Reuben Prepared Foods - Executive Summary |
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EXECUTIVE SUMMARY Accident Release Prevention Program and Emergency Response Policy It is the policy of the Reuben Prepared Foods (Reuben) 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 Reuben 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. Reuben's management is committed to providing the resources necessary to implement this policy. Facility Description Reuben operates a foods processing operation at this facility (see Figures 1-1 and 1 -2). Wholesale deli meats are the main product produced by Reuben at this facility. Operations at the facility include food processing machinery 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 complete 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). The 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 release scenario is evaluated using the same techniques as the worst-case 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." No trees, hills, and/or other structures are located in the immediate vicinity of the Santa Teresa, New Mexico facility; therefore, a rural dispersion environmental was assumed. Ammonia The data provided in the document "Model Risk Management Program 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 8,988 pounds of ammonia in 10 minutes or 899 lbs/min. Other assumptions included in the worst-case assessmen t are: the ammonia is a liquefied gas; the receiver tank is not diked; the nearfield dispersion environment is characterized as rural; 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 1.68 miles (2.70 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 relief valve due to overpressurizing a 1 1/4-inch line under a 300 psig pressure extending from a condenser. The largest relief valve has a relief rate of 64.12 pounds of air per minute (lbs/min). As a matter of convention, the specified release rate of any relief valve is always in pounds of air per minute. The release rate of 64.12 (lbs/min) correlates into a release rate of 45.5 pounds of ammonia vapor per minute. The ammonia refrigeration document provides calculated endpoint distances for typical meteorological conditions (3 m/s wind speed, D atmospheric stability, 50% relative humidity). It has been determined, through a review of Reuben's operational history, that the total release would likely be 455 pounds or less of ammonia. Based on the release rate of 46 lbs/min, the duration for a 455-lbs/min release is 10 minutes. Other assumptions include, no active or passive mitigation measures are currently in place and a rural dispersion environment in the nearfield. The results of the alternative-case release scenario for an ammonia release indicate that the endpoint concentration of 200 ppm is reached at 0.13 mile (209 meters) from the release point. Figure 1-4 details the ammonia alternative release zone. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The Santa Teresa, New Mexico facility is governed by a set of OSHA and USEPA regul ations 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 to 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 Reuben'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 Reuben's management. Reuben's management and key personnel are members of the PSM committee. Key personnel are responsible for conducting and implementing the findings from th e Process Hazard Analysis (PHA) for the ammonia system. Reuben employees are also members of the facility emergency response team. Reuben has an Emergency Response Plan in place and sufficient equipment on site to respond to most ammonia releases. Reuben's policy is to construct new equipment, systems, and facilities to ensure the appropriate safety and release prevention systems are included from the beginning of each project. Reuben 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, Reuben 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 Reuben's emergency response team receive annual training to ensure that response actions are promptly and safely completed. Five Year Accide nt History Reuben has not had a reportable release of ammonia from the Santa Teresa, New Mexico facility that has affected the public or the environment within the last five years. Emergency Response Program Reuben 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 training that is conducted as part of the hazardous communication training that incorporates emergency drills. Planned Changes to Improve Safety Reuben completes a thorough review of the ammonia system each time a design change is implemented. Reuben 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, the PSM committee continues to incorporate changes to the PSM. Daily logs of equipment inspections and tests that are conducted are filed in the refrigeration office for easy access. |