Luigino's Incorporated - Executive Summary |
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LUIGINO'S, Incorporated RISK MANAGEMENT PROGRAM PLAN Executive Summary Accidental Release Prevention and Emergency Response Policies The accidental release prevention and emergency response policies at Luigino's Jackson, Ohio facility are engrained in the fundamentals of the process safety prevention program. In our Jackson, Ohio facility, we presently handle one chemical, ammonia, which is considered hazardous by the Environmental Protection Agency (EPA). The same properties that make this chemical valuable as a refrigerant also make it necessary to observe specific safety precautions. These safety precautions are exercised in the operation and maintenance of the refrigeration system to control human environmental exposure in an effort to reduce the overall threat to our workers as well as the surrounding communities. It is Luigino's policy to adhere to all applicable federal, state and local rules and regulations. However, the safe handling of hazardous chemicals is paramount at Luigino's. We adhere to standards and recommended practices governing the safe handling of hazardous chemicals to ensure that we have obtained a reasonable level of risk reduction. Investigation of inherently safer refrigeration technologies and fail safe design applications are a few of the continuous improvements occurring at Luigino's. Safety depends upon our management, the manner in which we handle ammonia, the safety devices inherent to our refrigeration systems, our operating procedures and philosophies, and the training of our employees. We believe that accountability for safety reaches throughout all levels of management at Luigino's. Senior management's commitment and dedication to continued safe-operating practices is clearly evident in our organization structure and employee empowerment. We have made extensive improvements to safety and health programs like our prevention program (process safety management), emergency preparedness and response, and training. Addit ionally, we believe employee involvement is the cornerstone to continued safe operations. We call it employee ownership and its success is portrayed through lower injury rates, fewer incidents, and improved efficiencies at the plant. The Emergency Preparedness and Response Plan outlines procedures for warned and unwarned emergencies that may occur at the plant. Warned emergencies are usually tornadoes, heavy snowstorms, or conditions that are reasonably predictable. Unwarned emergencies usually consist of on-site emergencies such as a spill, fire/explosion, or a chemical release. As a responsible company, Luigino's provides the emergency response teams with state-of-art equipment and the latest training and procedures. This ensures prompt mitigation actions during incidents. Facility description and regulated substances handled Luigino's is a large domestic producer of processed foods that include Michelina's and Yu Sing food products. The Luigino's Jackson plant site covers a pproximately 585,000 square feet (13.4 acres) within the Jackson City limits. It is located at 100 East Broadway Street in Jackson, Ohio, Jackson County. There are approximately 1000 employees at the plant site, which are represented by the United Food and Commercial Workers union organization. We presently handle only one chemical that is considered hazardous by the EPA. This substance is present in quantities greater than the threshold quantity identified by the RMP regulation and therefore is included in our risk management program. X Ammonia (anhydrous)- Ammonia is used as a refrigerant at the plant. It is received into the plant by truck, however deliveries of ammonia are infrequent. One of the primary refrigeration vessels is the High Pressure Receiver vessel. This vessel has a maximum inventory of 15,000 pounds that is controlled through administrative procedures. The refrigeration systems at the facility have a total capacity of approximately 110,000 pounds (21,360 gal lons) of anhydrous ammonia. Offsite Consequence Analysis (worst-case & alternate-cases) The RMP rule requirements for identification and selection of a worst-case hazard scenario are prescriptive. These requirements negate most safety systems designed to mitigate an incidental release. Based on EPA defined Offsite Consequence Analysis (OCA) Guidance, Luigino's has one worst-case hazard scenario for the toxic material handled onsite. This scenario is estimated to create the greatest distance in any direction to an EPA defined concentration (endpoint) resulting from an accidental release. Luigino's worst-case toxic scenario involves anhydrous ammonia. Ammonia is used as a refrigerant at the plant and is stored under pressure in a vessel located outside. This vessel, the High Pressure Receiver, may have a maximum of 15,000 pounds of liquid ammonia at any one time. The scenario uses the EPA's theoretical assumption that the vessel catastrophically fails and liquid ammonia is rele ased to the atmosphere. It completely negates any mitigation attempts and assumes that all 15,000 pounds of ammonia can be spilled onto the ground and evaporated within 10 minutes to form a toxic vapor cloud that drifts offsite into the surrounding community. Using the EPA's Offsite Consequence Analysis Guidance Document, dated October 1998, to determine the greatest downwind distance, it was determined that an ammonia vapor cloud may extend 1.5 miles from the plant. This calculation was