Heritage Farms - Executive Summary |
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RMP EXECUTIVE SUMMARY A. Accidental Release Prevention and Emergency Response Policies Heritage Farms recognizes management's responsibility in protecting its employees, the public, the environment, equipment and property. The safety and health of all personnel are very important. The control of accidents has been and will continue to be a basic responsibility of all personnel in the Murfreesboro facility. To accomplish the company's goal in controlling accidental losses, the facility has established a Plant Safety Program. The objectives of the Plant Safety Program are to: maximize safety performance, eliminate human suffering and the economic burden resulting from injuries and accidents and reduce losses associated with damage of property. One of the activities associated with the Plant Safety Program has been the development and implementation of accidental release prevention and emergency response programs which are designed to comply with OSHA's Process Safety Management (PSM) standard (Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119), and EPA's Risk Management Program (RM program) regulation (Risk Management Programs for Chemical Accidental Release Prevention, 40 CFR Part 68). Mr. Dave Davis, Regulatory Compliance Manager, is responsible for implementation of the Risk Management Program. The purpose of the accidental release prevention and emergency response programs is to prevent the occurrence, and minimize the consequences of significant releases of toxic substances as well as fires, explosions, and other types of catastrophic accidents. Overall, these programs prevent accidental fatalities, injuries and illnesses and avoid physical property damage. The accidental release prevention and emergency response programs help prevent accidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment. These rules are detailed and improved as necessary. Th ey are also communicated to and accepted by all employees at the facility. In addition to the Plant Safety Program, the Heritage Farms facility follows these corporate and site-specific safety guidelines: Employee Handbook Plant Safety Rules Kroger Contractor Safety Rules Kroger Safety Inspections and Abatement Plans Kroger Process Improvement Team (PIT) Program Kroger Manufacturing Safety Key Element Assessment (KEA) & Management Kroger Behavioral Accident Prevention Process (BAPP) Steering Committee Teamwork Offers Positive Solutions (TOPS) Program General Office (GO) Safety Inspection program Co-worker Organized Work Safety (COWS) Program B. Stationary Source and Regulated Substances Handled Heritage Farms is part of the Kroger Limited Partnership II. The facility manufactures dairy and juice products. It operates an ammonia refrigeration system to provide cooling and freezing capabilities. The amount of anhydrous ammonia (CAS #7662-41-7) contained in the system is in excess of 10,000 pounds. The maximum inventory in the system is approximately 18,500 pounds. Since an ammonia release from the system could pose a risk of offsite public and/or environmental impact and the system is regulated under the OSHA PSM standard (29 CFR 1910.119), the system is subject to the Program 3 requirements of the EPA's RM program. C. Summary of Worst-Case and Alternative Release Scenarios The worst-case release scenario at the Heritage Farms facility involves the release of 8,436 pounds of ammonia over a 10 minute period due to the failure of the ammonia receiver. This quantity represents the full capacity of the vessel, which is a conservative assumption as it may only be full once every 10 years during a substantial system pump- down. Under worst-case weather conditions, ammonia could travel 1.1 miles before dispersing enough to no longer pose a hazard to the public. This distance has been calculated based on the method provided in EPA's Risk Ma nagement Program (40 CFR 68) Guidance for Ammonia Refrigeration. The worst-case release scenario is unlikely for the following reasons: The worst-case weather conditions which were used for this scenario are not typical; Industry standards were followed for the manufacture and quality control of the receiver; The receiver is located in an enclosed area that could help to contain such a release; The receiver is located in a low traffic area within the engine room which minimizes the possibility of loss of containment due to vehicular impact (e.g., from forklifts etc.); Ammonia is not corrosive in this service and the vessel is relatively new; An ammonia detector which is tied to emergency ventilation fans is located near the receiver in the engine room; Pressure safety valves limit operating pressure in the vessel; The facility has a preventive maintenance program in place to maintain the on-going integrity of vessels; The facility has a training program designed to ensure that the system is operated by qualified personnel; and, The facility emergency response procedures enable trained personnel to respond quickly to isolate any potential releases. The alternative release scenario at the Heritage Farms facility involves the