Gilardi Foods - Executive Summary |
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GILARDI FOODS RISK MANAGEMENT PROGRAM DOCUMENT This document contains all required information in order to meet 40 CFR 68 "Risk Management Program" including an Executive Summary and RMP data elements (68.155 through 68.185). EXECUTIVE SUMMARY 1.0 Release Prevention and Emergency Response Policies The Gilardi Foods facility in Oklahoma City, Oklahoma has a good record in preventing releases of anhydrous* ammonia. The Gilardi Foods facility has a thorough emergency training program for on-site emergency responders. The facility has implemented Gilardi Food's HAZWOPER plan (emergency response program) which is a plan designed for 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 appropriate personnel involved in containing a hazardous release (HAZMAT team). As part of this emergency response program, Gilardi Foods emphasizes a thorough training program and medical surveillance of the HAZMAT team prior to and after an incident. With the potential dangers associated with a hazardous chemical release, Gilardi Foods has researched and developed safe containment and disposal procedures as well as an evaluation procedure following an emergency response. All of these components make the Gilardi Foods HAZWOPER plan a thorough and comprehensive plan for release prevention and emergency response. The emergency response policies at the Gilardi Foods 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. 2.0 Process Description and Regulated Substances Gilardi Foods is a producer of prepared frozen pizzas. The NAICS code for this process at the facility is 311822. Many areas of the plant are refrigerated to preserve the food products. Gilardi Foods has one regulated substance under 40 CFR 68: ammonia. Ammonia is used as a refrigerant in the refrigeration of the foods in the various areas of the plant. The ammonia threshold for triggering applicability to 40 CFR 68 is 10,000 pounds. The Oklahoma City plant has one ammonia refrigeration process for the preservation of the food products. The quantity of ammonia stored in the Engine Room refrigeration process is approximately 9,813 pounds. This process does not exceed the threshold quantity of 10,000 pounds as set by 40 CFR 68. However, since the quantity is so close to the threshold, Gilardi Foods has decided to prepare an RMP and submit the plan to the EPA. This is called predictive filing, which means at the time the facility goes above 10,000 lbs, this plan will become active and is on file with the EPA. 3.0 Worst-case and Alternative Release Scenarios Worst-Case Scenario Description The largest potential release of ammonia would occur with a puncture in the liquid portion of the high pressure receiver. Taking the specifi c 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 high pressure receiver inside the engine room during a pumpout condition. The total quantity of ammonia that can be stored in the high pressure receiver is 6,397 pounds without administrative or passive controls. The release would reach offsite endpoints and nearby public receptors. Alternative Release Scenario Description The alternative release scenario that meets both selection criteria is an ammonia release from a broken sight glass on the high pressure receiver. The glass is located three feet above ground level. Administrative and passive controls are not applicable to this scenario. Active mitigation of the release is human intervention (system shutdown at 20 minutes from the start of the release). The release would reach offsite endpoints and nearby public receptors. 4.0 General Accidental Release Prevention Program and Chemical-Specific Preve ntion Steps Gilardi Foods is in the process of developing an OSHA PSM program for their ammonia refrigeration systems. At Gilardi Foods, ammonia falls under the 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, Gilardi Foods's ammonia PSM is being reviewed and completed for the RMP document. There are key aspects of the ammonia prevention program that are being developed: 1. The ammonia PSM program at Gilardi Foods includes provisions for employee involvement, procedures for working with contractors, pre-startup safety reviews and managing change within the system. The different sections of the PSM document detail employee participation (hazard analysis team), process safety information, process hazard analysis (PHA - what-if/checklist), operating procedures, training, mechanical integrity, hot work permits, management of change, incident investigation, compliance audits and emergency planning and response (HAZWOPER plan). The plant, therefore, maintains good training, certification, and employee awareness of operating procedures. 2. Gilardi Foods has researched information pertaining to the properties and hazards of ammonia, sought professional assistance from experts in the ammonia refrigeration industry, and used many internal resources to develop the "ConAgra Frozen Foods - Ammonia Refrigeration Reference Manual". Block flow diagrams and P&ID's have been developed and are updated as the ammonia refrigeration system audits are completed. 3. Gilardi Foods has established a hazards analysis team (comprising of plant employees) responsible for updating existing operating procedures for the refrigeration system and also verifying and documenting the mechanical integrity of the system. 4. In the event of a catastrophic release or an incident which could have resulted in a catastrophe, investigations will be undertak en (this is a policy of the PSM document). Necessary preventative measures will be taken to reduce the risk of incident reoccurrence. 5.0 Five-year Accident History The review of Gilardi Foods's accident history includes the following range of dates: June 22, 1994 - June 21, 1999. According to 40 CFR Part 68.42(a), there have been no accidental releases at this facility. 6.0 Emergency Response Program As mentioned previously, the Gilardi Foods facility has developed an OSHA hazardous substance emergency response program called HAZWOPER. The HAZWOPER document contain detailed procedures for: 1) pre-emergency planning and coordination; 2) personnel roles and lines of authority; 3) training; 4) communication; 5) emergency recognition and prevention; 6) safe distances and places of refuge; 7) site security and control; 8) emergency alerting and response; 9) ammonia decontamination; 10) emergency medical treatment and first aid; 11) critique of response and follow-up; 12) personal pr otective and emergency equipment; and 13) medical surveillance. Gilardi Foods' emergency response plan (HAZWOPER) is a detailed document that discusses the role of employees and management in an emergency situation. All emergency response personnel undergo training and records of this training are maintained and updated on site. The plan outlines specific procedures for evacuations, incident alarms and alerting. Depending upon a given situation, the Fire Department will be called to provide back-up emergency responders and equipment. The Fire Department will be called for all fire-related emergencies. The incident commander has ultimate control of implementation of the emergency response plan. 7.0 Planned Changes to Improve Safety Ammonia detectors will be put in place to provide effective monitoring for any type of ammonia release. The facility also plans to upgrade the engine room ventilation system. |