Emerald Industries - Executive Summary |
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TABLE OF CONTENTS 0 INTRODUCTION 0-1 1 RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 1-1 1.1 AMMONIA PROCESS 1-1 1.2 PROPANE PROCESS 1-1 2 PROCESS DESCRIPTION AND REGULATED SUBSTANCES 2-1 2.1 AMMONIA PROCESS 2-1 2.2 PROPANE PROCESS 2-1 3 WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS 3-1 3.1 AMMONIA WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS 3-1 3.1.1 Worst-case Release Scenario 3-1 3.1.2 Alternative Release Scenario 3-1 3.2 PROPANE WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS 3-1 3.2.1 Worst-case Release Scenario 3-2 3.2.2 Alternative Release Scenario 3-2 4 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS 4-1 4.1 AMMONIA PROCESS 4-1 4.2 PROPANE PROCESS 4-1 5 FIVE-YEAR ACCIDENT HISTORY 5-1 5.1 AMMONIA PROCESS 5-1 5.2 PROPANE PROCESS 5-1 6 EMERGENCY RESPONSE PROGRAM 6-1 6.1 AMMONIA PROCESS 6-1 6.2 PROPANE PROCESS 6-1 7 PLANNED CHANGES TO IMPROVE SAFETY 7-1 7.1 AMMONIA PROCESS 7-1 7.2 PROPANE PROCESS 7-2 0 INTRODUCTION This document contains all required information in order to meet 40 CFR 68 "Risk Management Program" including the executive summary and registration data elements (68.155 through 68.185). Section 1.0 describes the release prevention policies and emergency response policies at the plant. Section 2.0 gives a brief description of the plant and of the ammonia and propane systems. Section 3.0 defines the worst-case and alternative release scenarios for both of the regulated substances at the plant. The general accidental release prevention program and chemical-specific prevention steps are described in Section 4.0. A summary of the plant's five-year accident history is presented in Section 5.0. Section 6.0 discusses the plant's Emergency Response Program. Section 7.0 contains improvements made to the systems to ensure a safe working environment. The Registration Data Elements are located in Section 8.0. This document must be submitted to EPA by June 21, 1999. 1 RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Keebler Company senior management is committed to process safety and the implementation of safe operating procedures as evidenced by the Prevention Programs for ammonia and propane meeting 40 CFR 68 requirements. 1.1 AMMONIA PROCESS The Florence facility complies with all applicable Federal, state and local rules and regulations to protect the health and safety of the plant's employees and surrounding community. The plant only allows certified ammonia operators and authorized contractors to operate and maintain the ammonia system. The facility's emergency response policy involves coordination with the Florence Fire Department and Local Emergency Planning Committee (LEPC). The facility would notify off-site responders in the event of an ammonia release. The plant works closely with the LEPC to prevent the occurrence of a release. An employee of the facility is cur rently a member of the LEPC council. 1.2 PROPANE PROCESS This plant adheres to all applicable Federal, state, and local rules and regulations to ensure a safe working environment and safe environment for the community. Access to the propane system is restricted to certified propane operators, authorized contractors, and the Florence Fire Department. The emergency response policies for propane include procedures for notification of the Florence Fire Department, the primary responder in the event of a release. 2 PROCESS DESCRIPTION AND REGULATED SUBSTANCES The Keebler plant in Florence, Kentucky is a producer of cookies and crackers. The SIC code for these processes at this facility is 2052. The North American Industry Classification System (NAICS) Code for the primary process at this facility is 311821. Keebler has two regulated substances under 40 CFR 68: ammonia, and propane. Ammonia is used as a refrigerant. Propane is used as a stand-by fuel for the baking ovens. 2.1 AMMONIA PROCESS The Florence facility has one ammonia refrigeration process used for process and space cooling. The ammonia system is a single stage system utilizing four thermosyphon cooled rotary screw ammonia compressors. Cooling loads are fed ammonia from either the high pressure receiver or controlled pressure receiver. Two suction accumulators are used to control temperature for the various evaporators in the facility. Evaporative loads include seven coils in the cookie cooling tunnel, one scraped surface heat exchanger, one ice builder, one shell and tube water chiller and one air handling unit in the dry ingredients room. The four compressors discharge to three evaporative condensers via a common discharge header. Condensed ammonia flows by gravity from the evaporative condensers to the thermosyphon receiver. Standpipes in the thermosyphon receiver provide liquid ammonia to the high pressure receiver and controlled pressure receiver. The majority of the pressurized vessels for the ammonia system are located within the plant structure in the "ammonia room". Access to the ammonia room is limited to employees who have been certified in the plant's ammonia operator training program or are authorized contractors. Visitors are not allowed in the ammonia room unless accompanied by a certified Keebler employee. The ammonia system is continually monitored to ensure the system is operating within specified control limits. The ammonia system's inventory is approximately 17,000 pounds. Thus, the plant exceeds the threshold quantity of 10,000 pounds as set by 40 CFR 68. 