release of 5,060 pounds of ammonia over a 10 minute period due to the failure of a 1/2" liquid line downstream of the rooftop evaporative condenser. Under alternative release weather conditions, ammonia could travel 0.2 miles before dispersing enough to no longer pose a hazard to the public. This distance has been calculated based on the method provided in EPA's Risk Management Program (40 CFR 68) Guidance for Ammonia Refrigeration. The alternative release scenario is unlikely for the following reasons: Industry standards were followed for the manufacture and quality control of the liquid lines; Ammonia is not corrosive in this service; Most of the lines are elevated to minimize potential damage fro m traffic, fork lifts etc.; The facility has a preventive maintenance program in place to maintain the on-going integrity of the system; The facility has a training program designed to ensure that the system is operated by qualified personnel; and, The facility emergency response procedures enable trained personnel to respond quickly to isolate any potential releases by closing isolation valves in the liquid lines. D. Description of the Accidental Release Prevention Program The prevention program consists of the following elements: Employee Participation: This program involves the employees in establishing and implementing the program. Employees are also to be involved when a process hazard analysis is conducted. The program also ensures that all employees have complete access to the program. Process Safety Information: Written information has been collected which enables the employees to identify and understand the potential hazards in the system. The written i nformation includes the ammonia MSDS and a description of the design of the ammonia refrigeration system. Process Hazard Analysis (PHA): Formal studies using the What-If/Checklist Technique have been conducted to examine the system and identify potential hazards. Any recommendations from the PHA are resolved to improve facility safety. Operating Procedures: Written, detailed procedures have been developed which describe the steps which should be followed to safely operate the ammonia refrigeration system. Training: A training program has been developed which ensures that employees are trained on all aspects of the system and on the duties which they should perform to ensure the safe operation of the ammonia refrigeration system. Contractors: All contractors are screened and evaluated before they perform work on or near the ammonia refrigeration system. The contractors are also periodically evaluated to ensure that they perform work by following safe work practices. Pre-Startup Safety Review: A pre-startup safety review is required for all new ammonia projects to verify that all safety programs are in place, training has been performed, and construction has been completed according to design standards before the project is put into use. A pre-startup safety review is also performed when the process safety information related to the system changes significantly. Mechanical Integrity: This program ensures that the ammonia refrigeration systems are built and maintained using preventive maintenance procedures to minimize unexpected breakdowns or failures. Hot Work Permit: These procedures ensure that a signed permit is obtained prior to any cutting, welding, or burning. Management of Change: Procedures are designed to ensure that all changes made to the ammonia refrigeration system are properly reviewed. Incident Investigation: The procedures ensure that any incidents (and near misses) are investigated, reviewed, and documented us ing an investigation team. Any recommendations from the investigation are resolved to improve facility safety. Compliance Audits: There are procedures to conduct regular audits of the RM prevention program to ensure that the program is in place and working properly. Any recommendations from the audit are resolved to improve the prevention program. E. Five-Year Accident History There have been no ammonia-related incidents at the Heritage Farms within the last five years that have resulted in onsite or offsite impacts. F. Description of the Emergency Response Program An emergency response program has been implemented at the Heritage Farms facility. This program contains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures. The program has been coordinated with the Rutherford County LEPC. The emergency response program consists of the following elements: Organization Plan and Responsibilities Communications Procedures Detailed Action Plans First Aid Procedures Emergency Medical Treatment Procedures Evacuation Plans Description of Outside Assistance Available Site Re-Entry Procedures Training Programs and Drills Revision and Update Criteria G. Planned Changes to Improve Safety The following changes are planned to improve safety conditions and further strengthen the ongoing safety efforts at the Heritage Farms facility: improved labeling of system valves upgraded Preventative Maintenance (PM) program continual support for the Behavioral Accident Prevention Process (BAPP) and the Safety Key Element Assessment (KEA) process. |