Hillshire Farm & Kahn's - 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), Hillshire Farm & Kahns submits this Risk Management Plan (RMP) for operations at their New London, Wisconsin facility. Hillshire Farm and Kahns operations include the processing of meat products (hot dogs, sausages, hams and deli meats) for public consumption packaged under the familiar brand names of Hillshire Farm and Deli Select. Hillshire Farm and Kahns has been in operation at this facility for over 50 years providing quality meat products and over 1000 jobs to the local community. Accidental Release Prevention and Emergency Response Policy Hillshire Farm and Kahns is committed to protecting the health of its employees, the surrounding community, and the environment; therefore it is Hillshire Farm and Kahns policy to manage a safe and healthy workplace, protect the environment, and maintain compliance with safety, health, and environmental regulations: 40 CFR 68 as 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 OSHAs Hazardous Operations and Emergency Response regulations (29 CFR 1910.120). Stationary Sources and Regulated Substances Hillshire Farm and Kahns 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. Hillshire Farm and Kahns uses anhydrous ammonia (a 112(r) regulated substance) as a refrigerant to maintain the 500,000 ft2 facility within the required range of operating temperatures. Anhydrous ammonia is an industry-standard refrigerant for meat processing plants. Hillshire Farm and Kahns refrigeration system consisting of receivers, compressors, evaporators, condensers, and piping can contain a maximum amount of 120,000 pounds of anhydrous ammonia. Worst Case Release Scenario Anhydrous Ammonia As required by 40 CFR 68 Subpart B, Hillshire Farm and Kahns has evaluated a worst-case release scenario for anhydrous ammonia using the parameters specified by the EPA. Hillshire Farm and Kahns worst case release scenario would be the rupture of the largest single receiver when filled to 80% capacity (the maximum tank capacity limited by engineering controls) over a 10-minute period. Using the EPAs RMP*Comp program, the maximum distance to the toxic endpoint is 1.8 miles. The worst-case release scenario was developed following EPA regulations and is not considered to be a likely release scenario. During normal operations, Hillshire Farm and Kahns maintains the receivers at 40% capacity. Only during pump-down operations do the receivers have the potential to be filled to 80% of capacity. The receivers are operated in pump-down mode onl y when there is an emergency in the plant. The system has operated in pump-down mode twice in its history. Alternative Release Scenario Anhydrous Ammonia A more realistic release scenario (alternative release) was developed by Hillshire Farm and Kahns taking into consideration the 50-year history of operations experience and the hazards identified in the process hazard analyses (PHAs) conducted to ensure that Hillshire Farm and Kahns 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 Hillshire Farm and Kahns would be a release caused by a faulty piping valve located on the roof of the plant. In developing the release parameters of the scenario, Hillshire Farm and Kahns considered that the contents of the interconnected piping and receivers would be released before the system could be shut down. Using EPAs RMP*Comp program, the maximum distance to the toxic endpoint is 0.80 miles. 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, Hillshire Farm and Kahns has implemented several precautionary measures, such as process/equipment controls, standard operating procedures, preventative maintenance programs, employee training and audit programs. Hillshire Farm and Kahns maintains a no odor policy. The no odor policy instructs employees that detect an ammonia odor to call the Utilities Maintenance staff and the Utilities Maintenance staff must respond immediately to the call to address the situation. Hillshire Farm and Kahns has implemented and is in compliance with OSHAs PSM regulations and as such, has evaluated and engineered for anhydrous ammonia releases. Some of the controls installed to prevent catastrophic releases of ammonia are process equipment (vents, pressure relief valves, backup pumps, and manual shutoffs) and automated controls (automatic shut-offs, ammonia leak detection system, and electrical distribution system grounding). In addition, Hillshire Farm and Kahns has trained approximately 37 personnel to respond to potential ammonia releases (HazMat team). Hillshire Farm and Kahns has developed standard operating procedures (SOP) 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 on an annual basis by means of a SOP review session. Process safety information for the refrigeration system is revie wed during these annual meetings as well. Hillshire Farm and Kahns encourages employee participation in development of the control measures used at the plant by means of the annual procedures review. Any changes to the operating procedures are communicated to affected employees following written management of change procedures established by Hillshire Farm and Kahns. Hillshire Farm and Kahns understands that maintaining the refrigeration system in good working order is essential to preventing accidental releases; therefore Hillshire Farm and Kahns has implemented a preventative maintenance program. The preventative 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, auditing is conducted every 5 years by a certified refrigeration contractor. To ensure that Hillshire Farm and Kahns control measures are effective in m aintaining the safe operation of the plant, regularly scheduled audits are performed on the ammonia refrigeration system. 7 In accordance with the PSM program, Hillshire Farm and Kahns 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 In addition, Hillshire Farm and Kahns will implement auditing by the local fire department or Department of Commerce on an annual basis Five-Year Accident History Over the last five years, Hillshire Farm and Kahns has not experienced an accidental 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 Hillshire Farm and Kahns 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 RESPONSE & SPILL PREVENTION CONTROL & COUNTERMEASURES PLAN (ERSPCC) in order to facilitate response efforts in the event of off-site releases of anhydrous ammonia. Included in the ERSPCC are measures to be taken internally by Hillshire Farm and Kahns as well as measures to be taken by off-site response agencies. Hillshire Farm and Kahns has trained approximately 37 on-site personnel to respond to accidental releases of regulated substances. These personnel are trained in accordance with 29 CFR 1910.120, OSHAs Hazardous Operations and Emergency Response regulations according to their duties and function. These personnel receive initial training and annual update training thereafter. Hillshire Farm and Kahns stages mock release incidents annually to test the skills of the HazMat team. To assure that the local governmental response agencies are familiar with Hillshire Farm and Kahns emergency response procedures, Hillshire Farm and Kahns has submitted copies of the ERSPCC for review and approval by the local agencies. The following local agencies have reviewed Hillshire Farm and Kahns ERSPCC: 7 Outagamie County Local Emergency Planning Committee (LEPC) 7 State Emergency Response Commission 7 New London Fire Department 7 New London Police Department 7 Outagamie County Sheriff 7 New London Family Medical Center 7 Appleton Medical Center 7 Appleton Hazardous Materials Response Team To pre-plan for an ammonia release with off-site effects, Hillshire Farm and Kahns ERSPCC includes procedures/equipment to mitigate the release, procedures to inform local response agencies, evacuation procedures, and procedures for public communication. In th e event of an anhydrous ammonia release with off-site effects, the general public will be warned by the LEPC according to the facilitys off-site plan which is updated on an annual basis by the LEPC. Continuous Efforts to Improve Safety As a part of Hillshire Farm and Kahns 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 in 2005 and include refrigeration piping upgrades and relocation of piping to the roof of the facility. |