Best Kosher Foods Corporation - Executive Summary |
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BACKGROUND DATA In accordance with Title 40 of the Code of Federal Regulations Chapter 68 (40 CFR 68) promulgated by the Environmental Protection Agency (EPA), Best Kosher Foods Corporation submits this Risk Management Plan (RMP) for operations at their Chicago, Illinois facility. Best Kosher Foods Corporations operations include the processing of meat products (kosher meats) for public consumption. Best Kosher Foods Corporation has been in operation at this facility for over 30 years providing quality meat products and over 250 jobs to the local community. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICY Best Kosher Foods Corporation is committed to protecting the health of its employees, the surrounding community, and the environment; therefore it is Best Kosher Foods Corporations policy to manage a safe and healthy workplace, protect the environment and maintain compliance with safety, health, and environmental regulations: 40 CFR 68 as well as Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Federal Regulations, Chapter 1910, Section 119 (29 CFR 1910.119), and OSHAs Hazardous Operations and Emergency Response regulations (29 CFR 1910.120). STATIONARY SOURCES AND REGULATED SUBSTANCES Best Kosher Foods Corporation is required to maintain low temperatures in the food processing areas of the plant that are within standards required by the United States Department of Agriculture (USDA) to ensure quality in the final products. Best Kosher Foods Corporation uses anhydrous ammonia (the 112(r) regulated substance) as a refrigerant to maintain the facility within the required range of operating temperatures. Anhydrous ammonia is an industry-standard refrigerant. Best Kosher Foods Corporations refrigeration system consists of receivers, compressors, evaporators, condensers, and piping. WORST CASE RELEASE SCENARIO As required by 40 CFR 68 Subpart B, Best Kosher Foods Corporation has evaluated a worst-case release scenario for anhydrous ammonia using the parameters specified by the EPA. Best Kosher Foods Corporations worst case release scenario is the rupture of the largest single receiver when filled to 57.9% capacity (maximum fill capacity per administrative controls) over a 10-minute period. Using the National Safety Councils ALOHA program, the maximum distance to the toxic endpoint includes offsite receptors. The worst-case release scenario was developed following EPA regulations and is not considered to be a likely release scenario. ATERNATIVE RELEASE SCENARIO A more realistic release scenario (alternative release) was developed by Best Kosher Foods Corporation taking into consideration the 5-year history of operations experience and the hazards identified in the process hazard analyses (PHAs) conducted to ensure that (company) hazards are identified and minimized. These analyses were conducted under the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Federal Regulations Chapter 1910, Section 119 (29 CFR 1910.119). The most likely release scenario identified by Best Kosher Foods Corporation would be a release caused by a damaged ammonia pipe. The release could occur as a result of a leak from a pipe connected to the pressurized tank. In developing the release parameters of this alternative scenario, Best Kosher Foods Corporation considered that the release would occur from a 0.5-inch diameter pipe/valve, located 5 feet from the tank bottom. Using the ALOHATM program, the maximum distance to the toxic endpoint extends offsite. ACCIDENTAL RELEASE PREVENTION PROGRAM The ammonia refrigeration system is designed and constructed in accordance with ANSI/IIAR 2-1992 Standard for Equipment, Design, And Installation of Ammonia Mechanical Refrigerating Systems. To prevent and mitigate accidental releases of anhydrous ammonia, Best Kosher Foods Corporation has implemented several precautionary measures, such as process/equipment controls, standard operating procedures, preventive maintenance programs, employee training, and audit programs. Best Kosher Foods Corporation has implemented and is in compliance with OSHAs PSM regulations and as such, has evaluated and engineered for anhydrous ammonia releases. Some of the controls installed to prevent catastrophic releases of ammonia are process equipment (vents, pressure relief valves, backup pumps, and manual shutoffs) and automated controls (automatic shut-offs, ammonia leak detection system, and electrical distribution system grounding). Best Kosher Foods Corporation has developed standard operating procedures for all employees and contractors that have contact with the ammonia refrigeration system that incorporate safety measures into the procedures. These safety procedures were developed by Original Equipment Manufactures (OEM) and refrigeration syste m operators and are reviewed on a periodic basis. Process safety information for the refrigeration system is reviewed during PSM/RMP meetings as well. Best Kosher Foods Corporation encourages employee participation in development of the control measures used at the plant by means of verbal discussion and training sessions. Written management of change procedures have been established by Best Kosher Foods Corporation. Best Kosher Foods Corporation understands that maintaining the refrigeration system in good working order is essential to preventing accidental releases; therefore Best Kosher Foods Corporation has implemented a preventative maintenance program. The preventative maintenance program is scheduled, documented and managed using an equipment log attached to each major piece of equipment to ensure that regular maintenance occurs. Also, to ensure the mechanical integrity of critical refrigeration system components, infrared testing is conducted on an annual basis. To ensure that Best Kosher Foods Corporations control measures are effective in maintaining the safe operation of the plant, regularly scheduled audits are performed on the ammonia refrigeration system: 7 In accordance with the PSM program, Best Kosher Foods Corporation conducts detailed PSM compliance audits every three years. Each audit incorporates review of process safety information, process hazard analysis, operating procedures, training programs, system mechanical integrity, management of change, pre-start up review procedures, compliance audit procedures, incident investigation procedures, employee participation programs, hot work permit procedures, and contractor safety procedures. 7 In addition, Best Kosher Foods Corporation is audited by the local fire department on an annual basis. 7 Best Kosher Foods Corporation is audited by the USDA/OSHA on a periodic basis. 7 Best Kosher Foods Corporations insurance carrier also conducts independent audits on an annual basis. FIVE-Y EAR ACCIDENT HISTORY Over the last five years, Best Kosher Foods Corporation has not experienced an accidental release of anhydrous ammonia from the ammonia refrigeration system causing any on-site death, injury or significant property damage, or known off-site death, injury, property damage, environmental damage, evacuations, or sheltering in place. EMERGENCY RESPONSE PROGRAM The City of Chicago Fire Department, Hazardous Material Division has employees trained to respond to an accidental release of anhydrous ammonia. Best Kosher Foods Corporation has a documented evacuation procedure (Policy # 503A & C) located in the Emergency Plan & Response manual (located on the RMP shelf in the Sr. Mgr. Facilities office), in order to facilitate response efforts in the event of an off-site anhydrous ammonia release. Notification to the City of Chicago Fire Department, Hazardous Material Division is one measure included in the Evacuation Plan. To assure that the local governmental r esponse agencies are familiar with Best Kosher Foods Corporations operations, Best Kosher Foods Corporation has submitted copies of the Plan for review and approval by the local agencies. The following local agencies have reviewed and approved Best Kosher Foods Corporations Plan: 7 National Response Center 7 Illinois Emergency Management Agency 7 Cook County Sheriffs Emergency Management Agency 7 City of Chicago, Office of the Emergency Preparedness Disaster Service In addition to the above local response agencies, Best Kosher Foods Corporation has arranged emergency response assistance with City of Chicago, Fire Department, Office of Preparedness Disaster Services. In the event of an anhydrous ammonia release with off-site effects, the general public will be warned using one or more of the following methods: 7 City of Chicago Police and Fire Department fire vehicles equipped with public address systems, and 7 Public notification of residents. As backup measures, the City of Chicago, Fire Department has arranged for back-up assistance from another local environmental clean-up contractor. |