RYAN FOODS COMPANY INC. - Executive Summary

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RYAN FOODS 
JACKSONVILLE FLORIDA 
RISK MANAGEMENT PLAN 
SUPPORT DOCUMENTATION 
 
                                       PREPARED MAY 1999 
TABLE OF CONTENTS 
 
 
SECTION    PAGE 
 
   1.0    INTRODUCTION    1 
       1.1    Regulatory Background    1 
       1.2    Applicability of RMP Rule to Facility    2 
       1.3    Defining Process    2 
       1.4    Program Level    2 
       1.5    Registration Information    3 
 
   2.0    WORST CASE RELEASE ANALYSIS    5 
       2.1    Toxic Substance (Anhydrous) Ammonia Release    5 
       2.2    Residential Population within Endpoint Radius    5 
       2.3    Public Receptors within Endpoint Radius    6 
       2.4    Environmental Receptors within Endpoint Radius    7 
 
   3.0    ALTERNATIVE RELEASE ANALYSIS    8 
       3.1    Toxic Substance (Anhydrous Ammonia) Release    8 
       3.2    Residential Population Within Endpoint Radius    9 
       3.3    Public Receptors within Endpoint Radius    9 
       3.4    Environmental Receptors within Endpoint Radius    9 
 
   4.0    5-YEAR ACCIDENT HISTORY    10 
 
   5.0    MANAGEMENT SYSTEM    11 
 
   6.0    PREVENTION PROGRAM    12 
       6.1    Process Safety Information    12 
       6.2    Process Hazard Analysis (PHA)    12 
 
       6.3    Operating Procedures    14 
       6.4    Training    14 
       6.5    Mechanical Integrity    14 
       6.6    Management of Change    15 
       6.7    Pre-Start Up Review    15 
       6.8    Compliance Audits    15 
       6.9    Incident Investigation    16 
       6.10    Employee Participation    16 
       6.11    Hot Work Permits    16 
       6.12    Contractors    17 
 
   7.0    EMERGENCY RESPONSE PROGRAM    18 
 
   8.0    RISK MANAGEMENT PLAN SUBMITTAL AND UPDATES    19 
       8.1    RMP Plan Submission    19 
       8.2    Resubmission and Updates    19 
       8.3    Implementation Schedule    20 
 
 
EXHIBITS 
 
   A    RMP Plan Submitted to EPA 
 
   B    Calculations for Alternative Scenario 
 
 
 
Section 1.0 
INTRODUCTION 
 
1.1 REGULATORY BACKGROUND 
 
The Clean Air Act required the U.S. Environmental Protection Agency (EPA) to promulgate regulations to prevent accidental releases of regulated substances, and to reduce the severity of those releases that do occur.  On June 20, 1996, EPA promulgated rules (Clean Air Act Section 112 [r] Risk Management Program Rule) that apply to all stationary sources with processes that contain more than a thr 
eshold quantity of a regulated substance.  By June 21, 1999, covered processes are required to meet the requirements of one of three program categories (Program 1, 2, or 3) based upon: 
 
 
7 The potential for off-site consequences associated with a worst-case accidental release; 
7 The facility's accidental release history; 
7 The applicability of OSHA's Process Safety Management (PSM) standard prevention requirements to the facility; 
7 The status of the facility's coordination of emergency response with the local emergency response agencies; and 
7 The facility's Standard Industrial Classification (SIC) Code. 
 
Processes that have little or no potential impact on the public in the event of an accidental release are required to comply with Program 1.  Processes that have the highest potential for impact on the public will be required to comply with Program 3.  All other processes are required to comply with Program 2. 
 
Covered facilities must develop and implement a Risk Management Program ( 
RMP) consisting of the following four elements: 
 
7 Hazard Assessment - Impact of possible releases to the surrounding community; 
 
7 Prevention Program - Written procedures in place to prevent releases; 
 
7 Management Program - A plan to ensure that the RMP is implemented; and 
 
7 Emergency Response Program - A plan of action to respond to a release. 
 
Together these four components constitute the RMP.  The RMP Plan that must be submitted electronically to EPA by June 21, 1999, must contain a summary of these four main components along with a certification that the information submitted is true, accurate and complete.  A hard copy of the RMP Plan to be submitted to the EPA is included in Exhibit A. 
 
