Trenton Home Foods, Inc. - Executive Summary

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Introduction and History 
International Home Foods, Inc. purchased Trenton Home Foods, Inc. (THF) in September, 1998 from the Nestle corporation. THF is a meat and cheese canning, thermal processing facility. THF is under USDA inspection due to the meat ingredients used in processing. The storage of various meats requires THF to operate and maintain coolers and freezers, a two-stage ammonia refrigeration system. 
Since the acquisition, International Home Foods, Inc. (IHF) purchase of THF from the Nestle Corporation,  significant management changes have occurred. In the fall of 1999, THF performed an internal safety audit, at which time documentation quantifying ammonia was requested. This documentation was not available at that time. Immediately, a Process Safety Management (PSM) consultant was contacted, and ammonia was quantified.  
The present ammonia system was found to exceed the threshold quantity per 29 CFR 1910.119, Appendix A. From that point on, intense efforts have been focu 
sed on complying with OSHA and EPA. The consultant, Bill Rodman CSP & Associates of Greeley, Colorado, has been contracted to assist THF in complying with all applicable federal, state, and local regulations. Bill Rodman, CSP is a refrigeration expert, PSM consultant, and  teaches Process Safety Management at the OSHA Institute in Red Rocks, Colorado.  
Rodman & Associates performed a preliminary audit of THF in November, 1999. The audit was based on OSHA Instruction CPL 2-2.45A, Ch-1, dated 09/13/94. The study was customized and supplemented with additional questions to employees to assure that all areas were thoroughly covered. The audit was conducted by a Certified Safety Professional trained in Process Safety Management. The audit revealed that the existing ammonia refrigeration system had improvements made to the system, and that it shows signs of proper operation and maintenance. Calculations determined that the ammonia inventory exceeded the threshold of 10,000 pounds. Based on  
the calculations, it was determined that the ammonia system met the requirements of the PSM and RMP standards. 
Accident Release Prevention Program and Emergency Response Policy  
It is the policy of the THF facility management to implement the requirements of this Risk Management Program (RMP) in accordance with the United States Environmental Protection Agency (EPA) regulations under 40 CFR Part 68 and with the corresponding regulations under OSHA's Process Safety Management (PSM) program. The objective is to minimize the risk of a release of a hazardous material and if a release occurs, to minimize the potential impact to THF employees, the public and the environment. This objective will be accomplished by utilizing general good operating procedures, providing appropriate training to all employees, and coordinating response activities, as necessary, with the local emergency response providers. THF management is committed to providing the resources necessary to implement this policy 
Facility Description 
THF operates a food processing operation at this facility. Vienna sausage is the main product produced by THF at this facility. Operations at the facility include food processing machinery and a number of coolers and chillers.  Ammonia is used as a refrigerant throughout the facility. 
Worst-Case and Alternative-Case Release Scenarios  
RMP regulations require that each facility complete worst-case and alternative-case release scenarios. EPA has defined a worst-case toxic release as the release of the entire contents of the largest vessel that contains a regulated substance in a 10-minute period. This release rate is then evaluated using modeling techniques and/or reference tables to define the distance to a specified endpoint (concentration or overpressure). The distance to the endpoint is affected by several factors including molecular weight, volatility, heat of combustion, and physical setting (urban or rural). The alternative-case release scenario for ea 
ch covered process must be one that is more likely to occur than the worst-case scenario and that reaches an endpoint offsite, unless no such scenario exists. The alternative release scenario is evaluated using the same techniques as the worst-case scenario to define the distance to the specified endpoint. Under 40 CFR 68 Subpart B '68.22(e), the RMP rule identifies surface roughness as a parameter to be used in the hazard assessment to determine the physical setting of the site, urban or rural. "Urban means there are many obstacles in the immediate area; obstacles include buildings or trees. Rural means there are no buildings in the immediate area and the terrain is generally rolling and obstructed." Trees, hills, and/or other structures are located in the immediate vicinity of the Trenton, Missouri facility; therefore, an urban dispersion environmental was assumed. 
