Washington Beef - Toppenish - Executive Summary
EXECUTIVE SUMMARY |
RISK MANAGEMENT PLAN
WASHINGTON BEEF, INC.
The company's risk management program is described as follows:
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
Senior management is committed ensuring a safe working environment for its employees and its community. It does so by:
* Planned and preventative maintenance - to provide routine inspections and repairs, to the ammonia systems to minimize the potential for unplanned releases.
* Standard Operating Procedures - to provide mechanics and operators with guidelines on safe operation, startup, shutdown, and maintenance of the ammonia refrigeration systems.
* Training - to provide all employees and contractors with adequate training on the potential hazards of ammonia, and the correct steps to take in the event of an unplanned release.
FACILITY DESCRIPTION AND REGULATED SUBSTANCES
Washington Beef, Inc., is an integrated meat product company, primarily producing beef products for the retail and institut
ional customer. From cattle to packaged steaks, the company utilizes ammonia as a refrigerant for critical control of potentially harmful bacteria throughout its processes. Although ammonia may be a hazardous substance, these refrigeration systems are necessary to maintain food safety for the meat products produced by, stored at, and distributed from Washington Beef.
WORST CASE RELEASE AND ALTHERNATIVE RELEASE SCENARIOS
System F - processing and fabrication divisions
* Worst case: The vessel serving the processing and fabrication divisions with the potential for holding the largest amount of ammonia is a low pressure receiver with an operating charge of 2,125 lb. Modeling from information provided by Ecology and Environment, Inc., drawn from EPA's risk management program rule section 112 (r), Washington Beef determined that there is a hypothetical risk to six persons within a .19 mile radius from the plant. Commerce and residences are within this circle. Potentially harmful e
ffects are mitigated because the vessel is enclosed; it operates at approximately one-third full capacity; and there is an ammonia detection alarm system.
* Alternate release: If a condenser should overpressurize, the pressure relief valve is activated, as it is designed to do to prevent a more serious release. Using the document cited above, modeling for a mitigated (enclosed) ten-minute release for a 250# relief valve at the condenser could emit ammonia to a radius of 0.31 miles from the plant. There is a hypothetical risk to 15 persons, with residences, commerce, and a school within this circle. Potentially harmful effects are mitigated both by the relief valve mechanism, by enclosure, and by an ammonia detection alarm system. Once pressure has been reduced, the valve closes, thus stopping further release.
System R, value-added products and warehouse divisions
* Worst case: The estimated operating charge for the +15F recirculator is 10,430 lb. Modeling from information cited
above, Washington Beef has estimated that there is a hypothetical risk to 60 persons within at 0.62 mile radius from the plant should there be an unplanned, unmitigated release from this unit. Commerce, residences, schools, and parks are within this circle. Potentially harmful effects are mitigated by enclosure as well as the ammonia detection alarm system.
* Alternative release: Evaporators are located in the overheads of the warehouse and intermediate storage rooms such as the tempering room. Because product is loaded onto racks by high reach forklift, there is a chance that an evaporator and/or its associated piping could be struck by a forklift or its load. In this event, an evaporator leak could release 1,183 lb. Based on the document cited above, Washington Beef has estimated that there is a hypothetical risk to 6 persons within a .19 mile radius of the plant. Commerce and residences are within this radius. Potentially harmful effects are mitigated by: Enclosure, the amm
onia detection system, and the requirement that all operators of forklifts pass a certification program for forklift driving. Certification is based on written or oral, and demonstration of skill, performance.
ACCIENDTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
Washington Beef, Inc., complies with federal, state, and local regulations to ensure a safe work place for our employees. These systems' regulations include:
* OSHA Process Safety Management
* EPCRA Community Right to Know
* Washington State Uniform Fire Code
* Washington State Department of Labor and Industries - Pressure Vessel Permits
* Washington State Department of Labor and Industries - Safety and Health Regulations
Accident Prevention Plan
Lock Out/Tag Out Plan
Emergency Action Plan
Hot Work Plan
Chemical Hygiene Plan
* Washington State Department of Ecology Dangerous Waste Regulations - small quantity generator
* Yakima County Fire, Life and Safety Inspections
l release prevention includes: Standard operating procedures, scheduled preventative maintenance of the ammonia refrigeration systems and employee training. During orientation for new employees, training is provided to discuss potential hazards, such as the ammonia refrigeration systems, and how to recognize them (e.g., pipe labeling). Maintenance mechanics assigned work on the refrigeration system receive instructions on standard operating procedures (including management of change) for performing tasks and inspections on these systems. Washington Beef employs a refrigeration mechanic with specific responsibility for inspections, maintenance, and troubleshooting on the ammonia refrigeration systems.
Opportunities to improve the prevention capability by Washington Beef from accidental ammonia releases were identified in conjunction with the implementation of process safety management, and have been completed.
FIVE YEAR ACCIDENT RELEASE HISTORY
Washington Beef has not experienced
a reportable accidental release of ammonia in the past five years.
EMERGENCY RESPONSE PLAN
Washington Beef is a small quantity generator of hazardous waste, and is exempt from the requirements to develop and implement an emergency response plan. In lieu of this, the facility has an emergency action plan for evacuating its employees. An emergency shutoff unit is located for process ID 2 ("R" system) outside the engine room to provide a quick and safe means for shutting down the ammonia system with the least risk to employees or emergency response personnel. The company is a participant with the local emergency planning commission. Process information is on file with the local fire department in the event of an unplanned release that exceeds the emergency action capability of Washington Beef personnel.
PLANNED CHANGES TO IMPROVE SAFETY
Washington Beef continues its commitment to provide a safe work environment for its employees. There are no specific plans at this time for furt
her mitigation or process control of the refrigeration systems. The company does, however, remain willing to consider technological or equipment improvements when and if appropriate.