 
1.2 APPLICABILITY OF RMP RULE TO FACILITY 
 
The Ryan Foods Company, Jacksonville, Florida facility utilizes anhydrous ammonia (CAS No. 7664-41-7) as a refrigerant to maintain the proper temperature of milk, and non-dairy products within the facility. 
Anhydrous ammonia is identified on the "List 
of Regulated Flammable Substances and Threshold Quantities for Accident Release Prevention," with a threshold quantity of 10,000 pounds.  The refrigeration system at the facility meets this requirement so therefore the entire refrigeration system is subject to the RMP rule. 
 
 
 
1.3 DEFINING PROCESS 
 
The EPA RMP Rule defines a "process" as any activity involving a regulated substance including any use, storage, manufacturing, handling, or on-site movement of such substances, or a combination of these activities.  For the purposes of this definition, any group of vessels that are interconnected, or separate vessels that are located such that a regulated substance could be involved in a potential release, shall be considered a single process." 
Because the refrigeration system holds greater than 10,000 pounds of anhydrous ammonia, the entire refrigeration system, including the receiver, evaporators, compressors, piping, and valves, is considered part of the covered process. The refrigerati 
on system consists of approximately 30 pieces of equipment. 
 
 
 
1.4 PROGRAM LEVEL 
In order to be eligible for Program 1, the process must meet two basic criteria: 
 
 
 
7 There must be no public receptors within the distance to an endpoint from the worst-case release scenario; and 
 
7 No accidental release of ammonia can have caused off-site deaths, injuries, or response or restoration activities for an environmental receptor. 
 
The worst case release analysis (see Section 2.2) involves public receptors, and therefore, the process is not eligible for Program 1.  The process is subject to OSHA's Process Safety Management Program (PSM) , and therefore, it is not eligible for Program 2.  The process is not eligible for Program 1, nor is it eligible for Program 2 because it is subject to PSM. Therefore it is subject to Program 3. 
 
 
1.5 REGISTRATION INFORMATION 
 
Most of the information provided in the Registration Section of the RMP Plan submitted to the EPA (see Exhibit A) was provided by the fa 
cility.  Note the following regarding this information: 
 
7 Section1.5 Latitude and Longitude: 
 
The Facility's Form R report listed the latitude as 030 degrees, 19 minutes, and 56 seconds 
The Facility's Form R report listed the longitude as -081 degrees, 41 minutes, and 55 seconds. 
 
7 Section 1.8d&e - 24-hour Phone: 
 
The number inserted here is the home number for Jeff Kragt, Plant Manager. 
 
7 Section 1.9 Other Points of Contact: 
 
Completing this section is optional. 
 
7      Section 1.11 Number of Employees On Site: 
 
This number represents the number of full time employee equivalents and was calculated as follows: 
 
128 full time employees 
 
7 Section 1.17b NAICS Code: 
 
The NAICS Code selected was 311511, Fluid Milk Manufacturing.  This corresponds to a SIC code of 2026, which is the SIC Code reported on the Form R. 
 
7 Section 1.17c.3 Maximum Quantity of Ammonia: 
 
The maximum quantity of ammonia inserted was 10,675 pounds, which is the approximate maximum amount of ammonia that is in the  
system, at any 
One time, according to the information provided in the facility's PSM program. 
 
Section 2.0 
WORST CASE RELEASE ANALYSIS (40 CFR 68.25) 
 
 
2.1 TOXIC SUBSTANCE (ANHYDROUS AMMONIA) RELEASE 
 
EPA's "Risk Management Program Guidance for Ammonia Refrigeration" (November 1998) and the International Institute of Ammonia Refrigeration's (IIAR) Risk Management Guidelines (1998) were the primary documents used to develop the worst case release scenario.  The worst case release is one that is unlikely to occur.  The purpose of the worst case release analysis is to support a dialogue with the community on release prevention. It is a conservative analysis and is not to serve as a rational basis for actual emergency response planning. 
 
