Tasty Baking Oxford, Inc. - Executive Summary |
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Tasty Baking Oxford, Inc. (Tasty Baking), located in Oxford, Pennsylvania, is committed to ensuring a safe work environment for the employees and the community. To this end, the management strongly supports the implementation of safe procedures for all aspects of operation, including the one regulated process: anhydrous ammonia. The facility fully complies with the regulation and intent of both the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) rule and the Environmental Protection Agency's (EPA) Risk Management Program (RMP). The success of the facility's commitment is verified by the fact that there have been NO accidents which involve the anhydrous ammonia refrigeration system at any time within the last five years. Tasty Baking is a baking and packaging facility for the Tastykake brand of products. This facility utilizes anhydrous ammonia as an integral component of the refrigeration processes. Anhydrous ammonia is delivered to the faci lity in either a straight tank truck (capacity of 13,100 lbs) or a semi-tractor trailer (capacity of 38,000 lbs). Delivered ammonia enters the process either to the receiver tank (15,000-pound allowable capacity) or directly to the system. During delivery, the ammonia truck is connected at the charging valve station, and an on-the-truck pump performs the off-loading. At all points during delivery, a qualified facility employee remains with the delivery truck. As part of the RMP requirements, facilities which contain a regulated substance (such as anhydrous ammonia) at quantities exceeding 10,000-pounds must consider the impact of a worst-case and an alternate-case release of the substance. In order to determine the impact a release would have, Tasty Baking Oxford utilized the Areal Locations of Hazardous Atmospheres (ALOHA) Model developed by the National Oceanic and Atmospheric Administration and the EPA. By definition, a worst-case release involves a catastrophic failure under the worst possible atmospheric conditions, and is therefore extremely unlikely. For this facility, the worst-case scenario is the failure of the High Pressure Receiver, located inside, when filled to the greatest amount allowed (80% of capacity). The evaporating ammonia released in this situation would be somewhat restrained by the building enclosure; a 1,500 lb/min release rate within the building would result in 210 lb/min of ammonia escaping the building. Some of the vaporized ammonia which escapes the building is predicted to reach offsite endpoints and nearby public receptors; no sensitive environmental receptors would be impacted. The High Pressure Receiver is on a regular maintenance and inspection schedule and is in a protected and fairly isolated location, making a catastrophic failure all the more unlikely. The alternate-case release which was evaluated involves a small hole in a pipe or vessel releasing ammonia for a period of 60 minutes. This release would also occur within the building, providing some degree of containment. In this situation, evaporating ammonia would leave the property boundaries and would reach a minimal number of offsite endpoints; again, no sensitive environmental receptors would be impacted. A regular maintenance and inspection schedule and protected pipeline locations reduces the potential for release. As part of this facility's commitment to provide a safe work environment, Tasty Baking complies with OSHA's PSM rule. Monthly safety meetings are conducted for all plant employees to evaluate plant safety issues. Specific ammonia-related training is given to all operators of the ammonia system. All components of the ammonia system are covered under a Mechanical Integrity program to assure that they operate safely are and are physically sound. Appropriate standard operating procedures (SOPs) are in place for start-up and shutdown of the ammonia process, in both normal and emergency situations. All other components of the PSM program are in place, and are outlined and discussed in a PSM/RMP manual in use at the facility. Tasty Baking has an outstanding record of accident prevention which demonstrates its commitment to public and worker safety. Even minor incidents are investigated to identify what went wrong and to learn how to prevent future occurrences. As mentioned previously, this facility has had no accidents involving anhydrous ammonia within this 5-year history that resulted in any on-site or off-site impacts as defined by EPA. In the event of an ammonia release, Tasty Baking has in place an Emergency Response (ER) Plan which is reviewed and updated whenever a significant change to the ammonia system occurs. All employees have been trained on the notification and evacuation procedures detailing the ER Plan. The facility's emergency response plan establishes a written procedure to follow in the event of a release. The procedure presents guidelines to determine if an ammonia release is c onsidered minor or major. In the event of a minor release, specific procedures are in place to control the release and implement the clean-up plan. In the event of a major release, the plan calls for a facility evacuation and notification of the Chester County HazMat Team and the local fire department. The emergency response plan also contains procedures to alert facility personnel of the danger potential; a list of emergency contacts; evacuation procedures and primary/secondary gathering locations; and the procedures to be implemented in the event of a fire at the facility. Selected employees at the facility have been trained to assist external responders in the event of a major release. These employees have training in Ammonia Safety and Incident Response, and have completed 24-hour OSHA Training. Tasty Baking is committed to continuously improving the overall safety and environmental performance record at the Oxford facility. Although no specific changes are currently planne d, specific policies aimed at improving safety will be continually improved. These policies include: continuing development of best management practices; conducting site- and job-specific training; continuing coordination with the fire department, local HazMat team, and Local Emergency Planning Committee; and upholding the facility's goal for a safe workplace. In summary, Tasty Baking is fully committed to the safe storage, use, and operation of the anhydrous ammonia refrigeration system utilized at the facility. The facility fully complies with the regulation and intent of both the PSM rule and RMP. As a result of effective facility planning, well-trained and capable employees, and implemented safety procedures, the facility has never had an accident involving the anhydrous ammonia system. |