Kettle Cooked Foods - Executive Summary |
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EXECUTIVE SUMMARY Accident Release Prevention Program and Emergency Response Policy It is the policy of the Kettle Cooked Foods Company (Kettle Cooked Foods) facility management to implement the requirements of this Risk Management Program (RMP) in accordance with the USEPA regulations under 40 CFR Part 68 and with the corresponding regulations under OSHA's Process Safety Management (PSM) program. The objective is to minimize the risk of a release of a hazardous material and if a release occurs, to minimize the potential impact to Kettle Cooked Foods' employees, the public and the environment. This objective will be accomplished by utilizing general good operating procedures, providing appropriate training to all employees, and coordinating response activities, as necessary, with the local emergency response providers. Kettle Cooked Foods' management is committed to providing the resources necessary to implement this policy. Facility Description Kettle Cooked Foods operates a food pro cessing operation in Fort Worth, Texas (see Figure 1-1). Kettle Cooked Foods primarily produces and packages custom soups, sauces and side dishes for easy-to-use boil-in-bag preparation at this facility. Specific products include alfredo sauce, chicken potpie filling, spinach queso dip and broccoli cheese soup. Operations at the facility include ovens, grinding rooms, cooking areas, freezer rooms and a number of coolers and chillers. One chemical, ammonia, is utilized at the facility in sufficient quantities to be subject to the requirements of 40 CFR Part 68. Ammonia is used as a refrigerant throughout the facility. Worst-Case and Alternative-Case Release Scenarios RMP regulations require that each facility complete worst-case and alternative-case release scenarios. USEPA has defined a worst-case toxic release as the release of the entire contents of the largest vessel that contains a regulated substance in a 10-minute period. This release rate is then evaluated using modeling techn iques and/or reference tables to define the distance to a specified endpoint (concentration or overpressure). The distance to the endpoint is affected by several factors including molecular weight, volatility, heat of combustion, and physical setting (urban or rural). The alternative-case release scenario for each covered process must be one that is more likely to occur than the worst-case scenario and that reaches an endpoint offsite, unless no such scenario exists. The alternative-case release scenario is evaluated using the same techniques as the worst-case release scenario to define the distance to the specified endpoint. Under 40 CFR 68 Subpart B '68.22(e), the RMP rule identifies surface roughness as a parameter to be used in the hazard assessment to determine the physical setting of the site, urban or rural. "Urban means there are many obstacles in the immediate area; obstacles include buildings or trees. Rural means there are no buildings in the immediate area and the terrain is generally flat and unobstructed." Due to the presence of trees, hills, and/or other structures in the immediate vicinity of the Fort Worth, Texas facility, an urban dispersion environmental was assumed. Ammonia The data provided in the document "Model Risk Management Program and Plan for Ammonia Refrigeration" (May 1996) was used to estimate the toxic endpoint distance for the worst-case and alternative ammonia-case release scenarios. The EPA's "RMP Off-site Consequence Analysis Guidance" (May 1996) was not used to determine the toxic endpoint since it classifies ammonia as a "neutrally buoyant gas." The worst-case ammonia release scenario would involve liquid and would come from a pressurized liquid system; therefore, the released gas should be classified as a "dense gas" (a result of evaporative cooling). The ammonia refrigeration document provides calculated endpoint distances for typical meteorological conditions. The worst-case release scenario for an anhydrous ammonia release is a release of all the contents of the high-pressure receiver tank in a 10-minute period (per EPA guidelines). This release translates to a release of 14,315 pounds of ammonia in 10 minutes or 1,431.5 lbs/min. Other assumptions included in the worst-case assessment are: the ammonia is a liquefied gas; the receiver is not diked; the nearfield dispersion environment is characterized as urban; 10-minute averaging period; the wind speed is 1.5 meters/sec and the atmospheric stability is classified as F (stable). The results of the worst-case scenario for an ammonia release shows that the plume must travel 1.39 miles (2.25 kilometers) before dispersing to the endpoint concentration of 200 ppm. Figure 1-2 details the ammonia worst-case release zone. The selected alternative-case release