 
The worst case release scenario is defined under 40 Code of Regulations (CFR) 68.25 as "the release of the largest quantity of ammonia from a vessel or process line failure that results in the greatest distance to a toxic endpoint."  The worst case relea 
se scenario for the refrigeration process is assumed to be a case where the total quantity of ammonia in the high pressure receiver is released.  The receiver is located in an area on the front (north - east) side of the facility.  The receiver is capable of holding 6,096 pounds of ammonia when at 100% capacity (the greatest amount that would ever be placed in the receiver).  There are no passive mitigation systems (dikes, berms, drains, sumps or enclosures) considered in the analysis because the receiver is located outdoors. 
 
 
According to the IIAR Guidance (Chapter 4, page 4-8), the release should be reported as a "gas" because ammonia is normally a gas at ambient temperature and is handled as a gas liquified under pressure.  According to EPA's Guidance (Chapter 4, page 4-6), the release rate, where no passive mitigation is assumed, is calculated by dividing the total quantity released by 10 minutes.  In this case the release rate is 6096/10 or 609 pounds per minute. 
 
 
The meteorolog 
ical defaults to be used (unless other data is available) are a wind speed of 1.5 meters per second and an Atmospheric Stability Class of "F." 
 
 
According to Appendix A to 40 CFR 68.22, and EPA's guidance, the toxic endpoint used for this scenario must be where the ambient concentration of ammonia is 0.14 mg/L or less.  This endpoint is a concentration below which nearly all individuals could be exposed to for one hour without serious health effects.  Based Exhibit 4-4 in EPA's guidance, with a release rate of 600 pound per minute (rounded 609 to nearest value on the table), and an urban topography, the distance to the toxic endpoint is .90 miles. 
 
 
2.2 RESIDENTIAL POPULATION WITHIN ENDPOINT RADIUS (40 CFR 68.30) 
 
The facility is located in an urban area surrounded primarily by residential area. There are a few commercial establishments located within the toxic end point. There is also an Elementary school within this area. The population within this area is aproxamently 7448 persons.  
 
 
 
 
2.3 PUBLIC RECEPTORS WITHIN ENDPOINT RADIUS (40 CFR 68.30) 
 
The rule (40 CFR 68.3) defines a public receptor as "off-site residences, institutions (e.g., schools and hospitals), industrial, commercial, and office buildings, parks, or recreational areas inhabited or occupied by the public at any time without restriction by the stationary source where members of the public may be exposed to toxic concentrations, radiant heat, or overpressure, as a result of an accidental release."  Schools, residences, hospitals, prisons, public recreational areas or arenas, or commercial or industrial areas within the radius to the toxic endpoint must be reported.  A list of all public receptors, however, is not required. 
Public receptors located within the toxic endpoint were determined using a visual observation of the area surrounding the facility. 
 
The following are public receptors located within the toxic endpoint: 
7 Hollybrook apartment complex and surrounding neiborhood. 
 
7 Rental service co 
rp. and a few other small businesses.   
 
7 West Jacksonville Elementary School 
 
7 Duval Christian School 
 
7 Technical High School 
 
7 Livingston School                                                                                                                          
There are no known hospitals, prisons/correctional facilities, or recreational areas within the toxic endpoint.  
 
2.4 ENVIRONMENTAL RECEPTORS WITHIN ENDPOINT RADIUS (40 CFR 68.33) 
 
Environmental receptors (as defined by the RMP Rule) located within the toxic endpoint were determined using a combination of the Landview III software and a USGS map. 
There are no national or state parks, forests or monuments, officially designated wildlife sanctuaries, preserves or refuges, or federal wilderness areas within the toxic endpoint. According to EPA's guidance, only environmental receptors that is shown on a USGS 
map need to be considered.              
 
 
Section 3.0 
ALTERNATIVE RELEASE ANALYSIS 
 
 
3.1 TOXIC SUBSTANCE (ANHYDROUS  
AMMONIA) RELEASE (40 CFR 68.28) 
 
According to 40 CFR 68.28, covered facilities must identify and analyze at least one alternative release scenario for each regulated toxic substance used in a covered process. The alternative release scenario is one that is more likely to occur than the worst case release scenario. 
 
EPA's "Risk Management Program Guidance for Ammonia Refrigeration" (November 1998) and the International Institute of Ammonia Refrigeration's (IIAR) Risk Management Guidelines (1998) were the primary documents used to develop the alternative release scenario.   
 
