Klement's Sausage Company - Chase Avenue Plant - Executive Summary |
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Klement's Sausage Company (KSC) is a processor of meats for wholesale and retail sale. The main office is located at 207 East Lincoln Avenue, Milwaukee, Wisconsin. The subject facility covered by the Risk Management Plan (RMP) is located at 2650 South Chase Avenue in Milwaukee, Wisconsin. The subject facility encompasses approximately 137,513 square feet which is divided internally into the following areas: hallways, shipping and receiving docks, fresh sausage kitchen, holding coolers, freezer, packaging, fresh sausage cooler, dry storage room, smoking and cooking room, stuffing department, smoke kitchen and raw meat cooler. KSC has adopted this RMP program in order to implement the requirements of the Environmental Protection Agency (EPA) under the Clean Air Act Amendments (CAAA). This RMP is required under 40 Code of Federal Regulations (CFR), Part 68-Chemical Accident Prevention Provisions, because KSC uses more than 10,000 lbs. of anhydrous ammonia (NH3) which is the threshold quantity. The RMP will identify the process, the worst case and alternate scenarios, five-year accident history, process safety information, process hazard analysis (PHA), operating procedures, training, mechanical integrity, management of change, pre-startup review, compliance audits, incident investigations, employee participation, hot work permit and contractors to enable all those who may be affected to be able to identify and understand the hazards posed by the processes that involve NH3. The RMP will be regularly reviewed and updated whenever necessary to reflect new or modified tasks and procedures. In conjunction with the PHA, KSC completed a compilation of written process safety information in order to enable KSC supervisory personnel and KSC employees who operate the equipment which affects the refrigeration system to identify and understand the hazards posed by NH3. Material Safety Data Sheets (MSDSs) for NH3 as well as oil, chemicals and coolants were included. NH3 is the chemical formula for ammonia which exists as a gas at room temperature and atmospheric pressure. NH3 is considered to be a nonflammable gas by the Department of Transportation (DOT) and consists of 99.5 percent (%) of grade C (industrial grade) anhydrous ammonia, 0.4 % water and 0.1 % oil. NH3 has, for most people, a noticeable odor at 20 parts per million (ppm). NH3 is moderately irritating to the nose at approximately 100 ppm and causes major throat irritation at approximately 400 ppm. Ammonia gas can be compressed into a liquid. Liquid ammonia is a corrosive material which causes burns and is harmful if swallowed. NH3 is reactive with the halogens (chlorine and bromine). NH3 is also reactive with heavy metals and their salts (silver, mercury and gold) to produce shock sensitive materials which when dry tend to explode. NH3 is thermally stable as a gas and as a liquid. However, when not confined, the NH3 will evaporate. NH3 is reactive with many organic materials i ncluding acids, acid chlorides, halogens, acid anhydrides, oxidizing agents, chloroformates, galvanized iron, zinc, copper and tin and their alloys and, therefore, is not a stable materials when in contact with other substances. Ammonia is most stable when confined in steel containers. The chemistry of NH3 in KSC's refrigeration system is a conversion of liquid ammonia to gaseous ammonia and back to liquid ammonia. Liquid NH3 is pumped through the system, the NH3 evaporates as it becomes hot (absorbs heat), is converted back to a liquid by compression through the desuperheater and condenser and is pumped into the high temperature receiver to repeat the process. The maximum inventory in the system is approximately 12,100 pounds of NH3. The steel tank in the equipment room is designed to contain approximately 7,800 pounds of NH3 at 90% capacity. The refrigeration system (tank and piping) can contain more ammonia; however, the total quantity of ammonia in the system is administrati vely controlled at approximately 12,100 pounds. KSC has assembled a team with expertise in engineering and process operations to perform the process hazard analysis (PHA) hazard evaluation required by the standard. At least one member of the team is knowledgeable in the specific process hazard analysis methodology being used. The team also includes at least one employee who has experience and knowledge specific to the process being evaluated. KSC has developed and implemented written operating procedures for the tasks that KSC personnel perform (compressor service oil change, drain oil traps, switch liquid pumps, service cooling tower screens and nozzles, add oil to compressors and liquid pumps, add chemicals to cooling tower and clean purger). Contractors which perform other maintenance and repair activities will familiarize themselves with KSC's system and prepare operating procedures for their activities. KSC's procedures do, and their contractor's operating procedures will, p rovide clear instructions for safely conducting activities involved in each process. Operating procedures have been prepared for initial startup, normal operation, temporary operations as the need arises, emergency operations, including emergency shutdowns, and authorized personnel to initiate these procedures, normal shutdown and startup following a turnaround, or after an emergency shutdown. Each employee presently involved in a process has been, and each employee before working in a newly assigned process, will be trained in an overview of the process and in the operating procedures. The training will include emphasis on the specific safety and health hazards, and procedures and safe practices applicable to the employee's job tasks. When selecting a contractor, KSC will obtain and evaluate information regarding the contract employer's safety performance and programs. Whenever KSC establishes new facilities or modifies facilities for which the modification necessitates a change in the process safety information, KSC will perform a pre-startup safety review. A permit will be required for all hot work operations. All contemplated changes to a process must be thoroughly evaluated in order to assess their potential impact upon the safety and health of employees and to determine what modifications to operating procedures may be necessary. KSC has therefore established written procedures to manage those changes to process chemicals, technology, equipment, procedures and facilities that affect a covered process. Those procedures will not, however, cover "replacements in kind." Written procedures to manage changes to the process were developed and will be adhered to. All incidents will be investigated that have either resulted in a catastrophic release of a highly hazardous chemical in the workplace, or could reasonably have so resulted. Each such incident investigation will be initiated as promptly as possible, but not later than 48 hours following the incid ent. KSC has established an incident investigation team to thoroughly investigate and analyze each such incident. The members of the investigation team will include at least one person knowledgeable in the process involved, including a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience. The investigation team must prepare a report at the conclusion of the investigation. KSC will establish a system to promptly address and resolve the incident report's findings and recommendations. All corrective actions and resolutions that are taken in response will be documented. The report of the investigation team will be reviewed with all affected personnel whose job tasks are relevant to the incident findings, including contract employees where applicable. All incident investigation reports will be retained for five years. KSC has established an Emergency Action Plan for the entire plant in accordance with the prov isions of 29 CFR ?1910.38(a), the OSHA standard that provides for the adoption of an Emergency Action Plan. KSC's Emergency Action Plan also includes procedures for handling small releases. Large releases will be addressed by the Milwaukee Count Sheriff's Emergency Division. The RMP Program is designed to be a written statement of overall company process safety management and risk management rules and policies. There are a number of additional work rules, procedures, requirements, documents, reports, and separate programs that apply in particular situations or that are required by particular laws or regulations (for example: hazard communication/right-to-know). Some of them are in writing and some are not. Others will be added from time to time in the future whenever required by applicable local, state or federal law or regulation or when deemed necessary by the company. All employees of the company must observe those rules and programs just as they are required to observe the provisions of this Program. |