Sandridge Food Corporation - Executive Summary |
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EXECUTIVE SUMMARY SANDRIDGE FOOD CORPORATION MEDINA, OHIO Background Data In accordance with Title 40 of the Code of Federal Regulations Chapter 68 (40 CFR 68) promulgated by the Environmental Protection Agency (EPA), Sandridge Food Corporation (Sandridge) submits this Risk Management Plan (RMP) for operations at their Medina, Ohio facility. The operations at the Medina facility include the processing and storage of perishable prepared food products for public consumption. These products are packaged under the familiar Sandridge Gourmet Salads brand name and distributed locally. Sandridge has been in operation at this facility for 15 years providing quality products and over 250 jobs to the local community. Accidental Release Prevention and Emergency Response Policy Sandridge is committed to protecting the health of its employees, the surrounding community, and the environment. It is Sandridge's policy to maintain a safe and healthy workplace, protect the environment, and comply with all applicable regulations, including 40 CFR 68 and the Occupational Safety and Health Administration's (OSHA's) Process Safety Management (PSM) regulation, 29 CFR 1910.119. Stationary Sources and Regulated Substances To ensure the quality of Sandridge's final products, refrigeration is necessary to maintain the low temperatures required for the food processing and storage areas of the plant. These requirements are promulgated and monitored by the United States Department of Agriculture, the Ohio State Department of Agriculture and the United States Food and Drug Administration. In addition, the refrigeration system is utilized to operate large coolers and freezers for the storage of ingredients and finished products. To achieve this, Sandridge uses anhydrous ammonia, the 112(r) regulated substance, as the refrigerant in the cooling system. The ammonia refrigeration system maintains the 110,000 square-foot facility within the required range of operating temperature s and provides the cooling necessary for the production and storage of their products. Anhydrous ammonia is a standard refrigerant for the food industries and widely used throughout the country. The refrigeration system at Sandridge Food Corporation's Medina facility consists of compressors, condensers, receiver vessels, pumps, evaporators, heat exchangers, air handling units, and the associated piping for this equipment. At the time of this RMP filing, a large plant expansion project, including the installation of additional refrigeration equipment, was underway. This system expansion will require the addition of ammonia to the system. Engineering calculations and system operational experience estimate that the system could contain up to approximately 21,300 pounds of ammonia after the expansion. The contents of this Risk Management Plan, including the release scenarios and consequence modeling, are based upon the post-expansion system conditions and increased ammonia inventory. It is anticipated, based on project schedules at the time of this filing, that ammonia could be added to the system as early as February 2, 2000. Worst Case Release Scenario As required by 40 CFR 68 Subpart B, Sandridge Food Corporation has evaluated a worst-case release scenario for anhydrous ammonia using the parameters specified by the EPA. The worst-case release scenario is defined as the release, over a 10-minute period, of the entire contents of the largest vessel or pipe in the facility's system. Based on the design of Sandridge's refrigeration system at the Medina facility, the worst case release scenario would involve the rupture of the High Pressure Receiver (HPR), which is the largest single vessel in the system. The High Pressure Receiver can contain up to approximately 11,068 pounds of ammonia when filled to 100% of capacity. The HPR, like all other major vessels in the system, is located inside the facility's compressor room, more commonly known as the engine ro om. The engine room has four interior doors leading into other sections of the building and no exterior doors or windows leading directly to the atmosphere. While the room provides passive mitigation for a release, the room is equipped with a ventilation fan that exhausts to the outside atmosphere. The basis for the worst case release scenario involves 100% of the volume of the High Pressure Receiver being released to the compressor room and then exhausted through the fan. Using the equations in Chapter 4 of the EPA's RMP Guidance for Ammonia Refrigeration, the maximum distance to the specified "endpoint" was calculated. This is a conservative distance, established by the EPA, at which it is expected that a person could be exposed to the chemical for an hour without suffering irreversible health effects. The distance to the endpoint, calculated for the worst-case release scenario, includes offsite receptors. The worst-case release scenario was developed following EPA regulations and is not considered by Sandridge Food Corporation to be a likely release scenario for the facility. During normal operations, the High Pressure Receiver is maintained at a level between 10% and 25% of its total capacity. The HPR has never been filled to 100% capacity, the volume used in the worst case scenario calculations, in the operating history of the plant. The highest level of ammonia that has ever been stored in the High Pressure Receiver is approximately 75% of the total volume. This only occurs during a pump-down of the refrigeration system for maintenance or the addition of new equipment. A pump-down of the entire system has only occurred once every 3 to 4 years, usually due to a system expansion. However, since the current system expansion will include the addition of enough ammonia to make a 100% volume scenario physically possible, this quantity was used to provide the absolute worst case scenario possible. The other event that could potentially cause a higher th an normal level of ammonia in the HPR is charging of the system which is only performed, if needed, once each year. Alternative Case Release Scenario A more realistic release scenario (alternative case release) was developed in accordance with the EPA requirements. This scenario considers the facility's 15-year history of operational experience and the potential hazards identified in the process hazard analysis (PHA) study conducted by Sandridge. The PHA study was performed to ensure that the potential hazards associated with the ammonia refrigeration system were identified and minimized. The analysis was conducted in accordance with OSHA's Process Safety Management regulations contained in 