The alternative release scenario must meet two criteria: 
 
1.    Must be more likely to occur than the worst case scenario, and 
 
2.    Must reach an endpoint off site, unless no such criteria exist. 
 
According to EPA's guidance, the meteorological defaults to be used in the alternative analysis (unless other data is available) are a wind speed of 3 meters per second and an Atmospheric Stability Class of "D." 
 
In determining 
the alternative release, the 5-year accident history and failure scenarios identified in the hazard review must be considered.  There has been no RMP reportable release in the past five years.  
 
A more likely alternative release scenario would be the lifting of a relief valve.  A relief valve will lift in the event of an overpressurization of the system to relieve pressure.  The capacities of the facility's refrigeration system relief valves range from 30.9 to 138 pounds ammonia per minute.  The average value of the relief valves is 50 pounds per minute.  Many of the valves are located inside the building, therefore, the building would serve to attenuate the release to the outside atmosphere in many instances.  Building attenuation cannot be considered, however, if the release occurs near an open door or window or outside.  For the alternate release scenario, it was assumed that a relief valve lifts either outside or near an open door or window.  A relief rate of 50 pounds per minute  
was assumed because it is the average relief valve capacity.  Because the facility has installed ammonia sensors throughout the cooler area and in the compressor room, it was assumed that a release would last only 10 minutes, which is EPA's default for most of its release scenarios.  Therefore, the total release to the atmosphere is assumed to be 500 pounds (50 pounds per minute X 10 minutes). 
 
The toxic endpoint used for this scenario must be where the ambient concentration of ammonia is 0.14 mg/L or less.  Based Exhibit 4-5 in EPA's guidance, with a release rate of 50 pounds per minute, the distance to the toxic endpoint is 0.10 miles with either urban or rural topography. 
 
 
3.2 RESIDENTIAL POPULATION WITHIN ENDPOINT RADIUS (40 CFR 68.30) 
 
The residential population within the distance to the endpoint for the alternative release analysis.  That population is estimated as 131 persons. 
 
 
3.3 PUBLIC RECEPTORS WITHIN ENDPOINT RADIUS (40 CFR 68.30) 
 
Public receptors located within the end 
point for the alternative release analysis were determined by a visual observation of the area surrounding the facility.  Only one type of public receptor is located within the endpoint for the alternative release analysis: 
 
7 Residences (to the north of the facility) 
 
There are no schools, hospitals, prison/correctional facilities, or recreational areas located within the distance to the endpoint. 
 
 
3.4 ENVIRONMENTAL RECEPTORS WITHIN ENDPOINT RADIUS (40 CFR 68.33) 
 
Environmental receptors (as defined by the RMP Rule) located within the endpoint for the alternative release analysis were determined using a combination of the Landview III software and a USGS map.  There are no national or state parks, forests or monuments, officially designated wildlife sanctuaries, preserves or refuges, or federal wilderness areas within the endpoint for the alternative release. 
 
 
Section 4.0 
5-YEAR ACCIDENT HISTORY (40 CFR 68.42) 
 
 
In accordance with 40 CFR 68.42, the five-year accident history must c 
onsider only releases where: 
 
1) The release must be from a covered process and involve a regulated substance held above its threshold quantity in the process. 
 
2) The release must have caused at least one of the following: 
 
7 On-site deaths, injuries, or significant property damage; or 
7 Known off-site deaths, injuries, property damage, environmental damage, evacuations, or sheltering in-place. 
 
 
According to 40 CFR 68.42(b), the following information regarding the 5-year accident history must be reported: 
 
1) Date, time and approximate duration of the release 
2) Chemical released 
3) Estimated quantity released in pounds 
4) Type of release event and source 
5) Weather conditions, if known 
6) On-site impacts 
7) Known off-site impacts 
8) Initiating event and contributing factors 
9) Whether off-site responders were notified, and 
10) Operation or process changes that resulted from the incident investigation 
 
 
There have been no accidental releases that meet the above criteria. 
Section 5.0 
 
MANAGEMENT SYSTEM 
 
 
The RMP Rule (40 CFR 68.15) requires the development of a system to oversee the implementation of the RMP Program elements.  The Plant Manager has the overall responsibility for the development, implementation, and integration of the RMP elements.  At the practical level, the Plant Engineer and the Plant Services Coordinator will implement and integrate the RMP Program.  Specifically, the responsibilities are broken down as follows: 
 
