Flowers Baking Company of South Carolina, Inc. - Executive Summary
Flowers Baking Company of South Carolina has completed a Management of Change on July 18, 2000. In that MOC, the following equipment was added to the facility: |
Six (6) coils, Imeco model 66PW x 10 RD x 220" FL,
One (1) evaporator, Krack model DTX2S-680-RBA-HGU
Relocated evaporator #9
Associated piping will also be removed or added as required.
The ammonia charge to the refrigeration system was not affected, however, several dates in the Risk Management Plan have been revised. This is a resubmission of the Risk management Plan for Flower's Baking of South Carolina.
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
At Flowers Baking Company of South Carolina, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning pro
grams to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including:
* A description of our facility and use of substances regulated by EPA's RMP regulation
* A summary of results from our assessment of the potential offsite consequences from accidental chemical releases
* An overview of our accidental release prevention programs
* A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule
* An overview of our emergency response program
* An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment
* The certifications that EPA's RMP rule requires us to provide
* The detailed information (called data elements) about our risk management progra
STATIONARY SOURCE AND REGULATED SUBSTANCES
Our facility produces various pastries and pies using a variety of chemicals and processing operations. In our processes, we use the following toxic chemical that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release:
Anhydrous ammonia is used as a refrigerant in our facility to cool our warehouse, shipping areas and freezers. Approximately 18,000 pounds of ammonia are on-site in the refrigeration process, including: high pressure receiver vessels, compressors, recirculators, associated piping, pumps, heat exchangers, and evaporators.
Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals.
KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS
EPA's RMP rule requires that we provide information about th
e worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario:
Worst-case Release Scenario(s) - Regulated Toxic Chemicals
The anhydrous ammonia falls under Program 3 requirements. Failure of our largest ammonia vessel would be the worst case scenario for our facility. That recirculator vessel is inside our building. In a worst case scenario, approximately 13,000 pounds of anhydrous ammonia could be released in 10 minutes. Using EPA offsite consequence analysis (OCA) lookup tables, such a release could reach receptors 1.4 miles (7,400 feet) from the plant before dispersing enough to no longer pose a significant hazard (0.14 mg/l or 200 ppm ammonia) to the public. Based on the 1990 U.S. Census and LandView III mapping software, approximately 5,138 people live within 1.4
miles of our facility. Within that distance are residences, businesses, schools and churches.
Alternative Release Scenario(s) - Regulated Toxic Chemicals
The alternative release scenario for our facility is based on a more likely event than the worst case scenario. We have assumed an outdoor relief valve (for example, near an evaporative condenser) opens (lifts) and the release goes undetected for 10 minutes before employees manually isolate the problem. The potential release of 600 pounds of ammonia gas results in a distance to toxic endpoint (0.14 mg/l or 200 ppm) at 0.19 miles (1,000 feet). This distance is determined using the EPA OCA lookup method. There were approximately 142 people living within that distance of our facility according to he 1990 U.S. Census for Spartanburg County and using LandView III mapping software.
We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable conting
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including:
* Process safety information
* Process hazard analysis
* Operating procedures
* Mechanical integrity
* Management of change
* Pre-startup review
* Compliance audits
* Incident investigation
* Employee participation
* Hot work permit
As part of our prevention efforts, we have implemented the following chemical-specific prevention step:
1. Scheduled preventive maintenance for ammonia refrigeration equipment.
These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we
have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention.
FIVE-YEAR ACCIDENT HISTORY
We keep records for all significant accidental chemical releases that occur at our facility. There have been no accidental chemical releases involving materials covered under EPA's RMP rule during the past five years.
EMERGENCY RESPONSE PROGRAM
We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan.
PLANNED CHANGES TO IMPROVE SAFETY
The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases:
Based on the criteria in 40 CFR 68.10, the distance to the specified endpoint for the worst-case accidental release scenario for the ammonia refrigeration process includes public receptors.
For all other covered processes, the undersigned also certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the other information submitted in this RMPlan is true, accurate, and complete.
RMP DATA ELEMENTS
The following pages present additional information about our risk management program that EPA's RMP rule has asked us to provide. This information is categorized as follows:
* Offsite consequence analysis
* Five-year accident history
* Program 3 prevention program
* Emergency response program