2.2 PROPANE PROCESS The facility has one propane process. The main components of the propane stand-by fuel process are: a 30,000 gallon water capacity storage tank, one pump, a water-bath vaporizer, two regulators, and piping. The piping located outside of the plant is buried to prevent contact with heavy machinery and condensation in the propane lines. The propane storage tank and pump are surrounded by a locked chain link fence. The fence prevents access by employees who are not trained on the use of the propane system. The components of the propane system that are located outside of the plant building are monitored by security to ensure that unauthorized personnel do not have access to the propane system. A security company, ADT, monitors the propane system to provide 24 hour day surveillance. The propane threshold for triggering applicability to 40 CFR 68 is 10,000 pounds. The plant administratively limits the amount of propane stored in the one storage tank to 80%. The maximum amount of propane contained onsite is 100,800 pounds of propane. This exceeds the threshold limit, which results in the Florence Keebler plant as being regulated under 40 CFR 68 as a Program 2 facility. 3 WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS 3.1 AMMONIA WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS Ammonia is a toxic regulated substance capable of causing off-si te consequences in a release. Various types of release scenarios are possible including a spill resulting in an evaporating pool, a puncture of a vessel which results in a horizontal jet or vertical jet, a mechanical failure in a vessel or in a valve which results in an instantaneous release or instantaneous evaporating pool. The worst-case release scenario and alternative release scenario for the ammonia system are described below. 3.1.1 Worst-case Release Scenario The EPA definition of the worst-case release is a failure of the largest tank, causing the release of the entire contents of the tank. The worst-case release for the ammonia system would result from a puncture in the liquid portion of the high pressure receiver. The high pressure receiver is located outside at the center of the western portion of the plant. The total quantity of ammonia that can be stored in the high pressure receiver is 8,704 pounds. It is assumed all 8,704 pounds is released to the atmosphere in 10 minutes. Since this facility is located in a populated area, the toxic cloud formed by the evaporating ammonia would reach offsite endpoints and nearby public receptors. 3.1.2 Alternative Release Scenario The alternative release scenario is more likely to occur than the worst-case scenario. The alternative release scenario consists of the sight glass being sheared off of the high pressure receiver. The release occurs near ground level as a horizontal jet. There are no applicable administrative controls or passive mitigation. The system is shut down approximately 60 minutes from the start of the release. Since this facility is located in a populated area, the toxic cloud formed by the evaporating ammonia would reach off-site endpoints and nearby public receptors. 3.2 PROPANE WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS Propane is a flammable regulated substance capable of causing off-site consequences in a release. Various types of release scenarios are possible including va por cloud fires (flash fires), a pool fire with radiant heat effects, boiling liquid expanding vapor explosion (BLEVE) leading to a fireball producing intense heat, a vapor cloud explosion, and a jet fire from a hole in a tank. The worst-case release scenario and a more likely alternative release scenario are described below. 3.2.1 Worst-case Release Scenario The EPA definition of the worst-case release is a failure of the largest storage tank, causing the release of the entire contents of the tank. The plant has one 30,000 gallon water capacity propane storage tank. The contents of the tank find an ignition source resulting in a vapor cloud explosion. A ten percent yield factor is assumed from the TNT-equivalency formula. Thus, ten percent of the released quantity will participate in a resulting explosion. Company policy limits filling the 30,000 gallon propane tank to 80% of the capacity at 60oF. The total released quantity of propane is 100,800 pounds. Since the facility is located in a populated area the vapor cloud explosion would affect public receptors. 3.2.2 Alternative Release Scenario The alternative release scenario examined involves the release of propane during a "pull-away" during tank loading operations. The pull-away consists of a failure of a 25 foot length of 4 inch diameter hose. The excess flow valve stops the flow from the tank resulting in the release of the hose contents. The hose contents, 69 pounds of propane, results in a vapor cloud explosion. Since the facility is located in a populated area the vapor cloud explosion would affect public receptors. 4 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS 4.1 AMMONIA PROCESS This facility complies with EPA's Accidental Release Prevention Rule, Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) program, and all Federal, state and local codes and regulations. The plant conducts inspections of the ammonia p rocess to ensure the integrity of the system. The inspections provide the ammonia process engineers with valuable information that helps to prevent the worst-case release scenario and alternative release scenario from occurring. The Florence plant has developed an OHSA PSM program for ammonia. A process is in compliance with EPA's RMP Program 3 if it is in compliance with OSHA's PSM. Keebler's ammonia PSM documentation has been reviewed and determined to be complete. 