 
Risk Management Program Element    Department or Position Assigned Responsibility 
Overall Responsibility    Jeff Kragt 
Process Safety Information    Plant Engineering/Plant Services Coordinator 
Process Hazard Analysis    Plant Engineering, Superintendents, Plant Services Coordinator 
Operating Procedures    Plant Engineering 
Training    Plant Engineering/Plant Services Coordinator 
Mechanical Integrity    Plant Engineering 
Management of Change    Plant Engineering/Plant Services Coordinator 
Pre-Start Up Review    Plant Engineering 
Compliance Audits    Plant Engineer 
ing and Plant Services Coordinator 
Incident Investigations    Plant Engineering and Plant Services Coordinator 
Employee Participation    Plant Engineering and Plant Services Coordinator 
Hot Work Permits    Plant Engineering/Plant Services Coordinator 
Contractors    Plant Engineering/Plant Services Coordinator 
 
Section 6.0 
PREVENTION PROGRAM 
 
 
A Program 3 Prevention Program incorporates the basic elements that are a foundation of sound prevention practices: 
 
7 Process Safety Information (40 CFR 68.65) 
7 Process Hazard Analysis (PHA) (40 CFR 68.67) 
7 Operating Procedures (40 CFR 68.69) 
7 Training (40 CFR 68.71) 
7 Mechanical Integrity (40 CFR 68.73) 
7 Management of Change (40 CFR 68.75) 
7 Pre-Start Up Review (40 CFR 68.77) 
7 Compliance Audits (40 CFR 68.79) 
7 Incident Investigation (40 CFR 68.81) 
7 Employee Participation (40 CFR 68.83) 
7 Hot Work Permits (40 CFR 68.85) 
7 Contractors (40 CFR 68.87) 
 
These elements are covered in detail in Ryan Foods Process Safety Management (PSM) Program that was de 
veloped and implemented in order to comply with OSHA's standard found in 29 CFR 1910.119.  Ryan Foods PSM Program was prepared pursuant to the PSM regulations, using IIAR's PSM Guidance. Information regarding each of these elements as they relate to the RMP Plan is summarized in the next subsections. 
 
 
6.1 PROCESS SAFETY INFORMATION (40 CFR 68.65) 
 
The Engineering Department maintains process safety information.  In Section 7.3 of the RMP Plan, the date of the most recent Process Instrumentation Drawing September 1997 was inserted as the date on which safety information was last reviewed or revised. 
 
 
6.2 PROCESS HAZARD ANALYSIS (PHA) (40 CFR 68.67) 
 
A hazard review must be updated at least every 5 years.  A hazard review must also be performed whenever there is a significant change to the equipment, processes, or substances used in the process.  The primary objective of a hazard review is to identify the following: 
 
7 The hazards associated with the process, 
 
7 Opportunities for equip 
ment malfunctions or human errors that could cause an accidental release, 
 
7 Safeguards used or needed to control the hazards or prevent equipment malfunction or human error, and 
 
7 Any steps used or needed to detect or monitor releases. 
 
The date of completion of the most recent hazard review/update inserted in Section 7.4 of the RMP Plan is the date of the last PHA performed for the PSM Program (April 16, 1997).  A "What If/Checklist" format developed by the IIAR was used to perform the PHA. 
 
Under 40 CFR 68.67, process hazard analyses that are completed in order to comply with OSHA's Process Safety Management Standard are acceptable as process hazard analyses under the RMP regulations. 
 
The expected date of completion of any changes resulting from the PHA inserted in Section 7.4c of the RMP Plan is April 16, 1997, the same day of completion of the PHA, because no specific new changes were recommended in the updated PHA. 
 
The major hazards identified in the RMP Plan were as follows: 
 
 
7 Toxic Release (various references) 
7 Overpressurization (Pressure Vessel) 
7 Corrosion (Piping and Valves) 
7 Overfilling (System Charging) 
7 Equipment Failure (multiple references) 
7 Loss of Cooling, Heating, Electricity, Instrument Air (Emergency)  
 
These items are addressed in detail in Ryan Foods' PSM Program.  The word in the parentheses refers to the chapter of the PSM Program in which they are addressed. 
 
