National Frozen Foods Corporation - Executive Summary

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General Executive Summary for Manufacturing: 
 
1.  Accidental Release Prevention and Emergency Response Policies: 
 
We at National Frozen Foods Corporation are committed to employee, public, and environmental safety.  This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility.  It is our policy to implement appropriate controls to prevent possible releases of regulated substances.  Unforeseeably, if such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release.  We are also completely coordinated with the Albany Fire Department who provides additional emergency response expertise. 
 
2.  The Stationary SLource and the Regulated Substances Handled: 
 
We have 1 regulated substance present at our facility, which is Ammonia (anhydrous).  Th 
e maximum inventory of Ammonia (anhydrous) that is expected to be present in this facility, based on process/operational requirements, is 40,000 lbs. 
 
3.  The Worst Case Release Scenario and the Alternative Release Scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario: 
 
To perform the required off-site consequence analysis for our facility, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance.  The following paragraphs provide details of the chosen scenarios: 
 
Toxic Worst-Case Analysis: 
 
The Worst-Case scenario involves a catastrophic release from national Frozen Foods Corporation's Main Plant Ammonia Refrigeration System.  The scenario involves the release of 8038 lb. of Ammonia (anhydrous) in a gaseous form over 10 minutes.  The release rate (lbs/min) is calculated to be 803.8.  A distance to endpoint of 2.8 miles is obtained which affects a residential popula 
tion of 9997 within this distance. 
 
Toxic Alternative-Case Analysis: 
 
The Alternative Case scenario involves a catastrophic release from national Frozen Foods Corporation's Main Plant Ammonia Refrigeration System.  The scenario involved the release of 1700 lb. of Ammonia (anhydrous) in a gaseous form over 10 minutes.  The release rate (lbs/min) is calculated to be 170 and a distance to endpoint of .31 miles is obtained which affects a residential population of 195. 
 
There are no Flammables Worst-Case or Alternative-Case scenarios for this process. 
 
4.  The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps: 
 
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA.  One process at our facility is subject to the OSHA PSM standard under 29 CFR 1910.119.  Our facility is also subject to EPCRA Section 302 notification requirements.  The following sections briefl 
y describe the elements of the release prevention program that is in place at our stationary source: 
 
Process Safety Information: 
 
National Frozen Foods Corporation maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. 
 
Process Hazard Analysis: 
 
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently.  The methodology used to carry out these analyses is the What-If Checklist.  The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of every three years.  Any findings releated to the hazard analysis are addressed in a timely manner. 
 
Operating Procedures: 
 
For the purposes of safely conducting activities within our covered processes, National Frozen Foods Corporation maintains written operating procedur 
es.  These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround.  The information is regularly reviewed and is readily accessible to operators involved in the process. 
 
Training: 
 
National Frozen Foods Corporation has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes.  New employees receive basic classroom training in process operations followed by on-the-job supervision until they are deemed competent to work independently.  Refresher training is provided at least annually and more frequently as needed. 
 
Mechanical Integrity: 
 
National Frozen Foods Corporation carries out highly documented maintenance checks on process equipment to ensure proper operations.  Process equipment examined by these checks includes: pressure ves 
sels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps.  Maintenance operations are carried out by qualified personnel with previous training in maintenance practices.  Furthermore, these personnel are offered specialized training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
 
Management of Change: 
 
Written procedures are in place at National Frozen Foods Corporation to manage changes in process chemicals, technology, equipment and procedures.  Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. 
 
Pre-Startup Reviews: 
 
Pre-startup safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at National Frozen Foods Corporation.  These reviews are 
conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for a safe startup prior to placing equipment into operation. 
 
Compliance Audits: 
 
National Frozen Foods Corporation conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented.  These audits are carried out at least every 3 yeaars and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. 
 
Incident Investigation: 
 
National Frozen Foods Corporation promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance.  These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring.  All reports are retained for a minimum of 5 years. 
 
Employee Participation: 
 
National Frozen Foods Corporation truly believes that process sa 
fety management and accident prevention is a team effort.  Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements.  In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analysis in particular. 
 
Contractors: 
 
On occassion, our company hires contractors to conduct specialized maintenance and construction activities.  Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out.  national Frozen Foods Corporation has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes.  Contractors are also informed of all the procedures for emergency response, should an accidental release of a regulated substance occur. 
 
5.  Five-Year Accident History: 
 
National Frozen Foods Corporation ha 
s had an excellent record of preventing accidental releases over the last 5 years.  Due to our stringent release prevention policies, there have been no accidental releases during this period. 
 
6.  Emergency Response Plan: 
 
This facility is included in the written community ER plan.  This facility has its own written ER plan.  The ER plan includes specific actions to be taken in response to accidental releases of regulated substances.  The ER plan includes procedures for informing the public and local response agencies of a chemical release.  The ER plan includes information on emergency health care. 
 
Date of most recent review/update of ER plan:   4/14/1999 
Date of most recent ER training of employees:    5/18/1999 
 
The local agency coordinating the ER plan is the Albany Fire Department which has the phone number 541-917-7700. 
 
7.  Planned Changes to Improve Safety: 
 
Several developments and findings have resulted from the implementation of the various elements of our accidental relea 
se prevention program.  We will continue our annual plant evacuation drills.  In addition, we conducted a joint emergency drill with Oregon Freeze Dry and the Albany Fire Department on May 18, 1999.  This drill enhanced our mutual aid capabilities in the event of an accidental chemical release.
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