Chef America, Inc. - Executive Summary |
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Accidental Release Prevention and Emergency Response Policies Chef America Corporation produces a large variety of frozen foods at its Chatsworth Facility. The food produced at Chatsworth is frozen and then shipped to various points around the country. The facility covers approximately eight acres. Approximately 500 employees work at the facility. The Facility operates under strict federal, state, and company regulations for safety of its employees, its products and the environment. Chef America uses ammonia as a refrigerant in its frozen food processes. By maintaining a comprehensive safety program for ammonia and documenting the program in this Risk Management Plan, Chef America is complying with OSHA's and CalOSHA's Process Safety Management Standards (called PSM) and California's and EPA's Risk Management Program regulations (called RMP). At Chef America, we realize that constant diligence in operation and proper maintenance of our ammonia system can reduce risks to our work ers and to the public. This RMP documents the procedures and controls in place to ensure that potential accidental releases of ammonia are prevented and to promptly respond to and mitigate any incident that might occur. Our RMP and PSM programs are applied to all onsite activities that could involve or affect the ammonia system. Our safety programs prevent accidents because they focus on the rules, procedures and practices that govern individual processes, activities or pieces of equipment. These rules are reviewed at regular intervals and improved as necessary. They are also communicated to, accepted, and practiced by all employees at the facility. Stationary Source and Regulated Substances Ammonia is handled at the facility as a refrigeration medium in a closed circuit system. No chemical reactions or venting occurs in the normal operation of the system. A total system capacity of 58,000 pounds of ammonia is the maximum inventory found at the site. System components include compressors, condensers, accumulators, piping and valves, instrumentation and controls and other miscellaneous components. Ammonia is periodically received by tank truck to recharge the refrigeration system and make up for fugitive emission losses which are normal for this type of system. Ammonia refrigerant is not used in any chemical reactions or chemical processes. Ammonia is used to transfer heat away from freezers in a continuous cycle of evaporation, condensation and compression. The ammonia is continuously recycled, so that make up or replacement of ammonia is done infrequently. Under normal operations, only very small, undetectable quantities are emitted. Anhydrous ammonia is a clear colorless gas with a characteristic odor. Although it is classed as a nonflammable gas, it will burn within certain vapor concentration limits, and the fire hazard will increase with the presence of oil or other combustible materials. It is shipped as a liquid under pressure. It is solubl e in water forming a corrosive liquid. Although ammonia is lighter than air, the vapors from a leak are cold and will initially hug the ground until they warm up and mix with air. General Accident Release Prevention Program Chef America has integrated program elements described in the RMP to deal with the risks involved with the storage and handling of ammonia throughout the refrigeration process. In this way, we promote overall plant, worker and public safety. These program elements include: Process Safety Information - Our ammonia refrigeration process has been designed and installed by reputable vendors who are well known in the refrigeration industry. We require that information on the design and operation of the facility be documented and maintained for as long as we operate it. Process Hazard Analysis - All of our processes involving ammonia have been thoroughly analyzed for unseen hazards using a trained team of employees with experienced hazard analysis leaders. Opera ting Procedures - Formal written procedures for operation and maintenance of our ammonia refrigeration system has been developed as part of our RMP. Procedures provide steps for each operating phase, they also document operating limits, safety and health considerations, and safety systems and their functions. Training - Chef America's refrigeration technicians have many years of experience in operating ammonia refrigeration systems. Several of them have 4 year degrees in technical subjects in addition to their work experience. Chef America certifies that their operators are competent. As required by Chef America, all technicians have proper training either before or after they are hired. Mechanical Integrity - Preventive maintenance practices have been in place for a number of years at Chef America. We perform routine safety checks, inspections and preventive maintenance tasks on refrigeration systems to reduce the likelihood and severity of equipment failures. Outside experts, including pressure vessel and piping inspectors are employed as needed to provide ongoing verification of the integrity of the system. Hot work procedures, Lockout/Tagout procedures and others are used to document and control safe work practices. Management of Change - Changes to the process, including chemicals, technology, equipment and procedures and changes to equipment that could affect the ammonia system are managed through use of a written management of change procedure. Designated management personnel must authorize changes under this program element. Pre-startup Safety Review - Before a major change can be instituted, Pre-startup Safety Review requires that Construction and equipment is in accordance with design specifications, procedures are in place and adequate, process hazard analysis