BallPark Brands - Executive Summary |
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Background Data In accordance with Title 40 of the Code of Federal Regulations Chapter 68 (40 CFR 68) promulgated by the Environmental Protection Agency (EPA), BallPark Brands submits this Risk Management Plan (RMP) for operations at their Philadelphia, Pennsylvania, facility. BallPark Brands operations include the processing of meat products (hot dogs, hams and deli meats) for public consumption packaged under the familiar brand names of BallPark and West Virginia Brand. BallPark Brands has been in operation at this facility for over 30 years providing quality meat products and over 300 jobs to the local community. Accidental Release Prevention and Emergency Response Policy BallPark Brands is committed to protecting the health of its employees, the surrounding community, and the environment; therefore it is BallPark Brands policy to manage a safe and healthy workplace, protect the environment, and maintain compliance with safety, health, and environmental regulations: 40 CFR 68 a s well as Occupational Safety and Health Organization (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Federal Regulations Chapter 1910, Section 119 (29 CFR 1910.119), and OSHA's Hazardous Operations and Emergency Response regulations (29 CFR 1910.120). BallPark Brands seeks to protect and enhance the quality of our environment by including environmental consideration as an integral part of the corporation's overall management. Our mission is to comply with all applicable environmental laws and regulations by continually reviewing products and packaging, by conducting on-site environmental appraisals and by implementing action where necessary. We will continuously improve to reduce waste from raw material conversion to finished goods, energy and water consumption, and paper used in the information process. Whenever practical, we will use recycled or recyclable materials. We will encourage our employees to practice recycling and conservation at work and home. As renovations are planned and implemented we will assure that environmental improvements are considered. As technology advances we will continue to revise policies and standards for the corporation, beyond applicable laws and regulations, to effectively meet the expectations of our consumers, employees, neighbors, and stockholders. Stationary Sources and Regulated Substances BallPark Brands is required to maintain low temperatures in the food processing areas of the plant that are within standards required by the United States Department of Agriculture (USDA) to ensure quality in the final products. BallPark Brands uses anhydrous ammonia (a 112(r) regulated substance) as a refrigerant to maintain the 80,000-ft2 facility within the required range of operating temperatures. Anhydrous ammonia is an industry-standard refrigerant for meat processing plants. BallPark Brands refrigeration system consisting of receivers, compressors, evaporators, condensers, and pipi ng can contain an average amount of 21,870 pounds of anhydrous ammonia. Worst Case Release Scenario Anhydrous Ammonia As required by 40 CFR 68 Subpart B, BallPark Brands has evaluated a worst-case release scenario for anhydrous ammonia using the parameters specified by the EPA. BallPark Brand's worst case release scenario would be the rupture of the largest single receiver when filled to 75% capacity (the maximum tank capacity limited by engineering controls) over a 10-minute period. Using the EPA's RMP*Comp program, the maximum distance to the toxic endpoint extends offsite and includes public receptors. The worst-case release scenario was developed following EPA regulations and is not considered to be a likely release scenario. During normal operations, BallPark Brands maintains the receivers at 40% capacity. Only during pump-down operations do the receivers have the potential to be filled to 75% of capacity. The receivers are operated in pump-down mode once during the year . Alternative Release Scenario Anhydrous Ammonia A more realistic release scenario (alternative release) was developed by BallPark Brands taking into consideration the 30-year history of operation's experience and the hazards identified in the process hazard analyses (PHAs) conducted to ensure that BallPark Brand's hazards are identified and minimized. These analyses were conducted under the Occupational Safety and Health Organization (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Federal Regulations Chapter 1910, Section 119 (29 CFR 1910.119). The most likely release scenario identified by BallPark Brands would be an evaporator impact from a forklift, causing a pipe rupture. The release would occur inside the loading dock area. In developing the release parameters of the scenario, BallPark Brands considered the average response time of BallPark Brands Emergency Response Team to shut down the system. Accidental Release Prevention Program Anhydrous Ammonia The ammonia refrigeration system is designed and constructed in accordance with ANSI/IIAR 2-1992 Standard for Equipment, Design, And Installation of Ammonia Mechanical Refrigerating Systems. To prevent and mitigate accidental releases of anhydrous ammonia, BallPark Brands has implemented several precautionary measures, such as