Basic American Foods (Blackfoot) - Executive Summary |
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EXECUTIVE SUMMARY Facility Overview: The Basic American Foods (BAF) facility in Blackfoot, Idaho is a potato processing operation primarily providing food service and consumer packaged products. The facility is regulated under Part 68 of the Clean Air Act Amendments, also referred to as the Risk Management Program (RMP), due to onsite chlorine storage in excess of the 2,500-pound RMP applicability threshold in a process. The facility's RMP covered process is a process water treatment system that uses chlorine gas at the site. The stationary source covered process consists of 8 to 10 one ton cylinders with each vessel storing a maximum of 2,000 pounds. Chemical Safety Overview: The facility's overall approach and commitment to chemical safety is demonstrated by 1) the existing management, training, operating procedures, and maintenance systems in place at the facility, and 2) the hazard assessment, prevention program, and emergency response provisions implemented specifically for chlorine in response to the RMP requirements. The management structure and oversight to ensure safety is documented in the facility's RMP and includes compliance with applicable regulations, codes, and standards (US EPA 40 CFR 68, US OSHA 29 CFR 1910.119). Release Scenarios: Worst-case and alternative release scenario assessments were conducted for the facility's single largest vessel based on US EPA's Offsite Consequences Analysis guidance. The release scenario was considered for both releases and public receptors were determined to be located within the impact zone of the worst-case. The resulting worst-case and alternative release impact zones were 3 miles and 0.20 miles, respectively. Chlorine Institute guidance is followed at the facility to minimize the potential quantity released in an accident. Five-year Accident History: The facility has had no RMP-reportable accidents/releases of chlorine within the five years preceding RMP submittal. Prevention Program: The facility h as implemented a Program 3 level Prevention Program, as required by the RMP rules, in accordance with US EPA, OSHA Process Safety Management (PSM), and vendor guidance for chlorine. These prevention program provisions are specifically intended to minimize the probability and/or consequences of accidental chlorine releases from the facility and include such measures as a system hazard review, operating and maintenance procedures, training, compliance auditing, management system, and updates. The facility prevention program is an ongoing system based on periodic training, incident investigations, audits, procedure revisions, and RMP updates as required to reflect facility change and RMP requirements. Emergency Response Program: The facility has coordinated response with the Blackfoot Fire Department to ensure that they will respond to any accidental release from the chorine system. The facility has also established a notification mechanism to ensure the Fire Department will be prop erly notified when response is required for a chlorine release. Based on this coordination with the local emergency responders, the facility is not required to implement additional RMP emergency response program requirements. Safety Management and Changes: The facility is committed to ensuring its operations are safe and in accordance with all RMP requirements, and has established a senior manager responsible for RMP development, implementation, and compliance. This manager is committed to maintain the safety of the RMP-covered chlorine system through active adherence to the appropriate procedures and codes. To ensure that the appropriate changes occur as necessary to maintain and improve safety, ongoing hazard reviews, training, audits, maintenance and investigations will be conducted as required by the RMP. Updates to the RMP will be completed as necessary in response to these activities. Summary: As documented in this submittal, the RMP for the facility has been completed in accordance with all 40 CFR 68 requirements and the facility has certified RMP compliance. |