency evacuation document.  The purpose of the document is to provide an orderly, effective plan of action for protecting employees in emergen 
cy situations when an evacuation is necessary. 
 
7    PLANNED CHANGES TO IMPROVE SAFETY 
 
A Process Hazard Analysis (PHA) was conducted for the ammonia system and a Hazard Review (HR) was conducted for the propane system to outline the hazards associated with each process.  A "what-if/checklist" was completed for both the PHA and the HR.  Each "what-if/checklist" contains a list of action items to be accomplished to help improve safety at the facility.  The following examples briefly describe current improved safety measures occurring at the Macon plant. 
 
7.1    AMMONIA PROCESS 
 
1.      The plant relocated the emergency exhaust fan and ammonia compressor controls to a location outside the machine room and near an outside door.  This will allow emergency response personnel to control the environment in the machine room without actually entering the machine room. 
 
2.      The plant is considering the replacement of all of the relief valves as part of an inspection program.  This will establish a benc 
hmark for future mechanical integrity audits. 
 
3.      The plant is establishing a uniform, documented training program for maintenance personnel. 
 
4.    The plant will pipe the discharges of the relief valves on the compressors to the outside of the building. 
 
5.      The plant maintenance department will expand the number of written SOP's to cover maintenance, operation and emergency response procedures. 
 
6.      The plant maintenance will document the existing preventative maintenance and  inspection program.  Although a regular inspection are currently conducted there is no ongoing record of each inspection. The new program will provide a check list and sign-off sheet for the inspections. 
 
7.      The plant is currently reprogramming the restart procedure for the compressors and pumps following a power outage.  The current practice requires a timely manual intervention in the restart to avoid equipment damage.  
 
 
7.2    PROPANE PROCESS 
 
1.    As a safety precaution the Macon plant will use only NFPA-5 
8 knowledgeable vendors to supply and fill the propane tank.  
 
2.    The possibility of a propane release caused by untrained personnel operating the propane system is a concern at the Macon plant.  To address this concern the facility has initiated a training program for all personnel responsible for the operation of the propane system.  Personnel who are not responsible for the operation of the system will not be allowed to perform any tasks related to the propane system.  
 
3. The Macon plant has installed fences surrounding the facility to prevent the general public from access to the tank.   
 
4. The plant buried the propane process lines to protect the propane system from punctures and or damages caused by heavy machinery.  
 
5.    The Macon plant has contracted the maintenance checks and inspections to a propane system design contractor.  The contractor is responsible for bringing the system up to present code.
Click to return to beginning