Lamb-Weston, Inc. Twin Falls Plant - Executive Summary |
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EXECUTIVE SUMMARY CORPORATE SAFETY COMMITMENTS Lamb-Weston, Inc. has potato processing plants located in Washington, Oregon, Idaho, and Minnesota. Lamb-Weston is committed to providing its employees and the surrounding community with a safe and healthy environment. The Risk Management Program is an integral part of our strong commitment to "sustainable development," which means development that meets the needs of the present without compromising the ability of future generations to meet their own needs. Sustainable Development requires reductions in the generation of wastes and pollutants, protection of clean air and clean water, sustainable protection of the land, and the wise use of energy. It requires employee commitment, strategic thinking, innovation, the involvement of our suppliers, new technology and enhanced production processes. DESCRIPTION OF FACILITY AND REGULATED SUBSTANCES The Twin Falls, Idaho processing facility produces various potato products such as french f ries, potato wedges and slices, hash browns, mashed potatoes and formed potato products. This facility employs approximately 850 people. The plant site consists of a main processing plant, raw potato storage building, dry storage and farm shop building, USDA inspection and receiving building, primary waste water treatment facility, field department building, and refrigerated cold storage. Activities are conducted at this site during all months of the year. The potato processing cycle includes a wide array of steps. The plant purchases the majority of its potatoes from local growers. Since potatoes have a single growing season, they must be held under controlled storage conditions. Prior to processing, the potatoes are separated by size and processing specifications. The inspected, washed, peeled, and hand-trimmed potatoes are cut, blanched and fried. The final products are frozen, packaged and prepared for shipping. The freezing process where finished products are conveyed th rough the freezer to be quickly cooled and frozen is made possible by refrigeration systems containing 137,833 pounds of anhydrous ammonia, an EPA-regulated chemical. Virtually all major food processors, including Lamb Weston, utilize anhydrous ammonia in large refrigeration or freezing plants and the chemical has been used in this capacity since the 1850's. OFFSITE CONSEQUENCE ANALYSIS The offsite consequence analysis conducted as part of the Risk Management Plan includes consideration of two ammonia release scenarios identified as "worst case release" and "alternative release." The first scenario as defined by EPA states that "for substances that are normally gases at ambient temperature and handled as a gas or liquid under pressure, the owner or operator shall assume that the maximum quantity in the largest vessel is released as a gas over 10 minutes". The alternative scenario is defined as "more likely to occur than the worst-case release scenario." Anhydrous ammonia, as used by the Twin Falls, Idaho facility, is a gas at ambient temperature and is stored as gas or liquid under pressure. The worst case scenario was performed for the Line 2 and 3 Freeze Tunnel High Pressure Receiver which is located outside and has the potential to contain a portion of the design volume of the Freeze Tunnel System. The 23,000 pounds of ammonia was assumed to be released from the high pressure receiver over a 10-minute period. Other parameters included a wind speed of 1.5 meters per second, stability class of F, hole size of 4.06-inches, tank pressure of 180 psi, tank temperature of 950 F, highest temperature at the site for the last 3 years of 1050F, average relative humidity of 53%, and surface roughness category identified as the outskirts of town. The dense gas model SLAB was used for the analyses. SLAB is a computer model developed by Lawrence Livermore Laboratory that simulates the atmospheric dispersion of denser than air releases. The SLAB model can simu late an evaporating pool, a horizontal jet, a stack or vertical jet and an instantaneous volume release. The modeling was performed using the horizontal jet option so that no vertical momentum was introduced. This would be representative of a hole in the side of a vessel or pipe. The results of the SLAB analyses for the worst-case scenario indicate off-site impacts. The alternative release scenario was performed for a <" hole at high pressure receiver conditions releasing liquid ammonia in a horizontal jet. This release could represent a variety of release scenarios including the five described in the regulation (40 CFR Ch. I Part 68.28). The release point is considered to be outside since there is piping at high pressure receiver conditions in the vicinity of the high pressure receiver. The release rate was considered to be constant over a one-hour period. The one-hour was chosen because it is the basis of the 200 ppm end-point for ammonia. Other parameters included average m eteorological conditions for the site, tank pressure of 165 psi, tank temperature of 900 F, wind speed of 8.4 mph, stability class of D (neutral), site temperature of 500F, relative humidity of 53%, and surface roughness category identified as the outskirts of town. The dense gas model SLAB was also used for the analyses of the alternative release