Fleischmann's Yeast - Executive Summary

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This document contains all required information in order to meet 40 CFR 68 "Risk Management Program".  This document consists of the executive summary and registration data elements (68.155 through 68.185). 
 
10.1    RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 
 
The Fleischmann's Yeast facility in Oakland, California has a good record in preventing releases of anhydrous* ammonia.  As part of their release prevention program, the plant has an excellent operator-training program and preventive maintenance "Microsoft Access Program" on the PM system.  More information about these aspects of the prevention program is discussed in Section 4.0 of this Executive Summary. 
 
The facility has implemented an Emergency Action Plan, which ensures the safety of its employees', the community and the environment.  This detailed emergency action plan includes procedures for handling an emergency - the established action plan and contacting appropriate outside personnel involved in containing an amm 
onia release - Emergency Response Team (HAZMAT).  As part of this program, there is emergency response training and medical surveillance of the HAZMAT team prior to and after an incident.  All of these components make the Emergency Action Plan a thorough and comprehensive plan for release prevention and emergency response. 
 
The emergency response policies at the Fleischmann's Yeast facility ensure that there is emergency response coverage 24 hours - 7 days per week.  There are also provisions for coordination of the Emergency Action Plan with numerous outside agencies including the Alameda County Hazmat Division and the Oakland Fire Department in the event of an emergency.  Any updates to the Emergency Action Plan are provided to all the agencies with which the plan is coordinated. 
 
10.2     PROCESS DESCRIPTION AND REGULATED SUBSTANCES 
 
Fleischmann's Yeast is a producer of baker's yeast and vinegar.  The NAICS codes for the processes at this facility are 311999 and 311941.   Many areas 
of the plant are refrigerated to preserve food products.  
 
Fleischmann's Yeast has two regulated substances under 40 CFR 68: anhydrous ammonia and 30% aqueous ammonia.  The anhydrous ammonia is used as a refrigerant in the refrigeration of the products in the plant, while aqueous ammonia is used as a process feed (nutrient for making yeast). 
 
The anhydrous and 30% aqueous ammonia thresholds for triggering the applicability to 40 CFR 68 are 10,000 and 20,000 pounds, respectively.  The quantity of anhydrous ammonia stored at the facility is 15,692 pounds, while the quantity of aqueous ammonia stored at the facility is 163,180 pounds.  Both processes exceed the threshold quantities of 10,000 and 20,000 pounds as set by 40 CFR 68 and thus are regulated by the Risk Management Program. 
 
10.3     WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS 
Worst-Case Scenario Description 
 
The largest potential release of ammonia would occur with a puncture in the liquid portion of the high pressure receiver 
.  Taking the specific definition of the worst-case from 40 CFR 68.25, the largest quantity of ammonia that can be stored in a vessel is in the high-pressure receiver during a pump out condition.  The total quantity of ammonia that can be stored in high-pressure receiver is 4,378 pounds, without administrative controls.  Since the facility is located in a populated are, the toxic cloud formed by the evaporating ammonia would reach offsite endpoints and nearby receptors. 
 
Anhydrous Ammonia Alternative Release Scenario Description 
 
The alternative release scenario for anhydrous ammonia is the release from a liquid line that is ruptured when a truck runs into the ground support.  The liquid line is located outside the northeast side of the vinegar plant at 15 feet above ground level.  Administrative controls are not applicable to this scenario.  Active mitigation of the release is human intervention (isolation of this section of piping).  Since the facility is located in a populated are 
a, the toxic cloud formed by the evaporating ammonia would reach offsite endpoints and nearby receptors.   
 
30% Aqueous Ammonia Alternative Release Scenario Description 
 
The alternative release scenario for 30% aqueous ammonia is the overfilling of the ammonia storage tank during routine filling.  The tank has the capacity to hold 19,566 gallons of 30% concentration aqueous ammonia, however, for this case the tank is normally half-full.  It is assumed that the operator walks away from the pump truck or falls unconscious during the time of filling, which allows the entire contents of the truck to be pumped into the storage tank.  In this scenario the maximum amount of aqueous ammonia that could spill out of the tank is 1,200 gallons (10,000 lbs).  Administrative controls are not applicable to this scenario. A 34' x 24.5' dike has been constructed around the storage tank as a form of passive mitigation.  Since the facility is located in a populated area, the toxic cloud formed by the eva 
porating ammonia would reach offsite endpoints and nearby receptors.   
 
10.4      GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS 
 
Fleischmann's Yeast has developed an OSHA PSM program for their ammonia refrigeration system. At Fleischmann's Yeast, ammonia falls under the RMP Program 3 Prevention Program, which is identical to the OSHA PSM program.  EPA has said that if the process is in compliance with OSHA PSM, then it is compliance with RMP Program 3.  Thus, Fleischmann's Yeast ammonia PSM has been reviewed and determined to be complete for the RMP document.   
 
Listed below are key aspects of the ammonia prevention program: 
 
1. Most of the piping work is out of the way of people and machinery, which results in a less chance of an ammonia release.  
 
2. The plant maintains good training, certification and employee awareness of operating procedures. 
 
10.5     FIVE-YEAR ACCIDENT HISTORY 
 
The review of Fleischmann's Yeast accident history includes the 
following range of dates: December 1, 1993 - December 1, 1998.  According to 40 CFR Part 68.42(a), there have been no accidental releases at this facility. 
 
10.6     EMERGENCY RESPONSE PROGRAM 
 
As mentioned previously, the Fleischmann's Yeast facility has developed an emergency action plan that establishes general and specific procedures and responsibilities that in the event of  emergency will protect employees and minimize property damage.  This document was developed in accordance with 29 CFR 1910.38 and 29 CFR 1910.120(q). 
 
Fleischmann's Yeast Emergency Action Plan is a detailed document that discusses the role of employees and management in an emergency situation.  All emergency response personnel will successfully complete CPR/First Aid and emergency response training prior to assuming responsibilities.  The plan outlines specific procedures for general evacuations, fire/explosion, bomb threats, earthquakes, power outages and chemical spills.  Depending upon a given situation, t 
he Alameda County Hazmat Division as well as the Oakland Fire Department will be called to provide back-up emergency responders and equipment.   The Fire Department will be called for all fire-related emergencies.  The Emergency Coordinator has ultimate control of implementation of the emergency response plan. 
 
This document contains specific procedures for:  1)  coordination with outside authorities and communications; 2)  emergency notification procedures, evacuation instructions, personnel accounting procedures as well as notification of response groups; 3)  emergency medical treatment and first-aid; 4) chemical spills and releases (includes roles and lines of authority, emergency recognition and prevention, safe distances and places of refuge, and emergency equipment);  5)  evaluation and critique of response. 
 
10.7     PLANNED CHANGES TO IMPROVE SAFETY 
 
Based on the completed Process Hazard Analysis (PHA) for ammonia, a list of action items to improve safety was developed and thei 
r status was monitored to ensure that implementation was accomplished.  An example of safety improvements made at the plant is discussed below: 
 
1.  Upgraded emergency response plan to address impacts of the loss of utlities (power, cooling, instrumentation, etc.) on the ammonia refrigeration system; and 
 
2. All ammonia piping and equipment will be labeled; and 
 
3. The three ammonia high-pressure receivers are to be repainted.
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