Winchester Foods - Executive Summary |
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EXECUTIVE SUMMARY Accident Release Prevention Program and Emergency Response Policy It is the policy of the KPR Holdings - Winchester Foods (Winchester) 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 Winchester 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. Winchester's management is committed to providing the resources necessary to implement this policy. Facility Description Winchester operates a meat processing and food preparation ope ration at this facility in Hutchinson, Kansas. The main products are wholesale bacon bits and frozen tacos. Operations at the facility include ovens, coolers, chillers and a spiral freezer. Figure 1-1 shows the site location and Figure 1-2 shows the facility layout. One chemical, ammonia, is utilized at the facility in sufficient quantities to be subject to the requirements of 40 CFR Part 68, RMP. 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 techniques and/or reference tables to define the distance to a specified endpoint (concentration or overpressure). The distance to the endpoint is affected by several facto rs including molecular weight, volatility, heat of combustion, and physical setting (urban or rural). The alternative 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 off site, unless no such scenario exists. The alternative release scenario is evaluated using the same techniques as the worst-case 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 buildings in the immediate vicinity of the Hutchinson, Kansas, facility, an urban dispersion environment was assumed. Ammon ia 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 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 would involve liquid and would come from a pressurized liquid system; 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 north-side pressure receiver in a 10-minute period (per EPA guidelines). This release translates to a release of 5,578 pounds of ammonia in 10 minutes or 557.8 lbs/min. Other assumptions included in the worst-case assessment are: the ammonia is a liquefied gas; the receiver is not diked; the release does not take place indoors; 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 assessment for ammonia show that the plume must travel 0.90 miles (1.44 kilometers) before dispersing to the endpoint concentration of 200 ppm. Figure 1-3 details the worst-case release zone. The selected alternative release scenario for the ammonia systems is a release from a relief valve on the condenser. The largest outdoor relief valve in the system was used in this scenario. The relief valve has a relief rate of 94.5 pounds 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 94.5 pounds of air per minute correlates into a release rate of 67. 8 pounds of ammonia vapor per minute. The ammonia refrigeration document provides calculated endpoint distances for typical meteorological conditions (3 m/s wind speed, D atmospheric stability, 50% relative humidity). It has been determined that the response time for the release would be approximately five minutes. Based on the release rate of 67.8 lbs/min, the total amount released is 339 pounds. Other assumptions include, no active or passive mitigation measures are currently in place and an urban dispersion environment in the nearfield. The results of the alternative-release scenario for an ammonia release indicates that the endpoint concentration of 200 ppm is reached at 0.07 miles (113 meters) from the release point. Note that this represents an overestimate of the distance as the ammonia released from the relief valve has been assumed to be a dense gas. Figure 1-4 details the alternate release zone. General Accidental Release Prevention Program and Chemical Specific Prevention St eps The Winchester 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 264, Hazardous Waste Contingency Plan * 29 CFR Part 119, Process Safety Management The key concepts in Winchester's release prevention program are employee participation, appropriate design and maintenance of equipment, and appropriate training of all employees. Winchester has a PSM committee made up of seven employees that understand the system. Winchester is in the process of identifying additional employees that are interested in learning the system and getting involved in the PSM/RMP process. Winchester has an emergency response plan in place and sufficient equipment on site to respond to most ammonia releases. Winchester's 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. Winchester maintains a computerized program of maintenance activities to ensure that key systems are maintained appropriately to minimize the risk of a release. Winchester is committed to providing appropriate training to all employees regarding safety procedures. New employees are provided comprehensive safety training during their initial orientation for the facility. In addition, Winchester 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 Winchester's emergency response team receive annual training to ensure that response actions are promptly and safely comple ted. Five Year Accident History Winchester has not had a release of ammonia from the Hutchinson, Kansas, facility that has affected the public or the environment within the last five years. Emergency Response Program Winchester 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. Planned Changes to Improve Safety Winchester completes a thorough review of the ammonia system each time a design change is implemented. Winchester is committed to using these methods to identify and implement ways to improve the safety of the system. The ammonia system was installed in 1997 and the PSM was completed in 1998. A PSM committee will be formed and the first order of business will be the verification of information in the PSM. |