process/equipment controls, standard operating procedures, preventative maintenance programs, employee training and audit programs. BallPark Brands has developed and implemented a PSM program pursuant OSHA and as such, has evaluated the system for the potential of anhydrous ammonia releases. Some of the controls installed to prevent catastrophic releases of ammonia are process equipment (vents, check valves, pressure relief valves, backup pumps, and manual shutoffs) and automated controls (automatic shut-offs, ammonia leak detection system, purge system, and electrical distribution system grounding). In addition, BallPark Brand s has trained approximately 12 personnel to respond to potential ammonia releases (Emergency Response Team). BallPark Brands has developed standard operating procedures (SOP) for all employees and contractors that have contact with the ammonia refrigeration system that incorporates safety measures, that were developed by refrigeration system operators, into the procedures. BallPark Brands encourages employee participation in development of the control measures used at the plant through postings on bulletin boards, on-site television presentations and through formation of safety committees. Pursuant to written management of change procedures established by BallPark Brands, any changes to the operating procedures are to be communicated to affected employees. BallPark Brands understands that maintaining the refrigeration system in good working order is essential to preventing accidental releases; therefore BallPark Brands has implemented a preventative maintenance program. The prevent ative maintenance program is scheduled, documented and managed to ensure that regular maintenance occurs on the refrigeration system. Also, to ensure the mechanical integrity of critical refrigeration system, components inspections and tests are conducted on an annual basis by a third party contractor specializing in refrigeration systems. To ensure that BallPark Brands control measures are effective in maintaining the safe operation of the plant, audits are performed on the ammonia refrigeration system. 7 In accordance with the PSM program, BallPark Brands conducts detailed PSM compliance audits every three years that incorporates review of process safety information, process hazard analysis, operating procedures, training programs, system mechanical integrity, management of change, pre-start up review procedures, compliance audit procedures, incident investigation procedures, employee participation programs, hot work permit procedures, and contractor safety procedures. 7 BallPark Brands refrigeration systems are inspected annually by an independent third-party. 7 BallPark Brands maintains a USDA inspector on-site 24 hours a day, 7 days a week Five-Year Accident History Over the last five years, BallPark Brands has not experienced an accidental off-site release of anhydrous ammonia causing any on-site death, injury or significant property damage, or known off-site death, injury, property damage, environmental damage, evacuations or sheltering in place. Emergency Response Program BallPark Brands has developed a comprehensive emergency response program designed to protect both employees and the community in the event of a release. This program is fully described in a document entitled "Emergency Action Plan", "Plant Emergency Organization", and "City of Philadelphia Emergency Planning Guide" in order to facilitate response efforts in the event of off-site releases of anhydrous ammonia. Included in the emergency response plans are measures to be taken interna lly by BallPark Brands as well as measures to be taken by off-site response agencies. BallPark Brands has trained approximately 12 on-site personnel to respond to accidental releases of regulated substances. These personnel are trained in accordance with 29 CFR 1910.120, OSHA's Hazardous Operations and Emergency Response regulations according to their duties and function. These personnel receive initial training and annual update training thereafter. To assure that the local governmental response agencies are familiar with BallPark Brands emergency response procedures, BallPark Brands has submitted copies of the Emergency Planning Guide for review and approval by the Philadelphia Local Emergency Planning Commission (LEPC). The following local agencies have reviewed BallPark Brands Emergency Planning Guide: 7 Philadelphia LEPC 7 Philadelphia Fire Department Hazardous Material Administrative Unit 7 Local Fire Department To pre-plan for an ammonia release with off-site effects, Bal lPark Brands emergency response includes procedures/equipment to mitigate the release, procedures to inform local response agencies, evacuation procedures, and procedures for public communication. In the event of an anhydrous ammonia release with off-site effects, the general public will be warned by the LEPC. Planned Changes to Improve Safety As a result of BallPark Brands initial process hazard analyses, several changes are planned at the facility to improve safety and prevent anhydrous ammonia releases. These changes are scheduled to be implemented by June 2002 and include upgrades to outdated equipment and piping, installation of remote emergency shut-offs, and adding manual overrides for all computerized systems. |