Barber Foods - Executive Summary
Risk Management Plan |
I. Executive Summary
A. Accidental Release Prevention and Emergency Response Policies
Barber Foods (Barber). is committed to operating its chicken production plant in Portland, Maine in an environmentally responsible manner and to providing a safe work place for its employees and the surrounding community. As part of this commitment, Barber has developed and implemented numerous safety programs that are designed to eliminate and/or drastically reduce the potential for accidental releases. Barber has also developed and implemented a number of programs that are designed to ensure that if an accidental release occurs, it will be handled in a manner that minimizes adverse impact to people, the environment and the plant. Many of these programs have been in place for some time.
Barber views accident prevention, and personnel and environmental protection as a neverending process. Consequently, Barber continuously str
ives to improve its accident prevention, environmental protection and emergency response programs. A recent addition to Barber's overall accident prevention and response program is the development of its Risk Management Program. Barber's Risk Management Program (RMP) complies with the U.S. Environmental Protection Agency's ("EPA's") Chemical Accident Prevention rule found at 40 C.F.R. Part 68. One of the requirements of this rule is to submit a Risk Management Plan. This document is Barber's RMP plan and provides the public with information about Barber's processes, accident prevention programs and emergency response planning efforts. Barber's compliance with EPA's RMP rule includes:
1. Completion of a hazard assessment in compliance with 40 C.F.R. Part 68, Subpart B, including the five-year accidental release history--Barber has never experienced an RMP reportable release or accident at its plant.
2. Implementation of a accident prevention program. The plant's RMP accident
prevention program is coordinated with the plant's Process Safety Management (PSM) program which was developed under similar rules administered by the Occupational Safety and Health Administration "OSHA";
3. Implementation of an emergency response plan.
Additional information regarding how Barber addresses each of these requirements is provided below and in the attached RMP plan.
The plant and all equipment is designed and operated to minimize the possibility of an accidental release. At a minimum, the plant and equipment meet government and industry design and construction standards.
B. RMP Covered Stationary Source and Regulated Substance
The Barber plant in Portland, ME is owned and operated by Barber Foods. The plant processes chicken. Ammonia is the only chemical present at the plant in sufficient quantity to be regulated by the RMP rule. Ammonia is used in the refrigeration system used to process chicken products.
Ammonia is stored in several tanks inside the Barber f
acility. The largest tank can hold up to 8,300 pounds of ammonia. The total maximum amount of ammonia used at any one time in the refrigeration process is approximately 13,000 pounds.
C. Off-site Consequence Analysis
As required by the RMP rule, Barber's off-site consequence analysis included evaluation of a worst-case accidental release for all toxic chemicals (ammonia) and an alternative release for each covered chemical (ammonia).
A worst-case release is defined by EPA as "a release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to an endpoint defined in ' 68.22." 40 C.F.R. ' 68.3. EPA requires the worst-case accidental release to be modeled using highly conservative meteorological data designed to result in the maximum possible adverse impact. For example, EPA requires worst-case models to be based on the hottest day of the year, occurring at night with a very slow, steady wind which would not di
sperse a release very effectively. Further, the model assumes that the entire contents of the largest vessel (8,300 pounds) is released in ten minutes (830 pounds per minute). Because Barber's high pressure receiver is located in a room with no doors or window that exit to the outside, the actual release rate to the ambient air has been adjusted in accordance with guidance provided by EPA.
Using the EPA mandated criteria described above, the worst-case release at the plant (for purposes of RMP) would involve a complete failure of the largest storage tank, filled to maximum capacity with 8,300 lbs. of ammonia. If such a release occurred, it would result in a vapor cloud that could impact persons outside of the plant's property line. The probability of a 8,300 lb. tank of ammonia releasing its entire contents in ten minutes in Maine on a 930F night when the wind is blowing at 3.4 miles per hour is extremely low.
