Reser's Fine Foods, Inc. - Executive Summary
1.0 EXECUTIVE SUMMARY |
1.10 Accidental Release Prevention and Emergency Response Policies
The Reser's Fine Foods, Inc. refrigeration system uses pure anhydrous ammonia (a commonly used refrigerant for industrial systems) as the refrigerant. Given the quantity handled, anhydrous ammonia is considered a hazardous substance by the EPA. Many of the properties that make ammonia valuable as a refrigerant also requires that precautions and procedures be in place to protect employee and public health and safety during a chemical emergency. It is the policy of Reser's Fine Foods, Inc. to be in compliance with all applicable federal and state rules and regulations.
Safety at our facility is inherent in the manner in which anhydrous ammonia is handled. While the design of the facility incorporates a multitude of safety devices, safe handling procedures combined with appropriate training of our personnel are key aspects to maintaining safety at our facility.
We have a written Process Safety
Management (PSM) plan that complies with the regulations stipulated by it. A crucial component of this plan is the Emergency Response Plan, developed in compliance with Emergency Response provisions. The Emergency Response Plan includes pre-emergency planning and coordinating with outside parties. This enables those who deal with emergencies to have a course of action to effectively deal with unplanned events.
1.20 Facility Description and Substances Handled
* Reser's Fine Foods, Inc. is a food manufacturing facility that stores and distributes refrigerated foods. Production requires the use of a refrigeration system to preserve the integrity of processed foods. This refrigeration process uses ammonia as a refrigerant. Access to the facility is restricted to authorized employees, management personnel, and contractors.
* The regulated substance at this facility is anhydrous ammonia.
* The ammonia refrigeration system maximum inventory is 17,512 pounds of anhydrous ammonia. T
here is no standby make-up inventory kept on-site.
1.30 The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distance for each reported scenario
Release scenarios were modeled using RMP*Comp (version 1.04), a software program developed by the National Oceanic Atmospheric Administration (NOAA) and EPA. Offsite receptors were defined using the Landview III (version 1.0) system. This system estimates residential population within the circle defined by the endpoint of the worst-case and alternative release scenarios. In addition, it lists whether certain types of public receptors and environmental receptors are within the circles.
* Worst Case Scenario. Catastrophic failure of the High Pressure Receiver located on the NE outside corner of the building when filled to the greatest amount would release 5,510 pounds of liquid ammonia. This scenario presumes that the entire contents are release
The distance to the toxic endpoint for the worst-case scenario is 0.9 miles from the point of release. The distance extends beyond the facility fence line and would encompass a population of zero (based on 1990 US Census data). Public receptors now located within this zone include residences, schools, correctional facility, recreational area, and an interstate freeway. No environmental receptors are located in this zone. Current census data is unavailable. A release map corresponding to this scenario is located in Section 3.30. Census data was derived using the LandView III (version 1.0).
This worst-case scenario would not likely occur unless an act of nature (e.g. earthquake) physically compromised the tank. The structural integrity of the tank is safeguarded by periodic inspection for mechanical integrity to prevent a rupture due to tank degradation. The tank is also safeguarded from rupture due to over-pressurization. It is a pressure-rated vessel hydro-tested to 375
psi and equipped with 250 psi pressure relief valves. The design specification of the tank only allows maximum capacity of 80% at 80(, limiting the total amount of ammonia in the system. During high demand, the High Pressure Receiver may only be filled to a fraction (~30%) of capacity.
* Alternative Scenario. Several alternative scenarios can generate the equivalent of a 1" opening in a high pressure liquid line. Alternative scenarios could include an opening created by a valve sheared off, a large gasket leak, or a pressure relief valve release. These scenarios presume a release duration of 10 minutes resulting in a loss of 5,510 pounds of liquid ammonia. This scenario was selected because a release of this type would occur outdoors resulting in the highest potential exposure to offsite receptors.
The distance to the toxic endpoint for the worst-case scenario is 0.2 miles from the point of release. The distance extends beyond the facility fence line and would encompass a p
opulation of 0 (based on 1990 US Census data). Public receptors now located within this zone include a recreational area, an interstate freeway, and residences. No environmental receptors are located in this zone. A release map corresponding to this scenario is located in Section 3.30. Census data was derived using the LandView III (version 1.0).
The severity of release from this scenario would likely be less since safety systems provisions are in place to limit the release duration to less than 10 minutes through the use of appropriately placed isolation valves.
1.40 General Accidental Release Prevention Program and Chemical Specific Prevention Steps
Reser's Fine Foods, Inc. complies with EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations. The design and construction of this facility was in accordance with published standards, tests or recommended methods of trade, industry or government organizations.
Reser's written PSM plan incorp
orates many policies and procedures to ensure safe operation and maintenance of this facility. Plan elements essential to safe operation of the refrigeration system include employee participation, process hazard information, process hazard analysis, operating procedures, training, contractor safety, pre-startup review, mechanical integrity, management of change, hot-work permits, incident investigation, emergency response and planning and compliance audits. This plan will be reviewed annually and updated as necessary by the Reser's Fine Foods, Inc. Risk Manager.
Training is provided to ensure that each employee involved in operating a process has been trained in an overview of the process, the operating procedures, and safety considerations. This training uses guidelines by the International Institute of Ammonia Refrigeration (IIAR) and Refrigeration Engineers Technology Association (RETA). Only qualified maintenance personnel operate and interact with the refrigeration system. T
his minimizes the chances of inadvertent error in operation that could lead to a release of ammonia. Startup, shutdown, and any onstream adjustments are handled by these qualified persons.
1.50 Five Year Accident History
There have been no significant releases of ammonia at Reser's Fine Foods, Inc.
1.60 Emergency Response Program
Reser's Fine Foods, Inc. has a written Emergency Response Plan developed to ensure that precautions and procedures are in place to protect employee and public health and safety during a chemical emergency. The Emergency Response Plan complies with Emergency Response regulations. The Emergency Response Plan includes pre-emergency planning and coordinating with outside parties. This enables those who deal with emergencies to have a course of action to effectively deal with unplanned events.
The approach in the development of this plan has been to identify the ammonia emergencies most likely to occur at Reser's Fine Foods, Inc. and establish precaution
s and procedures to protect life safety and health during an emergency. The refrigeration process has back-up prevention systems to keep processing malfunctions from becoming ammonia release emergencies. If an emergency does occur, the following response personnel, facilities, and equipment are in place:
* Incident Command Center
* Emergency Alarm and Communication System
* Emergency Response Team
* Safe Rooms, Evacuation Plans, and Assembly Points
* Personal Protective Equipment
The role and procedures for obtaining external emergency assistance have been established with the Topeka Fire Department. The Emergency Response Plan also includes procedures for notification of any potentially affected neighbors.
All Reser's Fine Foods, Inc. personnel will be trained to fulfill their highest designated responsibilities in an emergency. Mock emergency drills will be held periodically to maintain familiarity with response actions and identify plan elements requiring improvement.
lan will be reviewed annually and updated as necessary by the Reser's Fine Foods, Inc. Risk Manager.
1.70 Planned Changes to Improve Safety
All system components meet design specifications in ANSI/IIAR 2-1992, equipment, design, and installation of ammonia mechanical refrigeration systems. All pressure vessels are built according to American Society of Mechanical Engineers (ASME), Section VIII, Division I, 1995 Edition (1996 Addenda), ASME Boiler and Pressure Vessel Code, pressure vessels. Any upgrades or extensive maintenance work performed in the future will be in compliance with those standards applicable at that time.
Future hardware changes include the 5-year changeouts of pressure relief valves according to IIAR recommendations.
Executive Summary RMP
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