Atlantic Custom Processors, LLC - Executive Summary |
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This is to inform all interested persons, including employees, that the Atlantic Custom Processors, LLC facility in Fort Fairfield, Maine, is complying with OSHA's Process Safety Management Standard (or "PSM"), located in Title 29 of the Code of Federal Regulations (CFR) part 1910.119, as well as EPA's Risk Management Program regulations (RM Program or "RMP"), located in Title 40 CFR part 68. These regulations deal with the risks involved with the storage, handling, and processing of hazardous chemicals. By operating in compliance with these standards, we protect our employees, our facility, the general surrounding public, and the environment from the potentially harmful effects of these hazardous chemicals. These programs primarily enable our facility to prevent the occurrence, and minimize the consequences, of significant releases of toxic substances as well as fires, explosions, and other types of catastrophic accidents. Overall, these programs prevent accidental fatalities, inju ries and illnesses, avoid physical property damage, and minimize our impact on the environment. Our safety programs are applied to any activity involving hazardous chemicals including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. Any group of vessels that are interconnected and separate vessels, which are located such that a hazardous chemical could be involved in a potential release shall be considered a single process. Our safety programs prevent accidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment. These rules are detailed and improved as necessary. They are also communicated to and accepted by all employees at the facility. Atlantic Custom Processors, LLC ("ACP") operates a potato processing facility in Fort Fairfield, Maine. The only chemical found to be present above its respective RM Program quantity threshold at this facility is anhydrous ammonia. There is a single Program Level 3 ammonia refrigeration process in use at this facility. The RM Program for ACP, which is separately documented in detail, consists of the specific elements listed below. Management Plan: The facility has a system in place to manage the implementation of the RM Program elements. The Plant Manager is the designated facility RM Program Manager and therefore has the overall responsibility for the ACP facility RM Program. As Plant Manager, this individual has the authority to assign company resources to develop, implement, update, and integrate all applicable RM Program elements at the ACP facility. The Plant Manager/RM Program Manager has identified a team of ACP personnel that have been granted the responsibility for implementing and maintaining the RM Program. Members of the RMP/PSM Team include the Boiler and Refrigeration Team Leader and the operator, the Maintenance Team Leader and a representative maintenanc e employee, and the Safety Coordinator. The RMP/PSM Team is responsible for all five elements of the RM Program, including management, prevention, hazard assessment, emergency response, and RM plan updates. The RMP/PSM Team members are responsible for implementing and maintaining of the ACP RM Program. The RMP/PSM Team has responsibilities that are shared among its members and others that are assigned to specific team members. Typically, the responsibilities that are shared among the RMP/PSM Team are those responsibilities that can be performed prior to an emergency such as emergency planning, RM Program development, and RM Program maintenance activities. Responsibilities that must be performed during an emergency are assigned to specific individuals to lower the potential for confusion over responsibilities during emergency response. Each member of the RMP/PSM Team must delegate their specific responsibilities to an alternate during periods of prolonged absence and/or vacation. The RMP/PSM Team reports to the Plant Manager, acting as the RM Program Manager. The Plant Manager and the RMP/PSM team receive direction and support from the Vice President of Environment and Regulatory Affairs and the Corporate Safety Manager. The RM Program Manager reports to corporate management. The Corporate chain of management above the unit director is as follows: 1) the Director of Manufacturing; 2) the Senior Vice President of Operations; 3) the Food Group President; and lastly 4) the Chief Executive Officer. Chemical Release Prevention Program: The facility has a chemical release prevention program for the ammonia system. This prevention program is required by both RM Program and Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) regulations, which are quite similar with respect to release prevention. The prevention program for the ammonia process was developed to comply with PSM regulations in 1999. Because the PSM program has so rec ently been developed, some of the informative elements in the RMP do not yet apply (e.g. '7.9-7.11). Key provisions of the facility release prevention program are as follows: 7 Employees who operate these systems must receive training initially and periodically on safe startup/shutdown, operations, and emergency shutdown of the processes. 7 Release incidents are investigated, and the results are used to improve the safety of the process. 7 Results of incident investigations are also shared with employees who could be affected by a release incident. 