Bil Mar Foods - Zeeland, Michigan - Executive Summary
RISK MANAGEMENT PLAN |
Bil Mar Foods
In accordance with Title 40 of the Code of Federal Regulations Chapter 68 (40 CFR 68) promulgated by the Environmental Protection Agency (EPA), Bil Mar Foods (Bil Mar) submits this Risk Management Plan (RMP) for operations at their Zeeland, Michigan facility. Bil Mar operations include the processing of meat products (hot dogs and lunchmeat) for public consumption packaged under the familiar brand names such as Sara Lee, Mr. Turkey, and Ball Park Franks. Bil Mar has been in operation at this location since 1936 providing quality meat products and over 1,000 jobs to the local community.
Accidental Release Prevention and Emergency Response Policy
Bil Mar Foods is committed to protecting the health of its employees, the surrounding community, and the environment. It is Bil Mar's policy to maintain a safe and healthy workplace, protect the environment, and comply with all applicable regulations, in
cluding 40 CFR 68 and, as applicable, Occupational Safety and Health Organization (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Federal Regulations, Chapter 1910, Section 119 (29 CFR 1910.119), and OSHA's Hazardous Operations and Emergency Response regulations (29 CFR 1910.120).
Stationary Sources and Regulated Substances
Bil Mar Foods is required to maintain low temperatures in the food processing areas of the plant that are within standards required by the United States Department of Agriculture (USDA) to ensure quality in the final products. Bil Mar Foods also operates freezers and coolers for product storage. Bil Mar uses anhydrous ammonia (the 112(r) regulated substance) as a refrigerant to maintain the 550,000 sq.ft. facility within the required range of operating temperatures and to operate the freezers and coolers. Anhydrous ammonia is an industry-standard refrigerant for meat processing plants. Bil Mar's refrigeration system consis
ts of receivers, compressors, evaporators, condensers, and piping.
Worst Case Release Scenario
As required by 40 CFR 68 Subpart B, Bil Mar has evaluated a worst-case release scenario for anhydrous ammonia using the parameters specified by the EPA. The worst-case release scenario is defined as the release of the entire contents of the largest single vessel over a 10-minute period. Based on Bil Mar's refrigeration system, the worst-case release scenario is the rupture of one of the receiver tanks (9,600-gallon vessel) when filled to 80% capacity. Using EPA's RMP*Comp 1.06 version, it was determined that the ammonia release would reach offsite endpoints and nearby public / environmental receptors.
The worst-case release scenario was developed following EPA regulations and is not considered
by Bil Mar to be a likely release scenario for the facility. During normal operations, Bil Mar maintains the receivers at no more than 60% capacity. Only during pump-down operations do the rec
eivers have the potential to be filled to 80% of capacity. The receivers are operated in pump-down mode less than 1% of the time during the year.
Alternative Release Scenario
A more realistic release scenario (alternative release) was developed by Bil Mar Foods taking into consideration the 5-year history of operation's experience and the hazards identified in the process hazard analyses conducted to ensure that Bil Mar's hazards are identified and minimized. These analyses were conducted in accordance to Occupational Safety and Health Organization (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Federal Regulations Chapter 1910, Section 119 (29 CFR 1910.119). In accordance with 40 CFR 68.28, alternative release scenarios were considered, that would be more likely to occur than the worst-case release scenarios.
After reviewing the process hazard analysis performed on the system, the most likely anhydrous ammonia release could occur from a H
i-Lo (forklift truck) impacting one of the on-site evaporators located inside the plant. In developing the release parameters of this alternative scenario, Bil Mar considered the area of highest Hi-Lo traffic, rupture of the largest pipe connected to the evaporator, the average response time of the facility's Hazmat team, and the mitigation provided by the building structure.
Accidental Release Prevention Program
To prevent and mitigate accidental releases of anhydrous ammonia, Bil Mar has implemented certain precautionary measures, including process / equipment controls, procedures, preventative maintenance programs, employee training and auditing. In addition, Bil Mar's ammonia refrigeration system is designed and constructed in accordance with accepted industry standards and good engineering practices.
Bil Mar has also developed and implemented a PSM program pursuant to OSHA regulations and as such, has evaluated the system for the potential of anhydrous ammonia releases.
