Saputo Cheese USA - Executive Summary
1 Accidental Release Prevention and Emergency Response Policies |
We at Saputo Cheese USA are strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. If such a release does occur, Saputo relies on the assitance of the Tulare Fire Department, with whom we have coordinated.
2 The Stationary Source and the Regulated Substances Handled
Our facility's primary activities encompass Cheese Manufacturing. The plant is located at 901 Levin Avenue in Tulare, California. We have one RMP-regulated substance, Ammonia, at our facility, which is used to provide refrigeration for the manufacturing of cheese. The maximum inventory of Ammo
nia at our facility is approximately 14,000 lb.
3 The Worst Case Release Scenario and the Alternative Release Scenarios, including administrative controls and mitigation measures to limit the distances for each reported scenario
To perform the required offsite consequence analysis for our facility, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance and EPA Model RMP for Ammonia Refrigeration. The following paragraphs provide details of the chosen scenarios.
Consequence modeling was conducted to determine the release distances from the site.
The worst-case release scenarios represent a release of the largest vessel's contents when full over a 10-minute release period. The scenario involves the release of 4,300 lb. of Ammonia in a gaseous form over 10 minutes. Release distances were calculated using Class F atmospheric stability and 1.5 m/s windspeed, and toxic endpoint of 0.14 mg/L. Results for the WCS were modele
d using EPA's RMP-Comp based on an unmitigated toxic gas release that has been liquefied under pressure.
The alternative scenario consists of an ammonia release from an oil drain valve in the Ice Builder that was inadvertently left open. The pipe diameter is 1/2". The scenario involves a release rate of 220 lbs./minute. The guidance used to develop the release distance did not assume a specific release duration and is applicable to releases of all lengths. In the event of an actual release, it is expected that an operator would intervene to stop the release with a 10-minute period. EPA permits the alternative release scenarios to allow the facility to account for administrative controls and mitigation systems that could be used in case of an emergency. However, for purposes of this analysis, no such mitigation has been assumed. While mitigation systems and controls do exist, the analysis intended to report more conservative results.
4 The General Accidental Release Prevention Pr
ogram and the Chemical-Specific Prevention Steps
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The ammonia refrigeration system is also subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.
Process Safety Information
Saputo Cheese USA maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes.
Process Hazard Analysis
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is What If/Checklist. The studies are undertaken by a team of qualified
personnel with expertise in engineering and process operations and are revalidated at a regular interval of (five years or when changes dictate). Any findings related to the hazard analysis are addressed in a timely manner.
For the purposes of safely conducting activities within our covered processes, Saputo Cheese USA maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes.
Saputo Cheese USA has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every three years and more frequently as needed. All trai
ning will be documented and validated by employee in our internal tracking system.
Saputo Cheese USA carries out documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.
Management of Change
Written procedures are in place at Saputo Cheese USA to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly mad
e aware of and offered training to deal with the modification.
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Saputo Cheese USA. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
Saputo Cheese USA conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner.
Saputo Cheese USA promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incide
nt as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years.
Saputo Cheese USA truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular.
On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Saputo Cheese USA has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also inform
ed of all the procedures for emergency response should an accidental release of a regulated substance occur.
5 Five-year Accident History
Saputo Cheese USA has had a good record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, no incidents have occurred between June 21, 1994 and June 21, 1999.
6 Emergency Response Plan
Saputo Cheese USA carries an Emergency Action Plan that includes evacuation procedures and notification of local agencies and outside responders. This plan has been coordinated with the Tulare Fire Department. The Saputo Cheese facility in Tulare, CA does not, however, respond to accidental releases of hazardous materials. We rely on the outside assistance of the Fire Department for this function.
7 Planned Changes to Improve Safety
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Completion of the PHA recommen
dations are expected to occur by October 16, 2000.