7 The ammonia refrigeration system undergoes preventive maintenance through a mechanical integrity program, which not only minimizes the risk of accidents, it also maximizes process safety and efficiency. 7 Employees participate in a "Process Hazard Analysis" (PHA) which identifies potential hazards and ways to improve the safety of the process every five years, or whenever significant changes are made to the process. 7 The facility has a "Management Of Change" (MOC) program in place which tracks and controls any and all changes that are made to the refrigeration system. It also requires a preliminary safety review of proposed changes before construction or modification begins. 7 A pre-startup safety review is conducted after the completion and before the start up of a major change and prior to a new process coming on line. 7 A hot work (spark producing) permit program is also in place to prevent the occurrence of fires on or near the process. 7 ACP requires contractors who are hired to work on or near the regulated process to have adequate training on potential hazards prior to starting work. 7 The ACP facility has an ammonia alarm system which notifies the refrigeration system operators of a potential release, which allows for rapid response minimizing the duration of accidental releases. Five Year Accident History: Offsite consequence analyses need to consider the release history of each process. In the past f ive years, the ammonia refrigeration system has not had releases that have resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage (i.e. no reportable accidents as defined in 40 CFR Part 68.42). Worst Case and Alternate Case Release Scenarios: Potential ammonia release events were modeled to evaluate potential offsite impacts to areas surrounding the ACP facility. Modeling procedures followed EPA guidance to identify worst case release scenarios (WCS) and alternate case release scenarios (ACS) as defined by the RM Program regulations. EPA personnel freely admit that the assumptions used for WCS are not realistic and in some cases are not physically possible. However, EPA guidance was followed and toxic endpoints were identified for the WCS and the ACS. ACSs are considered by EPA to be more realistic and useful for emergency response planning than the WCS. The WCS for the facility was identified by assuming that the contents of the largest vessel would be released in a 10-minute period. Following EPA guidance, the largest vessel approach (considering passive mitigation) was used to estimate the WCS. The vessel with the highest calculated release rate to the environment is a low pressure receiver which is located on the plant roof. Written operating procedures, high-level alarms, and level control switches prevent more than 660 gallons from being present in the 860 gallon tank. This works out to a maximum of approximately 3,800 pounds of ammonia liquefied under pressure in the vessel. Since the low pressure receiver is located on the roof, no passive mitigation can be assumed. Under worst case weather conditions, the modeled WCS release would result in an endpoint radius of 1.2 miles. The estimated affected residential population within the 1.2 mile WCS radius is 1,200 persons. This estimate does not include any ACP employees in the facility, or other non-residential persons. Realistically, the use of standard operating procedures, administrative and engineering controls, and because of the location of the vessel, it is not likely that a release such as this could occur. Potential ACSs were evaluated following EPA and IIAR guidelines. The ACS that resulted in the longest distance to endpoint was selected for presentation in this document and for reporting to EPA. The selected ACS consists of a one inch diameter hole in the float switch column connected to a low pressure receiver. This release would occur indoors, which means that passive mitigation has been taken into consideration. The estimated rate of release is 10 pounds of ammonia (liquid and vapor) per minute for a maximum of 79 minutes (790 pounds total). Under common weather conditions, the calculated release rate to the environment from this accident scenario results in a toxic endpoint radius of 0.1 mile. The estimated affected residential populat ion within the 0.1 mile ACS radius is 0 persons. Although this accident scenario was selected as the ACS, the likelihood of its occurrence is minimal because of the process safety programs that have been instituted at the facility. Emergency Response Program: ACP's emergency response program is based on the OSHA requirements for Emergency Action Plans (29 CFR parts 1910.38 and 1910.119), Hazardous Waste Operations ("HAZWOPER" 29 CFR part 1910.120), and the EPA requirement for Emergency Response programs (40 CFR section 68.95). We have trained employees for emergency response and maintain a written emergency response plan. This plan is coordinated with the Local Emergency Planning Committee (the Aroostook Emergency Planning Committee) and the local fire department. We conduct annual drills for implementation of the emergency response plan at the facility. RM Program Reporting: The timely submittal of the RMP*Submit program meets the RM Program reporting requirements. ACP will upda te this submittal every five years, or sooner if necessary, based on RM Program regulation requirements or process modifications. |