scenario for the ammonia system is a release from an ammonia relief valve due to overpressurizing a 3/4-inch line, which is under a 250 psig pressure. The largest relief valve has a relief rate of 59.3 poun ds of air per minute. As a matter of convention, the specified release rate of any relief valve is always in pounds of air per minute. The release rate of 59.3 pounds of air per minute correlates into a release rate of 42.5 pounds of ammonia vapor per minute. This release rate was applied to a release from the relief valve. The ammonia refrigeration document provides calculated endpoint distances for typical meteorological conditions (3 m/s wind speed, D atmospheric stability, 50% relative humidity). Based on the release rate of 42.5 lbs/min, the duration for a 425-pound release is 10 minutes. Other assumptions include, no passive mitigation measures are currently in place and an urban dispersion environment in the nearfield. The results of the alternative-case release scenario for an ammonia release indicates that the endpoint concentration of 200 ppm is reached at 0.06 mile (96 meters) from the release point. Figure 1-3 details the ammonia alternative-case release zone. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The Fort Worth, Texas facility is governed by a set of OSHA and USEPA regulations that require planning and facility activities intended to prevent a release of hazardous material, or if a release inadvertently occurs, to minimize the consequences of a release to the employees of the facility, the public and to the environment. These regulations include: * 40 CFR Part 68, Accidental Release Prevention * 40 CFR Part 112, Spill Prevention, Control and Countermeasure * 40 CFR Part 122, National Pollution Discharge Elimination System * 40 CFR Part 264, Hazardous Waste Contingency Plan * 29 CFR Part 119, Process Safety Management The key concepts in Kettle Cooked Foods' release prevention program are employee participation, appropriate design and maintenance of equipment, and appropriate training of all employees. Employee participation in the release prevention program is encouraged and supported by Kettle Cooked Foods' management. Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the ammonia system. Kettle Cooked Foods' employees are also members of the facility emergency response team. Kettle Cooked Foods has an Emergency Response Plan in place and has sufficient equipment on site to respond to most ammonia releases. Kettle Cooked Foods' policy is to construct all new equipment, systems, and facilities to ensure the appropriate safety and release prevention systems are included from the beginning of each project. Kettle Cooked Foods maintains a computerized program of maintenance activities to ensure that key systems are maintained appropriately to minimize the risk of a release. Kettle Cooked Foods is committed to providing appropriate training to all employees regarding safety procedures. Each new employee is provided comprehensive safety training during his or her initial orientation for the facility. In addition, Kettl e Cooked Foods conducts regularly scheduled safety training for all employees each year. Additional training is provided to maintenance personnel for the systems they are responsible for. Members of Kettle Cooked Food's emergency response team receive annual training to ensure that response actions are promptly and safely completed. Five Year Accident History Kettle Cooked Foods had one release of ammonia from the Fort Worth, Texas facility within the last five years. The incident occurred on September 5, 1998, for a 10-minute duration. Approximately 500 pounds of ammonia were released due to a valve failure on the roof of the facility. Off-site responders were notified of the incident. There were no on-site or known off-site impacts that affected the public or the environment due to this release. Emergency Response Program Kettle Cooked Foods has personnel trained in emergency response at the facility 24 hours per day, seven days per week. These personnel receive annual training on emergency procedures and response techniques that include mock spills and staged exercise scenarios. Planned Changes to Improve Safety Kettle Cooked Foods completes a thorough review of the ammonia system each time a design change is implemented. Kettle Cooked Foods is committed to using these methods to identify and implement ways to improve the safety of the system. The PSM committee is involved with any modification of the Standard Operating Procedures (SOPs), Process and Instrumentation Diagrams (P&IDs), and the Emergency Response Plan. Currently, the PSM is in the process of being modified to incorporate programs that have not been developed and programs that been developed but not yet implemented. A computerized process area detection system is to be installed by June 1999. |