The data provided in the document "Model Risk Management Program and Plan for Ammonia Refrigeration" (May 19 
96) was used to estimate the toxic endpoint distance for the worst-case and alternative-case ammonia release scenarios. The EPA's "RMP Off-site Consequence Analysis Guidance" (May 1996) was not used to determine the toxic endpoint since it classifies ammonia as a "neutrally buoyant gas." The worst-case ammonia release scenario would involve liquid and would come from a pressurized liquid system; therefore, the released gas should be classified as a "dense gas" (a result of evaporative cooling). The ammonia refrigeration document provides calculated endpoint distances for typical meteorological conditions.  
The worst-case release scenario for an anhydrous ammonia release is a release of all the contents of the high-pressure receiver tank in a 10-minute period (per EPA guidelines). This release translates to a release of 10,100 pounds of ammonia in 10 minutes or 1,010 lbs./min. Other assumptions included in the worst-case assessment are: the ammonia is a liquefied gas; the receiver tank 
is not diked; the nearfield dispersion environment is characterized as rural; 10-minute averaging period; the wind speed is 1.5 meters/sec and the atmospheric stability is classified as F (stable). The results of the worst-case scenario for an ammonia release shows that the plume must travel 0.4 miles (0.64 kilometers) before dispersing to the endpoint concentration of 200 PPM. 
The results of the alternative-case release scenario for an ammonia release indicate that the endpoint concentration of 200 PPM is reached at 0.1 mile (0.16 meters) from the release point.  
General Accidental Release Prevention Program and Chemical Specific Prevention Steps  
The Trenton, MO facility is governed by a set of OSHA and EPA regulations that require planning and facility activities intended to prevent a release of hazardous material, or if a release inadvertently occurs, to minimize the consequences of a release to the employees of the facility, the public and to the environment. These regulations 
? 40 CFR Part 68, Accidental Release Prevention 
? 40 CFR Part 112, Spill Prevention, Control and Countermeasure  
? 40 CFR Part 122, National Pollution Discharge Elimination System 
? 29 CFR Part 119, Process Safety Management 
? Section 302, Emergency Planning and Community Right-to-Know Act 
The key concepts in THF's release prevention program are employee participation, appropriate design and maintenance of equipment, and appropriate training of all employees. Employee participation in the release prevention program is encouraged and supported by THF's management. THF's management and key personnel are members of the PSM committee. Key personnel will be responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the ammonia system. THF has an Emergency Response Plan in place. THF's policy is to construct new equipment, systems, and facilities to ensure the appropriate safety and release prevention systems are included from the beginning 
of each project. THF is committed to providing appropriate training to all employees regarding safety procedures. Each new employee is provided comprehensive safety training during his or her initial orientation for the facility. In addition, THF conducts regularly scheduled safety training for all employees each year. Additional training is provided to maintenance personnel for the systems they are responsible for. 
Five Year Accident History  
THF has not had a reportable release of ammonia from the Trenton, Missouri facility that has affected the public or the environment within the last five years.  
Emergency Response Program 
THF has personnel trained in emergency response at the facility 24 hours per day, 7 days per week. These personnel receive annual training on emergency procedures and response techniques, including training that incorporates emergency drills. In the event of an ammonia release, refrigeration personnel would shut off the liquid return which is located on th 
e roof, and shut down all compressors and pumps from a remote location. 
Planned Changes to Improve Safety 
THF completes a thorough review of the ammonia system each time a design change is implemented. THF is committed to using these methods to identify and implement ways to improve the safety of the system. The proposed PSM committee will be involved with any development and modification of Standard Operating Procedures (SOPs), Process and Instrumentation Diagrams (P&IDs), and the Emergency Response Plan. Currently, the proposed PSM committee will incorporate changes to the PSM. Daily logs of equipment inspections and tests that are conducted will be filed in the maintenance office for easy access.
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