Burn Philp Foods & Fermentation - Executive Summary |
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This document contains all required information in order to meet 40 CFR 68 "Risk Management Program". This document consists of the executive summary and registration data elements (68.155 through 68.185). 10.1 RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Burns Philp Food & Fermentation facility in Hutchinson, Minnesota has a good record in preventing releases of anhydrous* ammonia. As part of their release prevention program, the plant has an excellent and very detailed preventive maintenance program. More information about these aspects of the prevention program is discussed in Section 4.0 of this Executive Summary. The facility has implemented an Emergency Action Plan, which is to ensure the safety of its employees', the community and the environment. This detailed emergency response program includes procedures for handling an emergency - the established response plan outside people (Hutchinson Fire Dept.) that are involved in containing an ammonia release - HAZMA T team. These components make the Emergency Action Plan a thorough and comprehensive plan for release prevention and emergency response. The emergency response policies at the Burns Philp Food & Fermentation facility ensure that there is emergency response coverage 24 hours - 7 days per week. *From this point in the Executive Summary, anhydrous ammonia will be synonymous with ammonia. 10.2 PROCESS DESCRIPTION AND REGULATED SUBSTANCES Burns Philp Food & Fermentation produces of food grade yeast (Torula yeast). The NAICS code for the process at this facility is 311999. Burns Philp Food & Fermentation has one regulated substance under 40 CFR 68: anhydrous ammonia. The ammonia is used as a refrigerant in the process for chilling water and also as a yeast nutrient. The ammonia threshold for triggering the applicability to 40 CFR 68 is 10,000 pounds. The total quantity of anhydrous ammonia stored in the refrigeration process is documented as approximately 100,000 pounds. This process exceeds the threshold quantity of 10,000 pounds as set by 40 CFR 68 and thus is regulated by the Risk Management Program. 10.3 WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS Worst-Case Scenario Description The largest potential release of ammonia would occur with a puncture in the ammonia tank (D202-A or D202-B). Taking the specific definition of the worst-case from 40 CFR 68.25, the largest quantity of ammonia that can be stored in a vessel is in the ammonia tank during a pump out condition. The total quantity of ammonia that can be stored in the ammonia tank is 62,763 pounds, without administrative controls. Since the facility is located in a semi-populated area, the toxic cloud formed by the evaporating ammonia would reach offsite endpoints and nearby receptors. Alternative Release Scenario Description The alternative release scenario that meets the selection criteria is an ammonia release from the leakage of a pump seal/flange. The release is located outside, near the bottom of the high-pressure receiver at approximately 2 feet above ground level. Administrative controls are not applicable to this scenario. Active mitigation of the release is through human intervention. Since the facility is located in a semi-populated area, the toxic cloud formed by the evaporating ammonia would reach offsite endpoints and nearby receptors. 10.4 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Burns Philp Food & Fermentation has developed an OSHA PSM program for their ammonia feed system. At Burns Philp Food & Fermentation, ammonia falls under the RMP Program 3 Prevention Program, which is identical to the OSHA PSM program. EPA has said that if the process is in compliance with OSHA PSM, then it is compliance with RMP Program 3. Thus, Burns Philp Food & Fermentation ammonia PSM has been reviewed and determined to be complete for the RMP document. Listed below are key aspects of the ammonia prevention program: 1. Most of the equipment at the ground level is guarded against impact. 2. Critical ammonia equipment is installed above the 100 year flood level. 3. Most of the pipe work is out of the way of people and the machinery and so there is less of a chance of an ammonia release. 4. The plant maintains good training, certification and employee awareness of operating procedures. 10.5 FIVE-YEAR ACCIDENT HISTORY The review of Burns Philp Food & Fermentation accident history includes the following range of dates: December 1, 1993 - December 1, 1998. According to 40 CFR Part 68.42(a), there have been no accidental releases at this facility. 10.6 EMERGENCY RESPONSE PROGRAM The facilty's Emergency Response Plan will be in place by September 15, 1999. 10.7 PLANNED CHANGES TO IMPROVE SAFETY The facility's PHA will be in place by September 15, 1999. |