29 CFR 1910.119. The alternate release scenario identified by Sandridge involves damaging a = inch diameter pipe, resulting in the release of liquid ammonia. When considering the potential alternate release scenarios, all piping routed to and installed on equipment located outside the buil dings was considered first. In developing the release parameters of this alternative scenario, Sandridge considered piping and equipment located in areas where vehicle traffic, personnel foot traffic, and work-related activities were likely to occur. The resulting scenario involves damage to a = inch high-pressure liquid line running along the roof of the building. The piping is located in an area where plant personnel perform work activities and pass through to other areas of the roof. This makes the potential for damage by tools, equipment or personnel a credible scenario for consideration. The alternative case release scenario involves damage to the pipe resulting in a < inch diameter opening and the release of high-pressure liquid ammonia. The scenario also includes a conservative estimate of the response time necessary to control the release. Using the equations in Chapter 4 of the EPA's RMP Guidance for Ammonia Refrigeration, the maximum distance to the specified "endpoi nt" was calculated. This is a conservative distance, established by the EPA, at which it is expected that a person could be exposed to the chemical for an hour without suffering irreversible health effects. The distance to the endpoint, calculated for the alternate case release scenario, includes offsite receptors. Accidental Release Prevention Program To prevent and mitigate accidental releases of anhydrous ammonia, Sandridge has implemented several precautionary measures including process and equipment controls, operating procedures, preventive maintenance programs, employee training, and audit programs. In addition, the ammonia refrigeration system is designed and constructed in accordance with industry standards and good engineering practices. Sandridge has also developed and implemented a Process Safety Management program pursuant to OSHA regulations and as such, has evaluated the refrigeration system for the potential to release anhydrous ammonia. Some of the controls in stalled to prevent catastrophic releases of ammonia include process equipment (pressure relief valves, check valves, backup pumps, and manual shutoffs) and automated controls (automatic shutoffs, microprocessor control, ammonia leak detection systems, and electrical distribution system grounding). Sandridge has developed standard operating procedures for all employees and contractors that have contact with the ammonia refrigeration system. These procedures incorporate safety measures to prevent employee injury, equipment damage, and accidental releases. The procedures were developed by a team consisting of personnel from operations and maintenance, plant engineering, and Sandridge's PSM contractor. Pursuant to written management of change procedures established by Sandridge, any changes to the operating procedures are communicated to affected employees. Sandridge understands that maintaining the refrigeration system in good working order is essential to preventing accidental rele ases; therefore Sandridge has implemented a preventative maintenance program. The preventative maintenance program is scheduled, documented and managed to ensure that regular maintenance occurs on the system. Also, to ensure the mechanical integrity of critical refrigeration system components, equipment inspections are performed. To ensure that the control measures at Sandridge are effective in maintaining the safe operation of the plant, regularly scheduled audits are performed on the ammonia refrigeration system: 7 In accordance with the PSM program, Sandridge conducts detailed PSM compliance audits every three years. Each audit incorporates review of process safety information, process hazard analysis, operating procedures, training programs, system mechanical integrity, management of change, pre-start up safety review procedures, compliance audit procedures, incident investigation procedures, employee participation programs, hot work permit procedures, and contractor safety pr ocedures. 7 In addition, the facilities and records of Sandridge are inspected and audited by the following: 7 The City of Medina Fire Department 7 The Ohio State Department of Agriculture 7 The United States Department of Agriculture 7 The United States Food and Drug Administration 7 Sandridge's insurance carrier also conducts independent loss prevention audits every year. Five-Year Accident History Over the last five years of operation, Sandridge has not experienced an accidental off-site release of anhydrous ammonia from the refrigeration system. Emergency Response Program The Sandridge facilities are included in the written community emergency response plan developed by the Medina County Local Emergency Planning Commission (LEPC). In addition, Sandridge has developed an emergency action program designed to protect both employees and the community in the event of an ammonia release, fire, or other emergency. This program is fully described in a document entitled, "SANDRIDGE FOOD CORPORATION - EVACUATION AND EMERGENCY PROCEDURES". Included in the document are measures to be taken by Sandridge including emergency notifications, on-site and off-site coordination, ammonia release procedures and evacuation procedures. To ensure that local government response agencies are familiar with Sandridge's facility and their emergency response procedures, facility tours have been conducted with the following local agencies: 7 City of Medina Fire Department 7 Medina County Local Emergency Planning Commission In the event of an anhydrous ammonia release with the potential for off-site effects, the Medina County Local Emergency Planning Commission will be notified immediately. Any notifications and/or instructions to the general public shall be made by the Medina County LEPC and may include the following methods: 7 Door-to-door notification of residents, 7 Police and fire vehicles equipped with public address systems, and 7 Broadcast m essages via the Medina County Emergency Broadcast System, if necessary. Continuing Efforts to Improve Safety As part of Sandridge Food Corporation's continuous efforts to improve the performance of its safety systems, several changes are planned at the facility to improve safety and further reduce the potential for a release of anhydrous ammonia. These changes are scheduled to be implemented by the first quarter of 2001 and include equipment upgrades, additional preventive maintenance procedures, and additional safety systems. |