H.C. Brill Company, Inc. - Executive Summary

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Executive Summary 
1.    Accidental Release Prevention and Emergency Response Policies 
We at H.C. Brill Company, Inc. 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 a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release.  We are also completely coordinated with DeKalb County Department which provides additional emergency response expertise. 
2.    The Stationary Source and the Regulated Substances Handled 
Our facility's primary activities revolve around the production, storage and shipping of bakery products.   
Anhydrous ammonia is t 
he only regulated substance present at our facility.  All of the ammonia inventory is attributed to its use as a refrigerant. 
The maximum inventory of ammonia at our facility is 24,748 pounds. 
3.    The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario 
To evaluate the worst case and alternative release scenarios for ammonia we have used the methodology given in the Model Risk Management Program and Plan for Ammonia Refrigeration by SAIC.  The following paragraphs provide details of the chosen scenarios. 
The worst case release scenario submitted for the Program 3 toxic substance as a class involves a catastrophic release from ammonia used as a refrigerant.  The scenario involves the release of 24,748 pounds of ammonia in a gaseous form over 10 minutes.  At Class F atmospheric stability and 1.5 m/s wind speed, the maximum distance of 1.50 miles is obtained cor 
responding to a toxic endpoint of 0.14 mg/L. 
One alternative release scenario has been submitted for the toxic substance present in the Program 3 process. 
The alternative release scenario for Ammonia involves a release from a relief valve in the ammonia refrigeration process.  The scenario involves the release of 577 pounds of ammonia in a gaseous form over 10 minutes.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia is 0.10 mile. 
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.  In addition, our facility is subject to the OSHA PSM standard under 29 CFR 1910.119.  Our facility is also subject to EPCRA Section 302 notification requirements.  The following sections briefly describe the elements of the release prevention program that is in 
place at our stationary source. 
Process Safety Information 
H.C. Brill maintains a detailed record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with all the processes. 
Process Hazard Analysis 
The methodology used to carry out the analysis is What If-Checklist.  The analyses are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of 5 years.  Any findings related to the hazard analysis are addressed in a timely manner. 
Operating Procedures 
For the purposes of safely conducting activities within our covered process, H.C. Brill 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 reviewed and is readily accessible 
to operators involved with the process. 
H.C. Brill has a training program in place to train employees who are operating the process or are associated with the process.  Refresher training is provided at least every three (3) years and more frequently as needed. 
Mechanical Integrity 
H.C. Brill carries out documented maintenance checks on process equipment to ensure proper operations.  Process equipment examined by these checks includes pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and compressors.  Maintenance procedures are carried out by qualified personnel with a background in maintenance practices.  Training is provided to the personnel as needed.  Any equipment deficiencies identified during maintenance checks are corrected in a safe and timely manner. 
Management of Change 
Written procedures are in place at H.C. Brill to manage changes in process chemicals, technology, equipment and procedures.  Process o 
perators, maintenance personnel and all other employees whose job tasks are affected by a change in a process are promptly made aware of and offered training to deal with the changes. 
Pre-startup Reviews 
Pre-start up safety reviews related to new processes and to modifications in the established process are conducted as a regular practice at H.C. Brill.  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 
H.C. Brill 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 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. 
Incident Investigation 
Ventura Foods promptly investigates any incident that 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 
H.C. Brill truly believes that process safety management and accident prevention is a team effort.  Company employees are encouraged to express their views concerning accident prevention issues and to recommend improvements.  In addition, our employees have access to all information collected as part of the facility's compliance with the RMP Rule including information resulting from process hazard analyses. 
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.  H.C. Brill 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 applicable procedures for emergency response to an accidental release of a regulated substance. 
5.    Five-year Accident History 
H.C. Brill has an excellent record of preventing accidental releases, at all of our facilities, over the last 5 years.  This newly constructed facility is expected to continue this exemplary record.   
6.    Emergency Response Plan 
H.C. Brill has 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 will be regularly inspected and serviced.  In addition, the plan is updated to reflect any pertinent changes taking place within our processes that would require a modified 
emergency response. 
DeKalb County LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 
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.  Continued training, and program reviews are some of the major steps we want to take to improve safety at our facility.  These changes are expected to be implemented in a timely manor.
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