Some of the controls installed to prevent catastrophic releases of ammonia are process equipment (vents, pressure relief valves, backup pumps, and manual shutoffs) and automated controls (automatic shut-offs, ammonia leak detection system, and electrical distribution system grounding). In addition, Bil Mar has trained approximately 50 team members to respond to potential ammonia releases (HazMat team).
Bil Mar has developed standard operating procedures for all employees and contractors that have contact with the ammonia refrigeration system that incorporate safety measures into the procedures. These safety procedures were developed by refrigeration system operators and are reviewed periodically by the operators during weekly PSM training sessions. Process safety information for the refrigeration system is reviewed during these weekly meetings as well. Bil Mar encourages employee participation in development of the control measures used at the plant by means of company newsletters
and training sessions. Pursuant to written management of change procedures established by Bil Mar, any changes to the operating procedures are to be communicated to affected employees.
Bil Mar understands that maintaining the refrigeration system in good working order is essential to preventing accidental releases; therefore Bil Mar has implemented a preventative maintenance program. The preventative maintenance program is scheduled, documented and managed using a computer maintenance management software system to ensure that regular maintenance occurs on the system. Also, to ensure the mechanical integrity of critical refrigeration system components, regular inspections and testing is conducted.
To ensure that Bil Mar's control measures are effective in maintaining the safe operation of the plant, regularly scheduled audits are performed on the ammonia refrigeration system:
7 In accordance with the PSM program, Bil Mar conducts detailed PSM compliance audits at least every thre
e years that incorporate review of process safety information, process hazard analysis, operating procedures, training programs, system mechanical integrity, management of change, pre-start up review procedures, compliance audit procedures, incident investigation procedures, employee participation programs, hot work permit procedures, and contractor safety procedures.
7 Bil Mar's insurance carrier also conducts independent audits on a regular basis.
Five-Year Accident History
Over the last five years, Bil Mar has not experienced an accidental off-site release of anhydrous ammonia from the ammonia refrigeration system.
Emergency Response Program
Bil Mar has documented emergency response procedures in a document entitled OFF-SITE RESPONSE STANDARD OPERATING PROCEDURES FOR BIL MAR FOODS (SOP) in order to facilitate response efforts in the event of an off-site anhydrous ammonia release. Included in the SOP are measures to be taken internally by Bil Mar as well as measures to
be taken by off-site response agencies.
Bil Mar has trained approximately 50 on-site personnel to respond to accidental ammonia releases. These personnel are trained in accordance with 29 CFR 1910.120, OSHA's Hazardous Waste Operations and Emergency Response regulations according to their duties and function. These personnel receive initial training and annual update training thereafter. As an additional training exercise, a simulation of an emergency release with off-site effects was conducted with the entire emergency response system. This involved coordination between Bil Mar's Hazmat team and multiple local fire, ambulance and police departments; as well as two local hospitals (with Air-Med units). The simulation was critiqued and changes made to the SOP as appropriate. Bil Mar intends to do another simulation in the year 2000.
To assure that the local governmental response agencies are familiar with Bil Mar's emergency response procedures, Bil Mar has submitted copie
s of the SOP for review and approval by the local agencies. The following local agencies have reviewed and approved Bil Mar's SOP:
7 Olive Township Supervisor,
7 Blendon/Olive Fire Department,
7 Ottawa County LEPC, and
7 State Emergency Planning Commission (SERC)
To plan for an ammonia release with off-site effects, Bil Mar's SOP includes procedures/equipment to mitigate the release, procedures to inform local response agencies, transportation maps for response agencies, evacuation route maps, and procedures for public communication.
In the event of an anhydrous ammonia release with off-site effects, the general public will be warned using the following methods:
7 GRAIL (Grand Rapids Area Information Link) System
7 Broadcast message via the Ottawa County Central Dispatch
7 Police and fire vehicles equipped with public address systems, and
7 Door-to-door notification of residents by emergency response agencies (if deemed necessary).
As backup measures, Bil Mar h
as arranged emergency response assistance with a local clean-up contractor. The fire department has also arranged for back-up assistance from another local environmental clean-up contractor.
Continuing Efforts to Improve Safety
As part of Bil Mar Foods' continuous efforts to improve the safety of the system, certain changes are planned at the facility to improve safety and prevent anhydrous ammonia releases. These changes include improvements to operating procedures, relocation of ammonia equipment to safer locations, increased protection of ammonia equipment (e.g., guarding), and increased ammonia safety training.