Leprino Foods Company Remus, MI Plant - Executive Summary |
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1 Accidental Release Prevention and Emergency Response Policies Leprino Foods Company is strongly committed to employee, public and environmental safety. This commitment is inherent in its comprehensive accidental release prevention program, which covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. If such a release does occur, the facility will be evacuated and Mecosta County LEPC and the Remus Fire Department will be contacted for emergency response. 2 The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Cheese Manufacturing. The plant is located at 311 North Sheridan in Remus, Michigan. We have one regulated substance, Ammonia, at our facility, which is used to provide refrigeration for the manufacturing of cheese. The maxim um inventory of Ammonia at our facility is approximately 17,000 lb. 3 The Worst Case Release Scenario and the Alternative Release Scenarios, including administrative controls and mitigation measures to limit the distances for each reported scenario To perform the required offsite consequence analysis for our facility, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for the class of Program 3 toxic substances involves a catastrophic release from the Ammonia Refrigeration System. The scenario involves the release of 18,000 lb. of Ammonia in a gaseous form over 10 minutes. Release distances were calculated using Class F atmospheric stability and 1.5 m/s windspeed, and a toxic endpoint of 0.14 mg/L. No credit has been taken for existing active and passive mitigation systems that reduce the maximum distance t o the toxic endpoint. One alternative release scenario for Ammonia involves a release from the Ammonia Refrigeration System process. The scenario involves the release of 7,500 lbs. of Ammonia in a liquid spill and vaporization over 10 minutes. The release is also assumed to be controlled by active mitigation measures that include operator intervention. 4 The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set forth by the EPA under 40 CFR part 68. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Leprino Foods Company maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is a What If/Checklist. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of (five years or when changes dictate). Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Leprino Foods Company maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup aft er a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Leprino Foods Company has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with those processes. Refresher training is provided at least every three years and more frequently if needed. All training will be documented and validated by employees on the LFC Training Tracking System. Mechanical Integrity Leprino Foods Company carries out documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes, among others, pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered speci alized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Leprino Foods Company to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel, or any other employee whose job tasks are affected by a modification in process conditions, are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-startup safety reviews related to new processes and to modifications in established processes are conducted regularly at Leprino Foods Company. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Leprino Foods Company conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are be ing implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Leprino Foods Company promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident, as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation Leprino Foods Company truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting f rom process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of the contractor's safety performance is carried out. Leprino Foods Company has a strict policy of informing the contractors of known potential hazards related to their work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5 Five-year Accident History Leprino Foods Company has had a good record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, no accidental releases have occurred during this period. 6 Emergency Response Plan Leprino Foods Company carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan addresses emergency actions, medical treatment , evacuations, and notification of local emergency response agencies and the public. The Leprino facility in Remus, Michigan relies on the local fire department to respond to the release of hazardous materials. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Mecosta County is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7 Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Completion of the PHA recommendations are expected to occur by November 14, 2000. |