The process controls in use identified in the RMP Plan were: 
 
7 Vents 
7 Relief valves 
7 Check valves 
7 Manual shutoffs 
7 Automatic shutoffs  
7 Interlocks 
7 Alarms and procedures  
7 Purge System 
 
The mitigation systems identified in the RMP Plan were: 
 
7 Sprinkler System 
7 Enclosure (building) 
 
Monitoring/detection systems identified in the RMP Plan were: 
 
7 Process area detectors 
 
Ammonia sensors were installed in the cooler area and the ammonia compressor room. Since the last hazard review, the primary improvement has been to install process detection systems (Section 7.4h of 
the RMP Plan). 
 
 
6.3 OPERATING PROCEDURES (40 CFR 68.69) 
 
Written operating procedures have been prepared to cover practices to safely operate the ammonia system.  These are documented in the PSM Program.  The date of the most recent review of operating procedures inserted in Section 7.5 of the RMP Plan was April 16,1997 
6.4 TRAINING (40 CFR 68.71) 
An update of training is required at least every three years, or earlier if any major change is made to the process. 
 
The last training of the personnel on the operation and safety of the ammonia system was classroom training performed on February 13, 1997.  This date was inserted in Section 7.6 of the RMP Plan.   
 
Requirements for training are as follows: 
 
7 All new workers to be trained on operating procedures developed, 
7 Existing workers to be trained if necessary, 
7 If operating procedures are revised, all workers must be trained, 
7 Refresher training must be performed at least once every 3 years, and 
7 Competency testing will be perfo 
rmed to verify training. 
 
6.5 MECHANICAL INTEGRITY (40 CFR 68.73) 
 
Preventive maintenance and inspection and testing of equipment are critical to safe operations.  Inspection and testing follows recognized and generally acceptable good engineering practices, and are consistent with manufacturers recommendations. The entire refrigeration system is inspected annually using the IIAR Bulletin109.   
 
In addition, the Engine Room log is completed daily.  The Preventive Maintenance work orders are generated by the computerized Maintenance Management systems as needed. The date of the most recent review or revision of maintenance procedures and the most recent equipment inspection was September 1997.  A date of September 1, 1997 was inserted in Section 7.7a and 7.7 b of the RMP Plan, because the exact date in September 1997 was not known. 
 
 
6.6 MANAGEMENT OF CHANGE (40 CFR 68.75) 
 
Management of change is addressed in the PSM Program.  The purpose is to ensure that if the process is changed, em 
ployees are properly notified and trained in the change before startup, and process safety information and operating procedures are updated to reflect the change.  There has been no changes to the procedures. 
 
The date of the most review or revision of management change procedures was August 1, 1998.  This date represents an internal Dean Foods' memo from Mr. Larry Basel regarding Management of Change.  This date was inserted in Section 7.8b of the RMP Plan. 
 
 
6.7 PRE-START UP REVIEW (40 CFR 68.77) 
 
A pre-start up review must be performed for new covered processes or a modification of the process that is significant enough to require a change in process safety information. 
 
The date of the most recent pre-start up review inserted in Section 7.9 of the RMP was April 16,1997.  
 
6.8 COMPLIANCE AUDITS (40 CFR 68.79) 
 
Compliance audits must be performed at least once every 3 years to verify that the ammonia system has been evaluated with respect to compliance with the prevention program re 
quirements.  This audit should be conducted by at least one person knowledgeable about the process.  A report of findings must be developed to document an appropriate response to each finding and document the corrections to any deficiency.  The two most recent audit reports must be kept onsite. 
 
The date of the compliance audit listed in the RMP Plan is April 16,1997 as listed in the audit documents of the PSM Program documentation.  This date was inserted in Section 7.10a of the RMP Plan. 
 
 
6.9 INCIDENT INVESTIGATION (40 CFR 68.81) 
 
If an incident occurs from the ammonia process that resulted in or could have resulted in a catastrophic release of ammonia, the incident must be investigated with 48 hours following the incident.  The incident report must identify the following: 
 
7 Factors contributing to the incident and underlying cause 
7 Recommendations for corrective actions 
7 All data needed for five-year accident history 
 
 
Investigation Reports must be retained for 5 years. 
 
