Hillshire Farm & Kahn's - Executive Summary

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1.  Accidental Release Prevention and Emergency Response Policies 
Hillshire Farm & Kahn's at Bob Huber Drive, in Claryville, Kentucky complies with EPA's Accidental Release Prevention Program Rule (40 CFR Part 68), OSHA's Process Safety Management (PSM) Standard (29 CFR 1910.119) and OSHA Hazardous waste operations and emergency response (HAZWOPER) rules (29 CFR 1910.120).  The enclosed Risk Management Plan addresses the requirements of 40 CFR Part 68 as they relate to the storage, handling, and processing of a highly hazardous chemical - ammonia.  Through our compliance with Part 68 and 29 CFR 1910, we promote overall plant, worker, and community safety.  Our Risk Management Program enables our facility to prevent the occurrence and minimize the consequence of a significant release of  ammonia, including leaks, spills, fires, explosions, and other types of catastrophic accidents.  
In order to reduce the likelihood and severity of accidental chemical releases that may affect on-sit 
e workers and off-site populations and environmental receptors, the Company policy is to fully comply with the spirit and the letter of EPA's Accidental Release Prevention Program rules (40 CFR Part 68).  The Company has developed a formal Risk Management Plan in compliance with 40 CFR Part 68.  All employees are expected to understand their role in developing and implementing the plan and to diligently adhere to its provisions.  The Claryville facility's Risk Management System has clearly defined lines of authority and designation of responsibilities to ensure that the risk management plans are developed, implemented, and revised.  Hillshire Farm & Kahn's safety and risk programs prevent accidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment. 
2.  Facility and Regulated Chemical Description 
Hillshire Farm & Kahn's meat processing facility, located at 401 Bob Huber Drive in Claryville, Kentucky, is su 
bject to the requirements of 40 CFR Part 68, the Accidental Release Prevention Provisions (112r) of the Clean Air Act, due to an on-site process containing a regulated chemical above its threshold quantity.  Anhydrous ammonia, a regulated toxic substance, is present in the facility refrigeration system in a quantity greater than its 10,000 pound threshold.   The threshold quantity was established in the 112r regulations.  
Anhydrous ammonia is present as the refrigerant in the plant refrigeration system.  Preparation of the meat products, packaging, and storage operations require refrigeration to keep raw ingredients and products fresh. The system consists of a high pressure tanks, compressors, piping, pumps, chillers, and associated equipment located at various strategic locations throughout the plant.  The ammonia may exist as a gas or as a liquid in different parts of the system.  The total amount of ammonia present in the refrigeration system is approximately 65,000 pounds.  The ma 
ximum amount of anhydrous ammonia held in a single process is approximately 25,000 pounds.  This amount is found in pressure vessel V-3B located in the ammonia compressor room on the east side of the facility.  This vessel is part of the overall refrigeration system, but is isolated from other process areas via backflow valves, check valves, and other line mechanical segregation devices. 
3.  Worst-Case and Alternative Case Scenarios 
Worst-Case Scenario: Failure of the high pressure receiver V-3B when filled to the maximum of 25,000 pounds (maximum capacity of receiver rounded to two significant digits).  The entire contents are assumed to be released as vapor over ten minutes as per regulatory guidance.  The distance to the toxic concentration endpoint of 0.14 mg/L for the worst-case scenario is 1.6 miles based on the PHAST Model. 
Alternative Scenario:  Pressure vessel V-1 is ruptured after being struck by a fork lift truck.  The tank loses its contents of approximately 3,600 pou 
nds (normal operating capacity).  The scenario assumes the leak would be detected and stopped in 60 minutes. The distance to the toxic concentration endpoint of 0.14 mg/L is 0.16 miles based on the PHAST Model.  The occurrence of this scenario is unlikely because operating procedures to prevent such an occurrence are in place and employees are trained to ensure that proper control of fork lift trucks is maintained in the compressor room and that the area surrounding V-1 is avoided if at all possible. 
4.  Accidental Release Prevention Program 
The Claryville facility complies with EPA's Accidental Release Prevention program rules and OSHA safety rules under 29 CFR 1910 for ammonia.  All elements of the accidental release prevention requirements under Part 68 have been developed and implemented for ammonia at the Claryville facility. 
The ammonia refrigeration system meets OSHA PSM standards (29 CFR 1910.119) and has been audited to the standard as required every 3 years.  The refriger 
ation system was designed and constructed in accordance with ANSI/IIAR 2-1992 Standard for Equipment, Design, and Installation of Ammonia Mechanical Refrigerating Systems.  A process hazard review was conducted for ammonia on August 1, 1998 using a "What-If Checklist" and all identified problems were addressed.  Written operating procedures associated with all facets of ammonia storage, handling, and transfer are in place.  All persons working with ammonia or ammonia containing equipment have been trained on operating procedures and understand the consequences of deviation from the procedures.  A mechanical integrity program is in place for ammonia refrigeration equipment and operations. 
5.  Five-year Accident History 
No accidental releases of ammonia have occurred during the last five years that resulted in off-site impacts of any kind. 
6.  Emergency Response Program 
The emergency response program at the Claryville facility is based on the OSHA requirements for Emergency Action 
Plans (29 CFR 1910.38 and 1910.119) and HAZWOPER (29 CFR 1910.120).  We have trained employees for emergency response and maintain a written emergency response plan.  The plan is coordinated with the Campbell County Emergency Management and the Southern Campbell Fire Department.  The Hillshire response team trains and drills monthly.  We conduct annual drills for implementation of the emergency response plan at the facility with the participation of the LEPC and fire department. The emergency response plan includes procedures for notification of fire department and notification of any potentially affected neighbors.   
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