Barber developed an alternative release of ammonia that focuses on a
more realistic release scenario occurring during more common meteorological conditions. EPA requires modeling of a release which could impact off-site locations. Alternative release modeling of the most realistic scenario resulted in off-site impacts. After considering all criteria in the RMP rule, the Process Hazard Analysis performed on the refrigeration process, and all past releases, Barber used a gas release from a relief valve tied to one of the compressors for its alternative release. The rupture would result in a release of 680.85 pounds in one minute. More realistic meteorological conditions were used to generate a more realistic toxic endpoint distance.
D. Accident Release Prevention Program
Barber has developed an accidental release prevention program that is designed and implemented to drastically reduce the possibility of an accidental catastrophic release. The program complies with the requirements of OSHA's Process Safety Management rule found at 29 C.F.R. Part
1910.119 and analagous to RMP requirements found at 40 C.F.R. Part 68, Subpart D. The program has been very successful as evidenced by the fact that the plant has never experienced an accidental release that requires reporting under EPA's RMP rule. See 40 C.F.R. ' 68.42. To comply with the RMP rule, the plant has taken its existing PSM program and incorporated an additional focus-protection of the public.
The basic elements of Barber's prevention program are described below:
1. Employee Participation. Barber has developed and implements a written plan of action regarding employee participation in the safety and accident prevention process. The plan describes how employees are: (A) consulted and what input they will have in the development of process hazard analysis (PHA) and other PSM and RMP safety elements; and (B) given access to PSM and RMP information at the plant.
2. Process Safety Information. Barber has compiled written process safety information which helped
identify the hazards posed by ammonia, handling of materials, management, storage activities and the refrigeration process in general. The compilation of process safety information provided the foundation for understanding the hazards involved in the refrigeration process and was crucial to the development of the PHA (discussed in subsection 3 immediately below). The required process safety information includes information pertaining to the hazardous chemicals (e.g. ammonia), the technology of the process, and the process equipment. 29 C.F.R. ' 1910.119(d).
The type of information pertaining to the technology of the process includes: (1) block flow diagrams; (2) process chemistry; (3) maximum intended inventory; (4) safe upper and lower limits for temperature, pressure, flow and composition; and (5) an evaluation of the consequences of deviations, including those affecting the safety and health of employees and the nearby public.
The equipment information includes: (1) materia
ls of construction; (2) piping and instrumentation diagrams (P&IDs); (3) electrical classification; (4) relief system design and design basis; (5) ventilation system design; (6) design codes and standards employed; and (7) material and energy balances for processes built after May 26, 1992.
3. Process Hazard Analyses. Barber performed its most recent process hazard analysis (PHA) on the refrigeration system in 1999. The PHA is a key component of the PSM system and Barber's RMP accident prevention program. It provided a thorough, orderly, systematic approach for identifying, evaluating, and controlling hazards posed by the refrigeration process. The PHA utilized methodologies in accordance with 29 C.F.R. ' 1910.119(e) and 40 C.F.R. ' 68.67.
The PHA addressed: (1) hazards of the process; (2) engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases
(e.g., process monitoring and control instrumentation with alarms); (3) consequences of failure of engineering and administrative controls; (4) facility siting; (5) human factors (human error); and (6) a qualitative evaluation of a range of the possible safety and health effects of failure of controls on the employees in the work place.
4. Operating Procedures. Barber has developed and implements written operating procedures that provide clear instructions for safely conducting activities involved in the refrigeration process. These procedures are consistent with the process safety information described in subtask 2, above, and cover, where appropriate and applicable:
A. Initial startup;
B. Normal operations;
C. Temporary operations;
D. Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner;
E. Emergency oper
F. Normal shutdown;
G. Startup following a turnaround or after an emergency shutdown;
H. Consequences of deviation from operating limits;
I. Steps required to correct or avoid deviation;
J. Precautions necessary to prevent exposure, including engineering and administrative controls, and personal protective equipment;
K. Control measures to be taken if physical contact or airborne exposure occurs;
L. Quality control for raw materials and control of hazardous chemical inventory levels; and
M. Safety systems and their functions.
Barber has also developed and implements safe work practices that provide for the control of hazards during operations. For example, Barber has programs that govern the following activities: lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into PSM and RMP covered portions of the plant by maintenance, contractor or other support personnel.
