J. R. Simplot Company - Hermiston Plant - Executive Summary |
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This is to inform all interested persons, including employees that the J.R. Simplot Company Hermiston Oregon facility is complying with OSHA's Process Safety Management Standard (called Process Safety Management or PSM), Title 29 Code of Federal Regulations (CFR) 1910.119, and EPA's Risk Management Program regulations (called RM Program), Title 40 CFR Part 68, to deal with the risks involved with the storage, handling, and processing of hazardous chemicals. In this way we promote overall plant, worker, and public safety. These programs 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, injuries and illnesses and avoid physical property damage. 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 which 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. J.R. Simplot Company operates a potato products manufacturing facility in Hermiston, Oregon. The only chemical that was 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. The RM program for the Hermiston Facility, which is separately documented in detail, consists of the specific elements listed below. Manage ment Plan The facility has a system in place to manage the implementation of the RM program elements. The Unit Director is the designated facility RM Program Manager and therefore has the overall responsibility for the Hermiston facility RM Program. As Unit Director this individual has the authority to assign company resources to develop, implement, update, and integrate all applicable RM program elements at the Hermiston facility. The Unit Director/RM Program Manager has assigned a RMP/PSM Sponsor to ensure that the RM Program is developed, implemented, and updated in compliance with the RM Program regulations. The RMP/PSM Sponsor, an Environmental Manager for the Simplot Hermiston facility, has the everyday responsibility of ensuring the RM Program is in compliance with the RM Program regulations and that the RM program is updated as necessary. The RMP/PSM Sponsor is supported by the RMP/PSM Team which is comprised of utility supervisors, operators and staff level personnel. Th e RMP/PSM Team shares the final responsibility for the development and implementation of the RM Program. The RMP/PSM Sponsor reports to the RM Program Manager and receives direction and support from the Vice President of Environment and Regulatory Affairs and the Division Safety Manager. The Unit Director/RM Program Manager reports to division management. The 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 ARP 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, and was most recently updated in the second quarter of 1999. Key provisions of the facility release prevention program are as follows: ? Employees who operate these systems must receive training initially and periodically on safe startup/shutdown, operations, and emergency shutdown of the processes. ? Release incidents are investigated, and the results are used to improve the safety of the process. ? The ammonia refrigeration system is maintained through the mechanical integrity program, which minimizes the risk of accident and maximizes process safety. ? Results of incident investigations are also shared with employees who could be affected by the process. ? 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. ? The facility has a management of change (MOC) program in place that mandates that changes to the ammonia system are reviewed prior to implementing the change to ensure that the change would not compromise safety. ? A pre-startup review is also completed after a major change and prior to a new process coming on line. ? A hot work (spark producing) permit program is in place. ? Contractors who are hired to work on or near the regulated processes must have adequate training on the hazards prior to starting work. Five Year Accident History Offsite consequence analyses need to consider the release history of each process. In the past five 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. Modeling proc edures followed EPA guidance to identify worst case release scenarios (WCS) and alternate case release scenarios (ACS) as defined by the ARP 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 in the ammonia system are released in a 10-minute period. The largest vessel contains 23,000 pounds of ammonia. This vessel is inside of the refrigeration building. Since this building is ventilated and has doors and windows the more conservative passive mitigation factor used in RMP*Comp for enclosures was assumed. Under worst case weather conditions, the modeled WCS release would result in an endpoint radius of 2. 2 miles. The number of offsite permanent residents located inside the radius (centered on the release point) was then estimated by a field survey and using EPA's Landview III software (Version 1.0) to determine the census based average residents per household. The estimated potentially affected offsite residential population is 270 persons. This estimate does not include non-residential persons that could be located within the endpoint radius (i.e. workers, etc.). ACSs were evaluated following EPA and IIAR guidelines. The ACS that resulted in the longest distance to the endpoint was selected for presentation in this document and for reporting to EPA. The selected ACS consists of an ammonia transfer hose tear. This release occurs outdoors adjacent to the Line 4 Freeze Tunnel; therefore, no passive mitigation was assumed. The estimated release of liquid ammonia is 250 pounds per minute for a maximum of 8 minutes (2000 pounds total - the maximum transfer tank storage volume). Unde r common weather conditions, the calculated release rate to the environment from this accident scenario results in an endpoint radius of 0.3 miles. There are no residences located within this endpoint radius. This estimate does not include non-residential persons that could be located within the endpoint radius (i.e. workers, etc.). 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 The emergency response program at the Hermiston facility is initiated by Simplot personnel who are all trained to recognize ammonia releases and immediately inform the Safety Department. Employees contact Department and/or the Boiler/Refrigeration Control Room by phone or radio. Simplot personnel not having access to phones or carrying radios who notice a release are to clear the area immediately and notify their supervisor, or others who have access to phones or radios so they can inform the Safety Department and/or the Boiler/Refrigeration Control Room. This facility's emergency response program is based on the OSHA requirements for Emergency Action Plans (29 CFR 1910.38 and 1910.119) and we maintain a written emergency response plan. This plan is coordinated with the Local Emergency Planning Committee (LEPC) 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. J.R. Simplot will update this submittal every five years, or sooner if necessary, based on RM program regulation requirements or process modifications. |