The dat 
e of the most recent incident investigation was not listed because there have been no incidents in the past five years. 
 
 
6.10 EMPLOYEE PARTICIPATION (40 CFR 68.83) 
 
Employee participation is covered in the PSM Program.  It requires that a written plan be developed to include employee participation on the conduct and development of process hazard analyses and on the development of the other process safety elements of the RMP Program.  The date of the most recent review or revision of employee participation plans was April 16,1997.  This was the date of the last PHA.  This date was inserted in Section 7.12 of the RMP Plan. 
 
 
6.11 HOT WORK PERMITS (40 CFR 68.85) 
 
Hot work permits must be issued for hot work on or near covered processes.  Hot work permits are covered in the PSM Program. The date of the most recent review or revision of hot work permits was April 04.1999.  This date was inserted in Section 7.13 of the RMP Plan. 
 
 
6.12 CONTRACTORS (40 CFR 68.87) 
 
If contractors work on or a 
djacent to a covered process, a program must be developed to check safety performance, provide safety and hazard information, ensure safe practices, and to verify that the contractor acts responsibly.  The facility has already implemented a contractor program as part of the PSM Program.  The date of the most recent review or revisions of contractor safety procedures was April 04,1999  This date was inserted in Section 7.14 of the RMP Plan. 
 
 
Section 7.0 
EMERGENCY RESPONSE PROGRAM (40 CFR 68.95) 
 
 
The District Four Local Planning Committee has indicated that if a facility submits a Tier I/II 
Form annually every March 1,the facility will be included in their Emergency Response Plan. Therefore,"yes" was checked in response to question 9.1 of the RMP Plan. 
 
 
Ryan Foods is subject to a number of federal, state, and local regulatory requirements related to emergency preparedness, prevention, response and reporting. Several of these  
Regulations require written plans to demonstrate complianc 
e. Ryan foods Company has developed a spill prevention, Control and countermeasures (SPCC) plan to address the prevention of and response to the spills of petroleum products. In addition, the facility has developed an Emergency Response Plan as part of its OSHA PSM program. Therefore "yes" was checked in response to question 9.1b of the RMP Plan.   
 
 
The most recent review or update of this plan was August 1998. This date was inserted in Section 9.5 of the RMP Plan. 
 
In the event that the facility requires outside assistance, it will contact " 911" which will activate the Jacksonville Police Department and the Jacksonville Fire Department.  
Section 8.0 
RISK MANAGEMENT PLAN SUBMITTAL AND UPDATES 
 
 
8.1 RMP PLAN SUBMISSION 
 
The RMP Plan submitted to EPA was submitted using RMP* Submit.  It was submitted electronically on  June 18,1999  .  A hard copy of the submittal is located in Exhibit A. 
 
 
8.2 RESUBMISSION AND UPDATES 
 
All RMPs must be updated and submitted at least once every 5 year 
s.  The schedule for resubmission and updates is as follows: 
 
 
Situation    Schedule 
No changes    Within 5 years of initial submission 
New Regulated Substance listed by EPA    Within 3 years of substance listed 
Regulated substance first present above threshold    On or before date that exceed threshold 
Change that results in a revised hazard review    Within 6 months of the change 
Change requiring revised off-site consequence analysis (distance to worst-case endpoint changes by at least a factor of 2)    Within 6 months of the change 
Change occurs that alters program level of any covered process    Within 6 months of the change 
Change makes facility no longer subject to RMP    Within 6 months of the change 
 
 
Note:    The "Predictive Filing" can be used if the facility anticipates that a regulated substance will be on site in an amount greater than the threshold quantity, but is not on site at the time of submission. 
 
8.3    IMPLEMENTATION SCHEDULE 
 
The following represent the schedule for implementation of the RM 
P based on the dates presented in this support documentation.  It does not represent all required activities related to PSM. 
 
 
RMP Item    Initial Date    Update Required* 
RMP Submittal    June 1999    June 2004 
Process Hazard Analysis (PHA)    February 1997    February 2002 
Training    Varies by employee    Every 3  years 
Compliance Audit    April 1997    April 2000 
 
 
*Assuming no new covered processes or significant changes 
 
 
EXHIBIT A 
 
RMP PLAN SUBMITTED TO EPA
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