5. Training. Barber provides employees, contractors and vis
itors with training that focuses
on the special safety and health hazards posed by the plant operations, the RMP and PSM
covered process, emergency operations including shutdown, and safe work practices
applicable to the employees job tasks.
6. Contractors. As part of Barber's contractor selection process it obtains and evaluates
information regarding contract employer's safety performance and programs. (29 C.F.R. '
1910.119(h) Barber also:
A. Informs contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the covered process;
B. Explains to contract employers the applicable provisions of the facility's emergency response contingency plan (discussed below); and
C. Develops and implements safe work practices to control the entrance, presence and exit of contract employers and contract employees in covered process areas.
7. Pre-startup Safety Review. Prior to the introduction o
f highly hazardous chemicals to a new or existing RMP/PSM covered process, Barber confirms the process is constructed and the equipment is designed in accordance with specifications; and that appropriate safety, operating, maintenance, and emergency procedures are in place to adequately protect the health and safety of employees and the nearby public.
8. Mechanical Integrity. Barber has developed and implements written procedures to maintain the ongoing integrity of the process equipment listed below. Barber also trains contractors to maintain the following process equipment:
A. Pressure vessel's and storage tanks;
B. Piping systems (including piping components such as valves);
C. Relief and vent systems and devices;
D. Emergency shutdown systems;
E. Controls (including monitoring devices and sensors, alarms, and interlocks); and
9. Hot Work Permit. Barber implements a hot work permit program for all hot work operations (e.g., welding, soldering).
10. Management of Ch
ange. Barber has established and implements written procedures to manage changes to process chemicals, technology, equipment, and procedures associated with the refrigeration process; and changes to facilities that affect this process. These procedures ensure that the following considerations are addressed prior to any change:
A. The technical basis for the proposed change;
B. Impact of change on safety and health;
C. Modifications to operating procedures;
D. Necessary time period for the change; and
E. Authorization requirements for the proposed change.
11. Incident Investigation. Barber investigates each incident which resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical in the workplace. An incident investigation team is established and consists of at least one person knowledgeable in the process involved, including a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledg
e and experience to thoroughly investigate and analyze the incident.
12. Emergency Planning and Response. Barber has developed an emergancy response plan that satisfies applicable state and federal emergency response and accident prevention planning requirements.
13. Compliance Audits. Barber evaluates the plant's compliance with the PSM Standard and the RMP rule at least every three years to verify that the procedures and practices it has developed are adequate and being followed. RMP and PSM audit findings reports will be developed after each audit.
14. Trade Secrets. Barber makes all necessary information available to those persons responsible for compiling process safety information and those assisting in the development of the process hazard analysis.
E. Five Year Accident History
The Barber plant has never experienced a RMP reportable release.
F. Emergency Response Procedures and Policies
Barber has elected to develop an emergency action plan rather than a full-fle
dged emergency response plan. In the event that an accidental release occurs the plant depends on the Portland Fire and Police Departments for outside support. When the Portland Fire Department determines additional assistance is needed, it will contact other local and state emergency response teams.
Barber foods has implemented Emergency Response Procedures that meet state and federal requirements, including the RMP rule requirements. All employees at Barber Foods receive basic emergency response training appropriate to their response responsibilities. Those employees that work with hazardous materials or could come into contact with them are given specific training, depending on their duties, on the proper handling of hazardous substances and notification procedures in the event of a release. Many employees have received OSHA Hazard Communication Training. During an emergency, Barber employees have also been trained to evacuate to a predesignated muster point and contact the a
G. Planned Changes
There are no planned changes to note.