Steuben Foods, Inc. - Executive Summary |
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I. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY POLICIES Steuben Foods recognizes management's responsibility in protecting it's employees, equipment, property, and the environment. The safety and health of all personnel are very important. The control of accidents has been and will continue to be a basic responsibility of all personnel in the facility. The Steuben Foods PSM/RMP program assigns and documents the specific responsibilities for developing, implementing and integrating the OSHA PSM and the EPA RMP standards into its safety program. The PSM/RMP program focuses attention on "Making PSM/RMP the way we manage our ammonia based refrigeration system" rather than a project we expect to complete and put on the shelf when the fileing date has passed. Steuben Foods believes that Employee participation is the key to a successful program. Operating level employees, particularly the Project Manager and the Refrigeration System Operators, have been deeplly involve d and they assume the major responsibility for operating the Elma, New York facility safely. The Steuben Foods Emergency Response Program has been developed with the complete cooperation and support of the Elma Fire Department. All Steuben Foods employees have received documented emergency response training. II. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED Steuben Foods is a Manufacturer of Aseptic dairy products. The refrigeration system contains no more than 25,000 pounds of Anhydrous Ammonia. Anhydrous Ammonia is the only Hazardous Material on site in quantities above the threshold quantity. III. SUMMARY OF WORST CASE AND ALTERNATIVE RELEASE SCENARIOS The WORST CASE release scenario involves the complete rupture of the High Pressure Receive. A maximum of 11185 pounds of ammonia over a 10 minute period was considered. Under worst case weather conditions ammonia could travel up to .9 miles before dispersing. A WORST CASE relea se is very, very, very, unlikely to occur during the life of the facility, this is because of the release prevention and mitigation features incorporated in the PSM/RMP program. An alternative case release scenario that we call WORST CASE CREDIBLE was slightly more likely. A 2237 pound ammonia vapor loss from failure of a psv to reseat or from ruptured vapor piping. Unsder worst case weather conditions ammonia could travel up to .1 mile before dispersing. This release is very, very unlikely to occur during the life of the Elma, NewYork facility. An alternative case release that we call MOST LIKELY, MOST SEVERE was slightly more likely still. A 100 pound ammonia loss from a failing ammonia transfer hose during the unloading operation. Under worst case weather conditions ammonia could travel up to .1 mile before dispersing This release is very unlikely to occr during the life of the Steuben Foods facility. IV. DESCRIPTION OF THE STEUBE N FOODS ACCIDENTAL RELEASE PREVENTION PROGRAM Steuben Foods conducts an annual training and response exercise with the Elma Fire Department to practice, train and update the Emergency Response Program. Steuben Foods conducts an annual PSM/RMP implementation progress audit of the entire PSM/RMP prograr to identify strengths and weaknesses and make improvements. Steuben Foods considers the PSM/RMP manuals to be "living" documents that must be updated and revised regularly to maintain their viability. Steuben Foods emphasizes and insists on "employee participation" from the refrigeration system operators in all aspects of the developent, implementation, and integration of their PSM/RMP program. Steuben Foods provides a comprehensive, computer based, user friendly training program with "one-on-one" teacher involvement in specific training modules for each ammonia refrigeration employee. Steuben Foods maintains a pro-active "open-door" policy toward neighbors and concerned community citizens. Facility tours and risk management discussions are scheduled and conducted upon written request. V. FIVE YEAR ACCIDENTAL RELEASE HISTORY There have been no releases of ammonia at Steuben Foods that resulted in an injury, or that had an off-site impact, or that resulted in significant property damage either on-site or off-site. VI. Emergency Response Program Facility employees have been trained to respond to accidental ammonia release. The site emergency plan has been coordinated with the community emergency plan under the jurisdiction of the Local Elma Fire Department. VII. PLANNED CHANGES TO IMPROVE SAFETY Steuben Foods recognizes that (even though their Ammonia release and injury experience has been excellent) their PSM/RMP program will provide much needed improvement to their safety effort. The PSM/RMP program is considered to be a set of "living" documents and procedures that will require constant attention, development, and revision before "Safety" becomes becomes second nature. Steuben Foods expects to improve safety performance by emphasizing the following elements of their PSM/RMP Program (1) Employee Participation is the "Key" to a successful program. Bothof the Refrigeration System Operators are deeply involved in Verifying the P&ID's, Developing and updating the Standard Operating Procedures, and performing the documented Preventive Maintenance Inspections. (2) The Steuben Foods PSM/RMP Program is: (a) computer based, (b)user friendly, (c) includes "one-on-one" involvement with specified and qualified trainers, (d) written to minimize paperwork and maximize documentation, and (e) written to be understood and used by the operating level employees. (3) All recommendations developed during the HAZOP were designed to improve the safety performance of the Ammonia Refrigeration Process. Steuben Foods expects to evaluate each recommendation in a t imely manner and implement, as soon as possible, those recommendations that will reduce the possibility of a release and/or mitigate the consequences of an unintentional release. |