Sysco Food Services of Arkansas, LLC - Executive Summary |
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General Executive Summary for Manufacturing: 1. Accidental Release Prevention and Emergency Response Policies: We at Sysco Food Services of Arkansas, LLC are 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. Unforeseeably, if such as release does occur, our highly trained employees are on hand to control and mitigate the effects of the release. We are also completely coordinated with the Little Rock Fire Department, who provides our emergency response services. 2. The Stationary Source and the Regulated Substances Handled: We have one regulated substance present at our facility. This substance is Ammonia (anhydrous). The maxim um inventory of Ammonia (anhydrous) that is expected to be present in this facility, based on process/operational requirements is 13,500 pounds. 3. The Worst Case Release Scenario and the Alternative Release Scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario: To perform the required off-site consequence analysis for our facility, we have used the look-up tables and equations provided by the EPA in the RMP Off-site Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. Toxic Worst Case Analysis: The Worst Case scenario involves a catastrophic release from the Sysco Food Services of Arkansas, LLC Ammonia (anhydrous) system. The scenario involves a release of 13,500 lb. of Ammonia (anhydrous) in a gaseous form over 10 minutes. The release rate (lbs/min) is calculated to be 1,350 and a distance to endpoint of .7 miles is obtained which effects a residential population of 305 6 within this distance. Toxic Alternative-Case Analysis: The Alternative-Case Analysis involves a catastrophic release from Sysco Food Services of Arkansas, LLC Ammonia (anhydrous) system. This scenario involves the release of 1700 lb. of Ammonia (anhydrous) in a gaseous form over 10 minutes. The release rate (lbs/min) is calculated to be 170 and a distance to endpoint of .1 miles is obtained which effects a residential population of 43. There are no Flammables Worst-Case or Alternative-Case analysis for this facility. 4. The General Accidental Release Prevention Program and the Chemical Specific Prevention Steps: Our facility has taken the following steps as required by 40 CFR Part 68 of the EPA. Our Ammonia (anhydrous) process is subject to the OSHA PSM Standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 reporting requirements. The following sections briefly describe the elements of the release prevention program that is in place for our facil ity. Process Safety Information: Sysco Food Services of Arkansas, LLC maintains a detailed record of safety information that describes the chemical hazards, operating parameters, and equipment designs associated with the process. Process Hazard Analysis: Our facility conducts comprehensive studies to ensure that hazards associated with our process are identified and controlled efficiently. The methodology used to carry out these analysis is the What-if Checklist. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of every three years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures: Sysco Food Services of Arkansas, LLC maintains written operating procedures. These procedures address various modes of operation such as initial start-up, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and start-up aftern a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the process. Training: Sysco Food Services of Arkansas, LLC 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. New employees receive basic classroom training in process operations, followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided at least annually and more frequently as needed. Mechanical Integrity: Sysco Food Services of Arkansas, LLC carries out highly documented maintenance checks on process equipment to ensure proper operation. Process equipment examined by these checks includes: pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are given 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 Sysco Food Services of Arkansas, LLC to manage changes in process chemicals, technology, equipment and processes. Process operators, maintenance personnel, or any other employees whose job tasks are affected by a modification in process operations are promptly made aware of and given training to deal with the modifications. Pre-Startup Reviews: Pre-startup safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Sysco Food Services of Arkansas, LLC. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe start-up prior to placing equipment into operati on. Compliance Audits: Sysco Food Services of Arkansas, LLC conducts audits on a regular basis to determine whether the provisions set out under the RMP Rule are being implemented. These audits are carried out at least every three years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation: Sysco Food Services of Arkansas, LLC 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 recurring. All reports are retained for a minimum of 5 years. Employee Participation: Sysco Food Services of Arkansas, LLC believes that process safety management and accident prevention are a team effort. Company employees are strongly urged to express their views concerning accident prevention issue s 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 analysis 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 the contractor's safety performance is carried out. Sysco Food Services of Arkansas, LLC has a strict policy of informing contractors of known potential hazards related to the contractor's work and the process. Contractors are also informed of all the procedures for emergency notification and evacuation, should an accidental release of a regulated substance occur. 5. 5-Year Accident History: Sysco Food Services of Arkansas, LLC has documented three accidental releases of Ammonia (anhydrous), during the last five years. An accident occurred on 7/20/1999. A total of 3,500 p ounds of Ammonia (anhydrous) was released over a 3 hour period. There were no injuries to personnel, on or off site, as a result of this accident. An accident occurred on 2/26/1999. A total of 3,500 pounds of Ammonia (anhydrous) was released over a 3 hour period. There were no injuries to personnel, on or off site, as a result of this accident. An accident occurred on 9/4/1996. A total of 3,998 pounds of Ammonia (anhydrous) was released over a 2 hour period. There were no injuries to personnel, on or off site, as a result of this accident. 6. Emergency Response Plan: This facility is included in the written community ER plan. This facility has it's own written ER plan. The ER plan includes specific actions to be taken in response to accidental releases of regulated substances. The ER plan includes procedures for informing the public and local response agencies of a chemical release. The ER plan includes information on emergency health care. Date of most recent review/upd ate of ER plan: 3/01/2000 Date of most recent ER training of employees: 4/10/2000 The local agency coordinating the facility ER plan is the Pulaski County LEPC. Their phone number is (501) 555-5555 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. We will continue regular reviews of the Ammonia (anhydrous) equipment and procedures. We will continue annual notification and evacuation drills and pre-planning with the Little Rock Fire Department and Hazardous Materials Team. |