Rosani Foods - Executive Summary |
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EXECUTIVE SUMMARY Accident Release Prevention Program and Emergency Response Policy It is the policy of the Rosani Foods, Inc. (Rosani) facility management to implement the requirements of this Risk Management Program (RMP) in accordance with the USEPA regulations under 40 CFR Part 68 and with the corresponding regulations under OSHA's Process Safety Management (PSM) program. The objective is to minimize the risk of a release of a hazardous material and if a release occurs, to minimize the potential impact to Rosani employees, the public and the environment. This objective will be accomplished by utilizing general good operating procedures, providing appropriate training to all employees, and coordinating response activities, as necessary, with the local emergency response providers. Rosani's management is committed to providing the resources necessary to implement this policy. Facility Description Rosani operates a food processing operation at this facility (see Figures 1-1 and 1-2). Wholesale pepperoni is the main product produced by Rosani at this facility. Operations at the facility include ovens, drying rooms and a number of coolers and chillers. One chemical, ammonia, is utilized at the facility in sufficient quantities to be subject to the requirements of 40 CFR Part 68. Ammonia is used as a refrigerant throughout the facility. Worst-Case and Alternative-Case Release Scenarios RMP regulations require that each facility identify worst-case and alternative-case release scenarios. USEPA has defined a worst-case toxic release as the release of the entire contents of the largest vessel that contains a regulated substance in a 10-minute period. This release rate is then evaluated using modeling techniques and/or reference tables to define the distance to a specified endpoint (concentration or overpressure). The distance to the endpoint is affected by several factors including molecular weight, volatility, heat of combustion, and physical setting (urban or rural). T he alternative-case release scenario for each covered process must be one that is more likely to occur than the worst-case scenario and that reaches an endpoint offsite, unless no such scenario exists. The alternative-case release scenario is evaluated using the same techniques as the worst-case release scenario to define the distance to the specified endpoint. Under 40 CFR 68 Subpart B '68.22(e), the RMP rule identifies surface roughness as a parameter to be used in the hazard assessment to determine the physical setting of the site, urban or rural. "Urban means there are many obstacles in the immediate area; obstacles include buildings or trees. Rural means there are no buildings in the immediate area and the terrain is generally flat and unobstructed." Due to the presence of trees, hills, and/or other structures in the immediate vicinity of the Dallas, Texas facility, an urban dispersion environmental was assumed. Ammonia The data provided in the document "Model Risk Management Pr ogram and Plan for Ammonia Refrigeration" (May 1996) was used to estimate the toxic endpoint distance for the worst-case and alternative-case ammonia release scenarios. The EPA's "RMP Off-site Consequence Analysis Guidance" (May 1996) was not used to determine the toxic endpoint since it classifies ammonia as a "neutrally buoyant gas." The worst-case ammonia release scenario would involve liquid and would come from a pressurized liquid system; therefore, the released gas should be classified as a "dense gas" (a result of evaporative cooling). The ammonia refrigeration document provides calculated endpoint distances for typical meteorological conditions. The worst-case release scenario for an anhydrous ammonia release is a release of all the contents of the high-pressure receiver tank in a 10-minute period (per EPA guidelines). This release translates to a release of 15,399 pounds of ammonia in 10 minutes or 1,540 lbs/min. Other assumptions included in the worst-case assessment are: the ammonia is a liquefied gas; the receiver tank is not diked; the nearfield dispersion environment is characterized as urban; 10-minute averaging period; the wind speed is 1.5 meters/sec and the atmospheric stability is classified as F (stable). The results of the worst-case scenario for an ammonia release shows that the plume must travel 1.40 miles (2.25 kilometers) before dispersing to the endpoint concentration of 200 ppm. Figure 1-3 details the ammonia worst-case release zone. The selected alternative-case release scenario for the ammonia system is a release from an ammonia transfer line in the instance a truck is to drive off during filling operations. The delivery truck is equipped with two relief valves at both ends of the truck; therefore, only a minor amount of ammonia from the hose would be released. The ammonia receiving system is connected to a one-inch line that is under a 250-psig pressure. The valve connected to the system is a manual shut-off valve. This type of sce nario is similar in nature if shearing of a one-inch liquid pipe caused the release. For the release, the estimated release rate will be derived from the Bernoulli equation, incorporating chemical specific factors for ammonia. The ammonia refrigeration document provides calculated endpoint distances for typical meteorological conditions (3 m/s wind speed, D atmospheric stability, 50% relative humidity. Other assumptions include, no active or passive mitigation measures are currently in place and an urban dispersion environment in the nearfield. The results of the alternative-release scenario for an ammonia release indicate that the endpoint concentration of 200 ppm is reached at 0.304 mile (489 meters) from the release point. Figure 1-4 details the ammonia alternative-case release zone. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The Dallas, Texas facility is governed by a set of OSHA and USEPA regulations that require planning and facility activities intended to prevent a release of hazardous material, or if a release inadvertently occurs, to minimize the consequences of a release to the employees of the facility, the public, and the environment. These regulations include: * 40 CFR Part 68, Accidental Release Prevention * 40 CFR Part 112, Spill Prevention, Control and Countermeasure * 40 CFR Part 122, National Pollution Discharge Elimination System * 40 CFR Part 264, Hazardous Waste Contingency Plan * 29 CFR Part 119, Process Safety Management The key concepts in Rosani's release prevention program are employee participation, appropriate design and maintenance of equipment, and appropriate training of all employees. Employee participation in the release prevention program is encouraged and supported by Rosani's management. Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the ammonia system. Rosani employees are also members of the facility emergency response team. Rosani has an Emergency Response Plan in place and sufficient equipment on site to respond to most ammonia releases. Rosani's policy is to construct all new equipment, systems, and facilities to ensure the appropriate safety and release prevention systems are included from the beginning of each project. Rosani maintains a computerized program of maintenance activities to ensure that key systems are maintained appropriately to minimize the risk of a release. Rosani is committed to providing appropriate training to all employees regarding safety procedures. Each new employee is provided comprehensive safety training during his or her initial orientation for the facility. In addition, Rosani conducts regularly scheduled safety training for all employees each year. Additional training is provided to maintenance personnel for the systems they are responsible for. Members of Rosani's emergency response team receive annual training to ensure that response actions are prom ptly and safely completed. Five Year Accident History Rosani has not had a reportable release of ammonia from the Dallas, Texas facility that has affected the public or the environment within the past five years. Emergency Response Program Rosani has personnel trained in emergency response at the facility 24 hours per day, 7 days per week. These personnel receive annual training on emergency procedures and response techniques, including walking personnel through events when a release may occur. Planned Changes to Improve Safety Rosani completes a thorough review of the ammonia system each time a design change is implemented. Rosani is committed to using these methods to identify and implement ways to improve the safety of the system. The PSM committee is involved with any development and modification of the Standard Operating Procedures (SOPs), Process and Instrumentation Diagrams (P&IDs), and the Emergency Response Plan. Currently, Rosani is in the process of developing the PSM Pla n to include block flow diagrams and P & IDs. The PSM Incident Investigation Program will also be implemented. |