is performed and recommendations resolved and training is conducted. Compliance audits - Under RMP Chef America is required to evaluate compliance with the RMP regulations at least every three years. Incident Investigation - The RMP requires that incidents which resulted in or could reasonably result in a catastrophic release of ammonia be investigated promptly by a team of investigators with the appropriate knowledge and experience to thoroughly investigate and analyze the incident. Employee Participation - We actively encourage and require our employees to participate in program development and enforcement. We have a documented system that verifies employee participation in each program element. Hot Work Permit - Before work is performed which involves a potential source of ignition, designated personnel must inspect the work area, review the procedures and document the precautions necessary to prevent fires or explosions. The written permit authorizes work on specific dates and on specific equipment. Contractors - Chef America has adopted the recommended practices of the International Institute of Ammonia Refrigeration's recommended practices for controlling contractors in the workplace. The contractor's safety record, training program and procedures are evaluated before they are hired and periodically during the course of the contract. Five year Accident History EPA requires that facilities document a five year history of accidental releases that caused serious onsite or offsite consequences. The Chatsworth Facility has had no reportable accidents in the last five years. Release Scenarios EPA requires that facilities document a theoretical worst case and alternative release scenarios to prompt public participation and discussion in chemical safety and emergency preparedness. The following scenarios have been developed following EPA's specific modeling assumptions and requirements. The assumptions require pessimistic assumptions of wind speed, air stability and other factors that are not typical conditions for the area. Worst Case Release Scenario Failure of the receiver,which operates at 90 lb. pressure, containing 19,000 pound s, resulting in a ten minute release. Under worst-case weather conditions, ammonia could travel 1.7 miles before dispersing enough to no longer pose a hazard to the public. This scenario is unlikely and doubtful of occurring for the following reasons: -Under normal operations, the receiver that operates at 90 lb. pressure, contains only about 25% if its capacity (7,000 lbs.). -The ammonia is typically contained in piping and smaller vessels throughout the system that would be more easily be isolated before a large amount of ammonia is released. This vessel would only contain a large quantity of ammonia if the entire refrigeration system were shut down and pumped back to vessels in the machine area. This would be a very unusual situation since portions of the system are in operation 24 hours per day, 7 days per week. A jet striking the facility or a major system modification might be incidents that would require a complete pump down. A series of catastrophes would be required for the 19,000 lbs. to be released. -Industry standards for the manufacture and quality control are employed by the facility; -Ammonia is not corrosive in this service; pressure safety valves limit operating pressure in this vessel; a program is in place at the facility that includes regular maintenance, inspection and testing, and replacement of equipment. -The facility is continuously supervised 24 hours per day, 7 days per week by competent technicians who are trained to identify potential problems and to isolate leaks if they occur. Alternative Release Scenario Failure of a liquid drain valve or a valve left open after system maintenance with a release rate of 370 pounds per minute. Under typical weather conditions, ammonia could travel 0.2 miles before dispersing enough to no longer pose a hazard to the public -The Chatsworth Facility has in place each element of the prevention program to reduce the likelihood and consequences of this scenario. Mechanical integrity, prestart -up safety review, management of change and operating procedures help prevent this type of incident. -By procedure, all drains are verified closed and secured at time of startup. Emergency Response Program Chef America has recently revised their emergency response plan and reviewed the plan with the Los Angeles Fire Department. Chef America's emergency response plan provides procedures for prompt notification of public officials and employees in event of an emergency. Sensitive receptors outside of the facility have been identified in accordance with the Local Emergency Planning Committee guidelines and information has been provided to local officials to assist them with public notification and warning. The emergency response plan details how Chef America will interface with the public and local agencies. All employees at the facility are periodically trained in the provisions of the emergency plan and the relevant aspects of the Incident Command System utilized by Chef Amer ica and other response agencies. Planned Changes to Improve Safety Through the process of developing and implementing Process Safety Management and Risk Management Programs Chef America has identified a number of improvements that will be implemented at the Chatsworth Facility, including the following: -An Ammonia Detection system has been approved and is currently in the design stage. -Nondestructive testing of vessels and other equipment is scheduled. -All relief valves in ammonia service are scheduled for replacement. -The training program is being revised to include additional training for operators. -Operating and maintenance procedures are being updated. -Process safety information is being updated. |