Fleischmann's Yeast - Executive Summary
This document contains all required information in order to meet 40 CFR 68 "Risk Management Program". This document consists of the executive summary and registration data elements (68.155 through 68.185). |
10.1 RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
The Fleischmann's Yeast facility in Memphis, Tennessee has a good record in preventing releases of anhydrous* ammonia. As part of their release prevention program, the plant has an excellent and detailed preventive maintenance program. More information about these aspects of the prevention program is discussed in Section 4.0 of this Executive Summary.
The facility has implemented an Emergency Response Program to ensure the safety of its employees', the community and the environment. This detailed emergency response program includes procedures for handling an emergency - the established action plan and contacting appropriate outside personnel involved in containing an ammonia release - HEPACO (local private HAZMAT team).
All of these components make the Emergency Action Plan a thorough and comprehensive plan for release prevention and emergency response. The emergency response policies at the Fleischmann's Yeast facility ensure that there is emergency response coverage 24 hours - 7 days per week.
*From this point in the Executive Summary, anhydrous ammonia will be synonymous with ammonia.
10.2 PROCESS DESCRIPTION AND REGULATED SUBSTANCES
Fleischmann's Yeast is a producer of baker's yeast. The NAICS codes for the process at this facility is 311999. Fleischmann's Yeast has one regulated substance under 40 CFR 68: anhydrous ammonia. The ammonia is used in the process as an ingredient in the manufacturing of baker's yeast.
The ammonia threshold for triggering the applicability to 40 CFR 68 is 10,000 pounds. The total quantity of anhydrous ammonia stored in the process is documented as approximately 94,393 pounds. This process exceeds the threshold quantity of 10,000 pounds as set by 40 CFR 68
and thus is regulated by the Risk Management Program.
10.3 WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS
The ammonia feed system has associated hazards that can potentially affect on-site employees and the general public off-site if there is a release from the system. Described below are the associated hazards and the worst-case and alternative release scenarios for the regulated chemical. Though there may be other scenarios possible, EPA only requires that one worst-case and one alternative case scenario be reported for each regulated substance.
Ammonia is classified as a Group 2 Refrigerant per ASHRAE Standard 34-1989. The dominant characteristic of this chemical is its toxicity. It is a self-alarming chemical by its distinctive pungent odor. Due to this odor, persons exposed to ammonia vapor will not voluntarily stay in areas of even small concentrations. Ammonia will burn at a very narrow and high range of concentrations accompanied with a high ignition temperature. Alt
hough ammonia is not poisonous, it is corrosive to human tissue. Ammonia is readily absorbed into the moisture of the skin and, at high concentrations, can cause severe burns.
The risks to persons in an accidental release of ammonia include:
1. Corrosive attack of skin and other tissue (including lung tissue)
2. Freezing of skin and other body tissue when contacted by liquid ammonia
Below is a description of the scenarios for anhydrous ammonia and their off-site consequences:
10.3.1 Worst-Case Scenario Description
The largest potential release of ammonia would occur with a puncture in the Ammonia Storage Tank. Taking the specific definition of the worst-case from 40 CFR 68.25, the largest quantity of ammonia that can be stored in a vessel is in the bulk storage tank during a pump out condition. The total quantity of ammonia that can be stored in the bulk storage tank is 94,393 pounds, without administrative controls. Since the facility is loacted in a populated are, the toxic
cloud formed by the evaporating ammonia would reach off-site endpoints and nearby receptors.
10.3.2 Alternative Release Scenario Description
The alternative release scenario selected is an ammonia release due to a leak in a pump seal/flange. The release occurs outside, at the base of the storage tank at approximately 3 feet above ground level. The leak occurs through a 1/4-inch orifice and ammonia is being held at the system pressure of 125 psig. Administrative controls are not applicable to this scenario. Active mitigation of the release is the through human intervention (an operator will stop the leak). Since the facility is located in a populated area, the toxic cloud formed by the evaporating ammonia would reach off-site endpoints and nearby receptors.
10.4 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
Fleischmann's Yeast has developed an OSHA PSM program for their ammonia feed system. At Fleischmann's Yeast, ammonia falls under th
e RMP Program 3 Prevention Program, which is identical to the OSHA PSM program. EPA has said that if the process is in compliance with OSHA PSM, then it is compliance with RMP Program 3. Thus, Fleischmann's Yeast ammonia PSM has been reviewed and determined to be complete for the RMP document.
Listed below are key aspects of the ammonia prevention program:
1. Most of the pipe work is out of the way of people and the machinery and so there is less of a chance of an ammonia release.
2. The plant maintains good training, certification, and employee awareness of operating procedures.
10.5 FIVE-YEAR ACCIDENT HISTORY
The review of Fleischmann's Yeast accident history includes the following range of dates: December 1, 1993 - December 1, 1998. According to 40 CFR Part 68.42(a), there have been no accidental releases at this facility.
10.6 EMERGENCY RESPONSE PROGRAM
As mentioned previously, the Fleischmann's Yeast facility has developed an Emergency Action Plan. The response plan
is a detailed document which discusses the role of employees and management in an emergency situation. The plan outlines specific procedures for evacuations for plant personnel. For all emergencies, the Safety Director, otherwise known as the Incident Commander, has operating authority for emergency response at the site of release and assumes control of the incident scene beyond the first responder awareness level.
This document contains specific information regarding: contact numbers; emergency communication; incident team job descriptions; evacuation zones; emergency evacuation procedures; notification procedures; training; emergency shutdown procedures; personnel roles and lines of authority; emergency recognition and prevention; safe distances and places of refuge; site security and control; medical/first aid treatment; emergency alerting and response procedures; PPE and emergency equipment; and standard operating procedures in the event of an ammonia release.
CHANGES TO IMPROVE SAFETY
Based on the completed Process Hazard Analysis (PHA) for ammonia, a list of action items to improve safety was developed and their status monitored to ensure that implementation is accomplished. Examples of safety improvements made at the plant are discussed below:
1. Barricade liquid ammonia storage tank; and
2. Enhancepreventative maintenance programs for ammonia valves and piping