Oregon Freeze Dry - Executive Summary |
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General Executive Summary for Manufacturing: 1. Accidental Release Prevention and Emergency Response Policies: We at Oregon Freeze Dry are committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that 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. Unforeseeably, if such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also completely coordinated with the Albany Fire Department, who provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled: We have 1 regulated substance present at our facility. This substance is Ammonia (anhydrous). the maxim um inventory of Ammonia (anhydrous) that is expected to be present in this facility, based on process/operational requirements, is 72,246 pounds. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario: To perform the required off-site 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. Toxic Worst-Case Analysis: The first Worst-Case scenario involves a catastrophic release from Oregon Freeze Dry's Plant 1. The scenario involves the release of 3999 lb. of Ammonia (anhydrous) in a gaseous form over 10 minutes. The release rate (lbs/min) is calculated to be 399.9. A distance to endpoint of 1.6 miles is obtained which affects a residential population of 9763 within this distance. Th e second Worst-Case scenario involves a catastrophic release from Oregon Freeze Dry's Plant 2. The scenario involves the release of 2375 lb. of Ammonia (anhydrous) in a gaseous form over 10 minutes. The release rate (lbs/min) is calculated to be 237.5 and a distance to endpoint of 1.4 miles is obtained which affects a residential population of 7032 within this distance. Toxic Alternative-Case Analysis: The first Alternative-Case scenario involves a catastrophic release from Oregon Freeze Dry's Plant 1. This scenario involves the release of 1700 lb. of Ammonia (anhydrous) in a gaseous form over 10 minutes. The release rate (lbs/min) is calculated to be 170 and a distance to endpoint of .31 miles is obtained which affects a residential population of 195. The second Alternative-Case scenario involves a catastrophic release from Oregon Freeze Dry's Plant 2. This scenario involves the release of 1700 lb. of Ammonia (anhydrous) in a gaseous form over 10 minutes. The release rate (lb s/min) is calculated to be 170 and a distance to endpoint of .31 miles is obtained which affects a residential population of 195. Flammables Worst-Case Analysis: None applicable for Plant 1 or Plant 2 Flammables Alternative-Case Analysis: None applicable for Plant 1 or Plant 2 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps: Our facility, which includes all three of our manufacturing plants, has taken the following steps as required by 40 CFR part 68 of the EPA. Two 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 sources. Process Safety Information: Oregon Freeze Dry maintains a detailed record of safety information that describes the chemical hazards, operating parameters, and equipment design s associated with a process. 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 analysis is the 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 every three years. 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, Oregon Freeze Dry 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 after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the proces ses. Training: Oregon Freeze Dry has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. New employees receive basic classroom training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided at least annually and more frequently as needed. Mechanical Integrity: Oregon Freeze Dry carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes: 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 given specialized training as needed. Any equipment deficiencies identified by the mai ntenance checks are corrected in a safe and timely manner. Management of Change: Written procedures are in place at Oregon Freeze Dry 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 given training to deal with the modificiation. Pre-Startup Reviews: Pre-startup safety reviews related to new processes and to modifications in established processes are conducted as a regular ppractice at Oregon Freeze Dry. 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: Oregon Freeze Dry conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every three year s and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation: Oregon Freeze Dry promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of an 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 aare retained for a minimum of 5 years. Employee Participation: Oregon Freeze Dry 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 from process hazard analysis 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 safety performance of the contractor is carried out. Oregon Freeze Dry has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of al the procedures for emergency response, should an accidental release of a regulated substance occur. 5. Five-Year Accident History: An accident occurred in Oregon Freeze Dry's Plant 2 on 8/18/97. The release duration was 120:00 minutes. The on-site property damage was $0.00 and there were no injuries. Ammonia (anhydrous) was the only chemical involved in the accident. An accident occurred in Oregon Freeze Dry's Plant 2 on 5/24/98. The release duration was 300:00 minutes. The on-site property damage was $0.00 and there was 1 on-site death. There were no other on-site injuries and no off-site injuries or deaths. The number of off-site hospitalizations was 0 and 0 people were given medical treatment. 0 people were evacuated and 0 were sheltered-in-place. The off-site property damage was estimated at $0.00. Ammonia (anhydrous) was the only chemical involved in the accident. The initiating event for the accident was human error. An accident occurred in Oregon Freeze Dry's Plant 2 on 3/10/99. The release duration was 000:45 minutes. The on-site property damage was $0.00 and there were 0 on-site deaths. There were no on-site injuries and no off-site injuries or deaths. The number of off-site hospitalizations was 0 and 0 people were given medical treatment. 0 people were evacuated and 0 were sheltered-in-place. The off-site property damage was estimated at $0.00. Ammonia (anhydrous) was the only chemical involved in the accident. The initiating event for the accident was equipment failure. 6. Emergency Response Plan: This facility is included in the written comm unity ER plan. This facility has its own written ER plan. The ER plan includes specific actions to be taken in response to accidental releases of regulated substances. The ER plan includes procedures for informing the public and local response agencies of a chemical release. The ER plan includes information on emergency health care. Date of most recent review/update of ER plan: 2/15/99 Date of most recent ER training of employees: 5/18/99 The local agency coordinating ER plan is the Albany Fire Department which has the phone number: 541-917-7700. 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. We will continue our annual plant evacuation drills. In addition, a joint emergency response training drill was conducted with the National Frozen Foods Corporation and the Albany Fire Department on May 18, 1999. This drill enhanced our mutual aid capa bilities in the event of an accidental chemical release. |