scenario, and off-site impacts were indicated. ACCIDENTAL RELEASE PREVENTION PROGRAM Lamb-Weston's accident prevention/loss control systems and policies involve a unified approach that integrates technologies, procedures, and best-management practices. The OSHA-PSM and the EPA-RMP plans work together to assure that potential on-site hazards and off-site consequences are identified and controlled to the best of our ability, and that the processes are meeting health and safety objectives. The RMP Prevention Program is comprised of the 13 elements of OSHA's PSM program: Employee Participation, Process Safety Information, Process Hazard Ana lysis, Management of Change, Pre-Startup Safety Review, Operating Procedures, Hot Work Permits, Employee Training, Incident Investigation, Mechanical Integrity, Emergency Planning & Response, Contractor Safety, and Audits. Employee participation brought together people that knew and understood the system, from practical experience as well as their technical knowledge, to develop the Plan. Process safety information is a collection of data that allows us to identify and understand the hazards posed by our inventory. Representatives from our skilled work force and Lamb-Weston management, who understood the process being analyzed including the engineering behind the covered process, conducted the process hazard analysis. This analysis identifies potential process failures that could result in an uncontrolled release of ammonia. In order to safely manage changes that need to be made to the processes containing ammonia, a system of checks and balances has been established. This s ystem will evaluate safety prior to the work being done, and provide a solid review of the system to assure that once started, it will run as designed. Standard operating procedures are in place for each operating phase and are readily accessible to those workers who operate or maintain the process. In addition, a policy and procedure are used to assure that proper safety precautions are taken for all personnel performing Hot Work. The integrity of the refrigeration system equipment is maintained according to recognized and generally accepted good engineering practices and according to a well-documented preventive maintenance program. An extensive training program is in place for those employees and contractors involved in working on or around the process and covers operating procedures, health and safety hazards, emergency operations, and safe work practices. The facility also has a training program for all employees and contractors regarding the hazards of the chemical and safe work practices to be used. Part of this training includes monthly safety meetings as well as drills on spill response and plant evacuation. Any incidents related to the ammonia refrigeration systems are promptly investigated even though the rule only requires investigation of those incidents, which resulted in, or could reasonably have resulted in, a catastrophic release. All incidents are analyzed, resolved, and findings shared with affected employees. In order to assure compliance with all elements of the prevention program, an audit is conducted every three years including a report of the findings and documentation of any deficiencies corrected. FIVE-YEAR ACCIDENT HISTORY There have been no accidental releases at the Twin Falls, Idaho Facility in the last five years from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. EME RGENCY RESPONSE PROGRAM The Twin Falls, Idaho facility has an emergency action plan which has been coordinated (reviewed) with the Twin Falls Fire Department and the Region IV LEPC-Magic Valley Emergency Services (MVERT). The plan applies to all Lamb-Weston employees, visitors, and support service contractors performing tasks and activities as part of ongoing operations. The purpose of the plan is to establish policies and procedures for protecting the health and safety of employees, contractors, and visitors, and to comply with all applicable federal and state regulations. Training of employees and contractors includes providing a copy of the plan upon initial employment at Lamb-Weston and reviewing it for their specific assignment, annual refresher training for current employees, and review for all whenever the plan is changed. In addition, plant evacuation drills are conducted on a regular basis. The plan is comprehensive enough to deal with all types of emergencies specific to the Lamb-Weston Twin Falls, Idaho facility and defines the following: 7 How to conduct activities in a manner that protects the safety of employees, the public, and the environment 7 Preferred means for reporting fires, hazardous materials incidents, medical, and any other emergencies 7 Emergency escape procedures and emergency escape route assignments 7 Procedures to account for all employees including contractors and visitors 7 Names of agencies and persons to contact for further assistance, information, or explanation of the plan PLANNED CHANGES TO IMPROVE SAFETY The Twin Falls, Idaho facility takes seriously its responsibility for the safety of its employees, neighbors, and community. Central to this responsibility are our programs to prevent the release of chemicals to the environment. We will continue to implement these precautions and programs, to act as a responsible neighbor, and to maintain the goodwill of the community. |