Beatrice Cheese, Inc. - Executive Summary |
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Introduction The Beatrice Cheese, Inc. facility located in Fredericksburg, Iowa is a subsidiary of the Con Agra Corporation. The facility produces cheese products in various forms. As part of the cheese making process, both heating and cooling of ingredients and process areas is required. Cooling is achieved through the use of an ammonia refrigeration system. The system feeds ammonia to brine and glycol heat exchangers, coolers, freezers and jacket-cooled silos. Ammonia contained within the refrigeration system is a regulated substance under both the EPA and OSHA regulations. At Beatrice Cheese the maximum inventory of ammonia exceeds the regulatory threshold of 10,000 pounds. Beatrice Cheese is committed to protecting the public, its employees, and the environment from any accidental releases of hazardous materials used at its facilities. We have implemented safety, environmental protection, and risk management programs to prevent hazardous materials releases. If there is a n accidental release, we will immediately call for emergency response to minimize the effect of the release and notify the public of any actions necessary to ensure public protection, through the Waterloo Hazmat team. Worst-Case Release Scenario Beatrice Cheese, Fredericksburg, Iowa facility has conducted an offsite consequence analysis as required by the regulations, including an extremely unlikely, worst-case release scenario (i.e., total release from the single largest container over a ten minute period, assuming worst case meteorological conditions). Results of this worst-case event indicate that offsite receptors would be affected. A release represented by this worst-case scenario is extremely unlikely because of the design of system components (they are designed to withstand pressures well in excess of normal operating conditions) and the rigorous maintenance and prevention programs in place at the Beatrice Cheese facility. In fact, EPA release reporting databases and indus try experience suggest that the worst-case release scenario as defined in the RMP regulations is so unlikely that it should not be used as the basis for emergency planning. A more reasonable potential release scenario for emergency planning is presented in "The alternative release scenario(s)" section below. Alternative Release Scenario A "credible" alternate release scenario was formulated in accordance with USEPA guidance. This scenario involves the postulate of a one inch diameter hole in piping on the roof of the facility (liquid return line from condenser). This warm ammonia will readily vaporize and was modeled using EPA RMP guidance and modeled using RMP Comp. Results of this credible alternative event indicate that offsite receptors would be affected. The results of the process hazard analysis (PHA) and the facility's operating history suggest that even this credible alternative scenario is extremely unlikely to occur, but it can serve as the basis for emergency plannin g. Accidental Release Prevention Steps Con Agra is committed to public safety, personnel safety, continued reliable operation and regulatory compliance. Based on this commitment, the Plant Manager has assumed overall responsibility for the development and implementation of the Risk Management Program. The Plant Manager has also clearly defined accountability and responsibility for each of the prevention program elements to meet both EPA and OSHA Process Safety Management requirements. To ensure that a worst-case or alternative release scenario does not occur, the Beatrice Cheese, Fredericksburg, Iowa facility maintains a release prevention program with the primary focus of protecting the public and plant employees from the hazards associated with an accident or release involving ammonia. The multifaceted program includes the use of: Ammonia gas detectors and alarms to rapidly alert operators to any problems; Process safety information to document the safe process design; Proc ess hazards analyses to evaluate the chemical and process hazards; Operating procedures to ensure that the system is operated safely; Maintenance, inspection and testing to ensure that the system is maintained according to applicable standards and manufacturer's recommendations; Training, Hot Work Permits, Contractor Safety, and Employee Participation Programs to ensure that all employees and contractors working on and around the processes are aware of the hazards, can perform their job duties safely and know the actions to be taken in an emergency; Management of Change and Pre-startup Safety Reviews to ensure that changes are documented, analyzed and kept within the design basis; Incident Investigation procedure to investigate each incident and "near misses" to determine root causes and make needed safety improvements; and, Periodic Compliance Audits to ensure that our programs are working as they should to protect both the public and employees. Five-Year Accident History Wit hin the past five years, the Beatrice Cheese, Fredericksburg, Iowa facility has not had any accidental releases that resulted in injuries or property damage. The plant has maintained an excellent safety record throughout its operating history and has never had a major ammonia release that could have had adverse effects on the public. Emergency Response In the event that a ammonia release does occur, the Beatrice Cheese facility has an emergency response program that coordinates emergency response with the Waterloo Hazmat team. If such a release did occur, plant personnel would contact Waterloo Hazmat who would dispatch specially train personnel to the facility. Maintaining A Safe Operation The Beatrice Cheese continually works to safely manage the hazards of ammonia to protect the community we serve and the employees working for us. The Risk Management Program will be maintained to reduce the risk of accidental releases and each year we will conduct training, review procedures, maintain the equipment and follow safe work practices. Periodically, we will audit our program, review our Process Hazard Analysis, coordinate with the community emergency response organization, and will update our procedures, processes, and practices as needed to assure safe and efficient control and management of the plant. |