4.2 PROPANE PROCESS This facility complies with EPA's Accidental Release Prevention Rule and with all Federal, state and local codes and regulations. The system was originally designed and constructed in 1997 in accordance with the NFPA-58 code. The plant conducts inspections during operation of the propane system to ensure the system is intact and operating correctly. A process control system has also been installed on the propane system. The control system shuts down the propane system if high pressure and low pressure control levels are tripped. The plant has developed a prevention program for propane to meet the Program 2 requirements of the RMP rule. The prevention program was written to be in compliance with 40 CFR 68, to ensure the safety of the employees, and to ensure the safety of the surrounding community. Keebler developed a training program for the propane system personnel. The program discusses: (1) the potential hazards associated with propane, (2) the proper operating and maintenance procedures for the propane system, and (3) certification of employees for operation of the propane system. The plant also uses vendors who are NFPA-58 compliant. 5 FIVE-YEAR ACCIDENT HISTORY 5.1 AMMONIA PROCESS The review of this facility's accident history for ammonia includes the following range of dates: June 22, 1994 - June 21, 1999. The plant has had one ammonia release during the five-year accident history period. The accident occurred on August 28, 1997. Approximately 800 pounds o f ammonia was released. The plant developed a more stringent work policy to ensure the health and safety of the employees. The plant has incorporated these policies into their Program 3 documentation, maintenance procedures, and operating procedures. 5.2 PROPANE PROCESS The review of this facility's accident history for propane includes the following range of dates: June 22, 1994 - June 21, 1999. There have been no propane releases at this facility as defined in 40 CFR Part 68.42(a). 6 EMERGENCY RESPONSE PROGRAM 6.1 AMMONIA PROCESS The Florence plant does not have an internal emergency response team to address an ammonia release. The LEPC and the Fire Department are notified in the event of an emergency by calling 911. In the event of an ammonia release the plant follows an emergency evacuation procedure that directs the employees to a safe location. The plant has installed wind socks to determine the evacuation route. 6.2 PROPANE PROCESS The Florence plant does not hav e an internal emergency response team to address a propane release. The Florence Fire Department is notified in the event of an emergency by calling 911. The Florence plant has developed an emergency evacuation document. The purpose of the document is to provide an orderly, effective plan of action for protecting employees in emergency situations when an evacuation is necessary. 7 PLANNED CHANGES TO IMPROVE SAFETY A Process Hazard Analysis (PHA) was conducted for the ammonia system and a Hazard Review (HR) was conducted for the propane system to outline the hazards associated with each process. A "what-if/checklist" was completed for both the PHA and the HR. Each "what-if/checklist" contains a list of action items to be accomplished to help improve safety at the facility. The following examples briefly describe current improved safety measures occurring at the Florence plant. 7.1 AMMONIA PROCESS The Florence plant is modifying the ammonia system in 1999. The items listed b elow will be addressed during the modification. 1. The plant is replacing all relief valves on pressurized vessels. 2. The plant is rerouting the pressure relief valve piping on the high pressure receiver to an area where employees will not be affected if a release occurs. 3. Employees will be trained on the health and safety hazards associated with each task and will be required to be a certified ammonia system operator prior to performing work on the system. 4. In order to prevent a release from occurring, due to heavy machinery impacting the ammonia system, the plant will be conducting training for personnel who operate machinery on the hazards associated with ammonia and what to do if there is an ammonia release. The plant will also be placing additional warning placards near the equipment and pipe bollards where necessary. 5. The plant is installing an additional accumulator to prevent slugging of the compressor and a possible ammonia release. 6. The release of ammonia with in the plant is a concern. The plant will be installing a sail switch in the exhaust fans and will require the operation of HVAC to be added to the daily log. 7. The plant is installing ammonia detectors and monitors. 7.2 PROPANE PROCESS The plant recently installed the propane system in 1997. The system was designed and installed in accordance to federal, state and local codes. 1. As a safety precaution the Florence plant will use only NFPA-58 knowledgeable vendors to supply and fill the propane tank. (2/17/99) 2. The possibility of a propane release caused by untrained personnel operating the propane system is a concern at the Florence plant. To address this concern the facility has initiated a training program for all personnel responsible for the operation of the propane system. Personnel who are not responsible for the operation of the system will not be allowed to perform any tasks related to the propane system. (2/17/99) 3. The Florence plant has installed fenc es surrounding the facility to prevent the general public from access to the tank. (1997) 4. The plant buried the propane process lines to protect the propane system from punctures and or damages caused by heavy machinery. (1997) |