Edwards Baking Company - Executive Summary |
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See attached Baking Company RMP SUMMARY REPORT 1. Accidental Release Prevention and Emergency Response Policies We at Edwards Baking Company are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Frozen Pie Manufacturer. We have 1 regulated substances present at our facility. These substances include ammonia (anhydrous). Ammonia (anhydrous) is used for Refrigeration of Frozen Foods (Pies). The maximum inventory of Ammonia (anhydrous) at our facility is 40000.00 lb.. 3. The Worst Case Release Scenario(s) and the Alte rnative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To perform the required offsite consequence analysis for our facility, we have used the EPA's RMP Comp. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from Refrigeration System. In this scenario 10000 lb. of Ammonia (anhydrous) is released. The toxic liquid released is assumed to form a 1-cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. The released quantity has been limited to 25 % of the maximum capacity of the source by a system of administrative controls. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of .6 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. The alternative release scenario for Ammon ia (anhydrous) involves a release from Refrigeration System. The scenario involves the release of 2000 lb. . Toxic liquid is assumed to be released to form a 1-cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. The release is also assumed to be controlled by emergency shutdown system(s). These active mitigation systems have the effect of shutting down and controlling the system via a remote computer and specialized software. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.01 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. The following sections br iefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Edwards Baking Company maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is a group exercise conducting complete "What Ifs". The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval annually. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 5/15/00. Operating Procedures For the purposes of safely conducting activities within our covered processes, Edwards Baking C ompany maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Edwards Baking Company has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every year and more frequently as needed. Mechanical Integrity Edwards Baking Company carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Qualified perso nnel carry out maintenance operations with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Edwards Baking Company to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 5/15/00. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Edwards Baking Company. The most recent review was performed on 06/28/1998. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Edwards Baking Company conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted on 5/15/00. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Edwards Baking Company promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation Edwards Baking Company truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Edwards Baking Company has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Edwards Baking Company has had an excellent record of preven ting accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Edwards Baking Company carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Emergen cy Response procedures and training are some of the major steps we have taken to improve safety at our facility. These changes are expected to be implemented by June of 2000. |