Fleischmann's Yeast - Executive Summary |
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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 Gastonia, North Carolina 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 Action Plan 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 notifying appropriate outside agencies involved in containing an ammonia release - Emergency Response Team (HAZMAT). As part of this program, there is emergency response training and medical surveillance of the HAZMAT team prior to and after an incident. 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. There are also provisions for coordination of the Emergency Action Plan with the Gastonia Fire Department in the event of an emergency. Any updates to the Emergency Action Plan are provided to all the agencies with which the plan is coordinated. *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: anhyd rous ammonia. The ammonia is used to chill water at the facility and also as a process feed (nutrient for making 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 72,500 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 Worst-Case Scenario Description The largest potential release of ammonia would occur with a puncture in the Bulk 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 64,197 pounds, without administrative controls. Since the facility is located in a popul ated area, the toxic cloud formed by the evaporating ammonia would reach off-site endpoints and nearby receptors. Alternative Release Scenario Description The alternative release scenario selected is an ammonia release from the rupture of a pressure relief valve (PRV) that is located on the high-pressure receiver. The PRV release is located outside the plant at approximately 10 feet above ground level. The PRV outlet has a 1/2-inch orifice and is set at 250 psig. Administrative controls are not applicable to this scenario. Active mitigation of the release is the resetting of the PRV when the blowdown pressure is reached. 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 refrigeration system. At Fleischmann's Ye ast, 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, 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 machinery 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 develop ed 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 Plant manager has operating authority for emergency response at the sign of release and assumes control of the incident scene beyond the first responder awareness level. This document contains specific information regarding the following: emergency contact numbers, emergency communication, medical emergencies, what to do in the case of fires, air contaminant releases, hazardous material spills, hazardous weather conditions, bomb threats, earthquakes and civil disturbances, in addition to evacuation procedures, discharge practices, documentation, the reporting system, solids and liquids used at the facility, hazardous and large volume materials and emergency shutdown procedures for various systems and equipment throughout the facility. 10.7 PLANNED 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. Ammonia detectors are to be added in the machine room; 2. Install barriers around ground-mounted condensers; and 3. Purge equipment through a water bath to reduce ammonia emissions. |