oakland foods, L.L.C. - Executive Summary |
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See attached Executive Summary for oakland foods, L.L.C. (EXECUTIV.TXT) Executive Summary Accident Releases Prevention Program and Emergency Response Policy It is the policy of oakland foods, L.L.C to implement the requirements of the Risk Management Program (RMP) in compliance with the USEPA regulations under 40 CFR Part 68 and with the 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 impact to oakland foods employees, the public and the environment. This objective will be met by using good operating procedures, providing appropriate training to all employees, and coordinating response activities with the local emergency response providers. This plan covers all oakland foods, L.L.C owned activities. Facility Description The oakland foods facility is a food processing and storage facility. Raw materials are trucked to the facility and then made i nto various prepared meats (e.g., hotdogs, sausages, meatballs and bacon etc.) for restaurant, wholesale, retail and food service customers. The refrigeration system is used for cooling and freezing capabilities required for the processing and storing of the food product. The cooling medium for refrigeration at this site is anhydrous ammonia (subject to the requirements of 40 CFR Part 68) which is used in a closed loop recirculating and recycling system. Worst-Case and Alternative-Release Scenarios RMP regulations states that each company must identify a worst-case and an alternative-release scenario. The EPA defines worst-case release as the release (in a 10-minute period) of the largest quantity of a regulated substance from a single vessel or process line failure that results in the greatest distance to the endpoint. To find the end point the release rate is evaluated then the reference tables are used in the "Risk Management Program Guidance for Ammonia Refrigeration". Molec ular weight, volatility, heat of combustion, and the physical setting (urban or rural) affect the distance to the endpoint. The alternative release scenario 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 also evaluated 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; these include buildings, trees, and hills. Rural means there are no obstacles in the immediate area and the ground is flat and unobstructed. Due to the location of the plant being out of the city limits of Oakland, IA and in the country with very few trees or buildings around, a rural environment was assumed. Anhydrous Ammonia The da ta provided in the "Risk Management Program Guidance For Ammonia Refrigeration" (November 1998) was used to estimate the toxic endpoint for the worst-case and alternative-case ammonia release scenarios. This document provided us with calculated endpoint distances for typical meteorological conditions. The EPA-mandated meteorological conditions for the worst-case scenario were Class F stability, wind speed 1.5 meters per second, ambient temperature of 25 degrees C (77 degrees F), and humidity at 50%. For the alternative-release scenario Class D stability, wind speed 3 meters per second, ambient temperature of 25 degrees C (77 degrees F), and humidity at 50% were used for the meteorological conditions. The worst-case release for ammonia involved an outside high-pressure receiver. The receiver has a 5000 gallon capacity, but the maximum fill capacity is 80% (administrative control). At 4000 gallons of ammonia the maximum amount of ammonia that can be released from this vessel is 20 ,592 lbs. In a 10 minute release, the release rate would be 2059.2 lbs./min. Referencing exhibit 4-4 of the "Risk Management Program Guidance For Ammonia Refrigeration" the toxic endpoint distance at 2059.2 lbs./min. would be 2.6 miles (rural). The selected alternative-release for ammonia was selected based on the "What-If" scenerios from our Process Hazard Analysis, our 2-year history and input from the facility's engineering department personnel. The high pressure cut-out failed, resulting in the condensor tower relief valve discharging. The relief valve (mitigation measure) is gauged at 250 psig with a 1/2 inch pipe from the condensor to the valve. After conversing with Preston Refrigeration the average time it would take for the relief valve to reset would be approximately 1 minute. Using the Bernoulli Equation the calculated release rate would be 629.1 pounds per minute. Referencing the "Risk Management Program Guidance For Ammonia Refrigeration" exhibit 4-5 with a releas e of 629.1 lbs./min. of ammonia the toxic endpoint distance would be 0.5 miles (rural). Description of the Accidental Release Prevention Program The prevention program consists of the following elements: * Employee Participation: This program involves the employees in establishing and implementing the program. Employees are also to be involved when a process hazard analysis is conducted. The program also ensures that all employees have complete access to the program. * Process Safety Information: Written information has been collected which enables the employees to identify and understand the potential hazards in the system. The written information includes the ammonia MSDS and a detailed description of the design of the ammonia refrigeration system. * Process Hazard Analysis: Formal studies using the What-If Technique have been conducted to examine the system and identify potential hazards. Any recommendations are resolved to improve facility safety as well. Based upon p otential hazards identified, recommendations have been developed to improve the safety of the system. * Operating Procedures: Written, detailed standard and emergency procedures have been developed which describe the steps which should be followed to safely operate the ammonia refrigeration system. * Training: A training program has been developed which ensures that employees who operate the system are trained on all aspects of the system and on the duties which they should perform to ensure the safe operation of the ammonia refrigeration system. * Contractors: All contractors are screened and evaluated before they perform work on or near the ammonia refrigeration system. The contractors are also periodically evaluated to ensure that they perform work by following safe work practices and all standard and emergency operating procedures. * Pre-Start-up Safety Review: A pre-startup safety review is required for all new ammonia projects to verify that all safety programs are in plac e, training has been performed, and construction has been completed for their effect on the system as a whole. * Management of Change: Procedures are designed to ensure that all changes made to the ammonia refrigeration system are properly reviewed. * Incident Investigation: Procedures ensure that any incidents (and near misses) are investigated, reviewed, and documented using an investigation team. Any recommendations are resolved to improve the safety of the facility. * Compliance Audits: Audits will be conducted at least every three years as mandated by OSHA Standard 29 CFR Part 119. As of this submission oakland foods, L.L.C. has been in operation less than three years. Five Year Accident History Oakland foods, L.L.C. has not had a release of ammonia from the Oakland, Iowa facility that has affected the public or the environment. Emergency Response Program In the event of an incident requiring off-site response the oakland foods Emergency Response Team will be assembled to perform preparatory measures for the Oakland fire Department. The highest-ranking Plant Emergency Response Team Member will assume the responsibilities of Incident Commander until the Oakland Fire Department arrives. The Oakland Fire Department will assume Incident Command and will contact the Council Bluff's HAZMAT Team for assistance and designate individuals to proceed with off-site evacuation of the surrounding community(s) if necessary. The plant Emergency Response Team will stand by and be prepared to assist the Incident Commander and the Council Bluff's HAZMAT Team as needed within their level of certified training. The plant Emergency Response Team will work as a liaison with the Incident Commander for the Oakland Fire Department and entry to any Hot Zone will only be as directed by the Incident Commander. Planned Changes to Improve Safety oakland foods, L.L.C. completes a thorough review of the ammonia systems each time a design change is implemented. oakland foods , L.L.C. is committed to using these methods to identify and implement ways to improve the safety of these systems. Jeveridg/safety/Executiv 3 1 oakland foods, L.L.C. June 10, 1999 |