Sara Lee Bakery - Tarboro - 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), Sara Lee Bakery submits this Risk Management Plan (RMP) for operations at their Tarboro, North Carolina facility.  Sara Lee Bakery's operations include the manufacturing of frozen bakery products for public consumption packaged under the familiar brand names such as Sara Lee.  Sara Lee Bakery has been in operation at this facility for over 10 years providing quality bakery products and over 600  jobs to the local community. 
Accidental Release Prevention and Emergency Response Policy 
Sara Lee Bakery is committed to protecting the health of its employees, the surrounding community, and the environment.  It is Sara Lee Bakery's policy to maintain a safe and healthy workplace, protect the environment, and comply with all applicable regulations, including 40 CFR 68 and, as applicable, Occupational Safety and Health Administration 
(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).  
Stationary Sources and Regulated Substances 
Sara Lee Bakery 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) [Federal Department of Agriculture (FDA)] to ensure quality in the final products.  Sara Lee Bakery also operates freezers and coolers for product storage.  Sara Lee Bakery uses anhydrous ammonia (the 112(r) regulated substance) as a refrigerant to maintain the 375,000 ft2 facility within the required range of operating temperatures and to operate the freezers and coolers.  Anhydrous ammonia is an industry-standard refrigerant for bakery  plants. Sara Lee Bakery's refrigeration system, consisting of receivers, compr 
essors, evaporators, condensers, and piping, can contain a maximum amount of 38,000 pounds of anhydrous ammonia. 
Worst Case Release Scenario 
As required by 40 CFR 68 Subpart B, Sara Lee Bakery has evaluated a worst-case release scenario for anhydrous ammonia using the parameters specified by the EPA.  The worst-case release scenario is defined as the release of the entire contents of the largest single vessel over a 10-minute period.  Based on Sara Lee Bakery's refrigeration system, Sara Lee Bakery's worst case release scenario is the rupture of the largest single vessel (a receiver) containing 12,000 pounds of ammonia  when filled to 90% capacity, the maximum fill capacity allowed by Sara Lee Bakery operating and engineering controls. Using the EPA's RMP*Comp program, the maximum distance to the specified "endpoint" (a conservative distance established by EPA at which it is expected that a person could be exposed to the chemical for an hour without suffering irreversible health eff 
ects) includes offsite receptors. 
The worst-case release scenario was developed following EPA regulations and is not considered by Sara Lee Bakery to be a likely release scenario for the facility.  During normal operations, Sara Lee Bakery maintains the receivers at no more than 50% capacity.  Only during pump-down operations do the receivers have the potential to be filled to 90% of capacity.  The receivers are operated in pump-down mode 1% of the time during the year.   
Alternative Release Scenario 
A more realistic release scenario (alternative release) was developed by Sara Lee Bakery taking into consideration the 10-year history of operation's experience and the hazards identified in the process hazard analyses (PHAs) conducted to ensure that Sara Lee Bakery hazards are identified and minimized.  These analyses were conducted in accordance to Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Fe 
deral Regulations Chapter 1910, Section 119 (29 CFR 1910.119).  A more credible release scenario identified by Sara Lee Bakery would be a release caused by a rupture of a =" high pressure liquid pipe and a reasonable response time from the facility's Hazmat team.  
Accidental Release Prevention Program 
To prevent and mitigate accidental releases of anhydrous ammonia, Sara Lee Bakery has implemented several precautionary measures that include process/equipment controls, procedures, preventive-maintenance programs, employee training, and audit programs.   In addition, the ammonia refrigeration system itself is designed and constructed in accordance with ANSI/IIAR 2-1992 Standard for Equipment, Design, And Installation of Ammonia Mechanical Refrigerating Systems.  
Sara Lee Bakery has also developed and implemented a PSM program pursuant to OSHA regulations and as such, has evaluated the system for the potential of anhydrous ammonia releases.  Some of the controls installed to prevent ca 
tastrophic releases of ammonia are process equipment (pressure relief valves, backup pumps, and manual shutoffs) and automated controls (automatic shut-offs, ammonia leak detection system.  27 personnel to respond to potential ammonia releases (HazMat team). 
Sara Lee Bakery has developed standard operating procedures for all employees and contractors that have contact with the ammonia refrigeration system that incorporate safety measures into the procedures.  These safety procedures were developed by refrigeration system operators and are reviewed at least annually by means of SOP review session(s).  Process safety information for the refrigeration system is reviewed periodically as well.  Sara Lee Bakery encourages employee participation in development of the control measures used at the plant by means of Sara Lee Bakery newsletters and training sessions. Pursuant to written management of change procedures established by Sara Lee Bakery, any changes to the operating procedures are to 
be communicated to affected employees. 
Sara Lee Bakery understands that maintaining the refrigeration system in good working order is essential to preventing accidental releases; therefore Sara Lee Bakery has implemented a preventative maintenance program.  The preventative maintenance program is scheduled, documented and managed using a computer maintenance management software system to ensure that regular maintenance occurs on the system. 
To ensure that Sara Lee Bakery's control measures are effective in maintaining the safe operation of the plant, regularly scheduled audits are performed on the ammonia refrigeration system: 
In accordance with the PSM program, Sara Lee Bakery conducts detailed PSM compliance audits every three years.  Each audit 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 In addition, Sara Lee Bakery is audited by the local fire department on an annual basis. 
7 Sara Lee Bakery's insurance carrier also conducts independent audits on an annual basis. 
 Sara Lee Bakery is audited by the FDA annually. 
Five-Year Accident History 
Over the last five years, Sara Lee Bakery has not experienced an accidental off-site release of anhydrous ammonia from the ammonia refrigeration system. 
Emergency Response Program 
Sara Lee Bakery has devised 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 RESPONSE PLAN (ERP) in order to facilitate response efforts in the event of an off-site anhydrous ammonia release.  Included in the plan are measures to be taken internally by Sara Lee Bakery as well as  
measures to be taken by off-site response agencies. 
Sara Lee Bakery has trained approximately 27 on-site personnel to respond to accidental ammonia releases.  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.  In addition, simulations of emergency releases with off-site effects are conducted periodically by the Edgecombe County Emergency Management Coordinator to test the skills of Sara Lee Bakery's HazMat team.  Each simulation is critiqued and changes are made to the ERP as appropriate. 
To assure that the local governmental response agencies are familiar with Sara Lee Bakery's emergency response procedures, Sara Lee Bakery has submitted copies of the ERP for review and approval by the local agencies.  The following local agencies have reviewed and approved Sara Lee Bakery's ERP: 
dgecombe County Fire Department 
7 Edgecombe County LEPC 
To plan for an ammonia release with off-site effects, Sara Lee Bakery's ERP includes procedures/equipment to mitigate the release, procedures to inform local response agencies, transportation maps for response agencies, evacuation route maps, and procedures for public communication. 
In addition to the above local response agencies, Sara Lee Bakery has arranged emergency response assistance with a local clean-up contractor. 
In the event of an anhydrous ammonia release with off-site effects, the general public will be warned using the following methods: 
7 Broadcast message via the Edgecombe County Central Dispatch 
7 Police and fire vehicles equipped with public address systems, and 
7 Door-to-door notification of residents (if time permits). 
As backup measures, Sara Lee Bakery has arranged emergency response assistance with a local clean-up contractor.    
Continuing Efforts to Improve Safety 
As part of the Sara  
Lee Bakery's continuous efforts to improve the performance of its safety systems, several changes are planned at the facility to improve safety and prevent anhydrous ammonia releases.  These changes are scheduled to be implemented by 12/31/99.
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