based on the EPA recommended guide for ammonia. The EPA rule also requires that alternate or more likely accident scenarios involving regulated chemical be identified. Other more likely ammonia incidents were assessed at Luigino's using parameters prescribed in the RMP regulation. The analysis of the alternate scenarios included mitigation affects from both passive and active safety systems. Luigino's conducted an iterative assessment of several alternate or more likely scenarios. From the vari ous scenarios assessed, Luigino's selected the following: X An inadvertent piping failure at a valve connection that results in complete separation from the connection point was selected as the alternate case for ammonia. This failure assumes that 12,430 pounds of ammonia is released within a 10-minute period. Evaporation of the liquid ammonia could result in the formation of a vapor cloud extending 0.23 miles (1,214 feet) from the site. Accidental release program & chemical-specific prevention steps After significant expansion of our facility's refrigeration capacity, ammonia inventories were increased at or above the threshold quantities established by the Occupational Safety and Health Administration (OSHA), which required the development of a Process Safety Management (PSM) program. Luigino's contracted with an outside consulting firm to assist in the refinement of the prevention program tailored exclusively to ammonia refrigeration operations. This prevention program was de signed around mechanical integrity and training aspects. The primary objective being to ensure complete containment of ammonia through safe operation and maintenance of the refrigeration system. Luigino's has completed 100% of its process hazard analyses (PHAs) of the ammonia refrigeration systems. A PHA was conducted in January 1999 that resulted in 11 recommendations. The recommendations generated during this review were prioritized using a standardized Risk Rank Matrix method. A second Process Hazard Analysis (PHA) for the balance of the systems was conducted in May of 1999 resulting in 12 recommendations. A total of 23 recommendations were identified of which 5 were procedural/administrative and are completed. All other recommendations identified through the PHA process involve protection of the systems or the men who work on them and have action plans to resolve all high-risk areas. The PSM Coordinator is responsible for communicating the PHA recommendations to all affecte d employees. The Safety & Health Department entered the recommendations into Luigino's PHA Recommendation Tracking database. Monthly progress reports are continuously sent to management based on updates received from the departments responsible for addressing the recommendations. Five year accident history Luigino's has a very comprehensive Incident Reporting and Investigation procedural process. This process is defined and explained by PSM-012. Basically, an incident occurs when a deviation from expected performance is experienced. Formal investigations are conducted by appointed teams knowledgeable in operations or equipment being investigated. Root cause and corrective actions are determined and formal reports are written. Progress regarding corrective action on all investigated incidents is tracked through completion. A number of different systems have been used in the recent past to track recommendations arising from Accident/Incident Investigations. The system we are presently using consists of maintaining a list of all recommendations that are part of the formal Accident/Incident Investigation Reports. All of these recommendations and other information relevant to them have been put into the computerized management program. Luigino's has not had an accidental release of EPA regulated chemicals within the past five years that resulted in an onsite injury or adversely affected the community. Emergency response Program We are a viable participant in the Jackson Local Emergency Planning Committee (LEPC) activities such as the city's annual emergency response exercise. Our plant emergency preparedness and response plan has been designed to address likely incidents arising from our ammonia refrigeration systems. Our emergency plan is a vital part of the prevention program at Luigino's. While we strive to adhere to the latest mechanical integrity and inherently safer technologies we continue to plan for the unplanned ammonia release. In order to improve emergency response efforts within the plant, we have formed a group of volunteers known as the Emergency Response Team. The function of this group is to quickly assess and mitigate any hazardous release of ammonia and act as a communications resource to make notifications and provide pertinent information during an incident This group conducts periodic training and emergency response drills on their required duties. The technician level responders must demonstrate competency in performing advance control, containment, and confinement operations. The group has made good progress towards fulfilling their role in the emergency response program at Luigino's. This group plans to continue training on their respective duties in order to improve their response efforts. Planned improvements to reduce risk Some small bore ammonia piping in plant cooler and freezer areas were identified as potential release points if accidentally struck by forklift equipment. These areas are being retrofitted with protective barriers to reduce the risk of damage from motorized equipment. |