Hebrew National Kosher Foods - Executive Summary |
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EXECUTIVE SUMMARY 1.0 RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Hebrew National Kosher Foods facility in Indianapolis, Indiana has a good record in preventing releases of anhydrous* ammonia. As part of their release prevention program, the plant has developed a well documented Process Safety Management (PSM) program. More information about this aspect of the prevention program is discussed in Section 4.0 of this Executive Summary. The facility has implemented an Emergency Action Plan "Ammonia Response" which is 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 appropriate personnel involved in containing an ammonia release - HAZMAT Team. 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 Actio n Plan a thorough and comprehensive plan for release prevention and emergency response. The emergency response policies at the Hebrew National Kosher Foods facility ensure that there is emergency response coverage 24 hours - 7 days per week. *From this point in the Executive Summary, anhydrous ammonia will be synonymous with ammonia. 2.0 PROCESS DESCRIPTION AND REGULATED SUBSTANCES Hebrew National Kosher Foods is a producer of processed smoked kosher meat products (hot-dogs, sausage, salami, deli meats, corn beef pastrami). The NAICS code for the processes at this facility is 311612. Many areas of the plant are refrigerated to preserve the meat products. Hebrew National Kosher Foods has one regulated substance under 40 CFR 68: ammonia. Ammonia is used as a refrigerant in the refrigeration of the products in the various areas of the plant. The ammonia threshold for triggering applicability to 40 CFR 68 is 10,000 pounds. The total quantity of ammonia stored in the refrigeratio n process is approximately 68,106 pounds. The process exceeds the threshold quantity of 10,000 pounds as set by 40 CFR 68 and thus is regulated by the Risk Management Program. 3.0 WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS The ammonia refrigeration system has associated hazards that can potentially affect on-site employees and the general public off-site if there is a release from the system. Described below are the associated hazards and the worst-case and alternative release scenario for the regulated chemical. Though there may be other scenarios possible, EPA only requires that one worst-case and one alternative scenario be reported for each regulated chemical. Ammonia is classified as a Group 2 Refrigerant per ASHRAE Standard 34-1989. The dominant characteristic of this chemical is its toxicity. It is a self-alarming chemical by its distinctive pungent odor. Due to this odor, persons exposed to ammonia vapor will not voluntarily stay in areas of even small concentratio ns. Ammonia will burn at a very narrow and high range of concentrations accompanied with a high ignition temperature. Although ammonia is not poisonous, it is corrosive to human tissue. Ammonia is readily absorbed into the moisture of the skin and, at high concentrations, can cause severe burns. The risks to persons in an accidental release of ammonia include: 1. Corrosive attack of skin and other tissue (including lung tissue) 2. Freezing of skin and other body tissue when contacted by liquid ammonia 3. Eye contact Below is a description of the release scenarios for ammonia and their off-site consequences: 3.1 Worst-Case Scenario Description One worst-case scenario has been developed for the Indianapolis plant. The largest potential release of ammonia would occur with a three and three-eights inch diameter puncture in the liquid portion of the 20 pound recirculator. Taking the specific definition of the worst-case from 40 CFR 68.25, the vessel that can store the largest quan tity of ammonia is the 20 pound recirculator. The total quantity of ammonia that can be stored in the 20 pound recirculator is 32,886 pounds. Administrative and passive controls are not applicable to this scenario. It is assumed that the entire 32,886 pounds is released into the atmosphere. The release rate to the atmosphere is 3,288.6 lb./min. For the worst-case release, regulations dictate that the release height is at ground level. Under Section 68.25(c)(1), a regulated toxic substance such as ammonia that is normally a gas at ambient temperature and handled as a liquid under pressure shall be considered to be released as a gas over a 10 minute period. Thus, ammonia's physical state in the worst-case scenario is a gas. Since this facility is located in a populated area, the worst-case release scenario distance-to-endpoint will reach off-site public receptors. 3.2 Alternative Release Scenario Description The alternative release scenario is an ammonia release from a flan ge gasket or valve packing leak on a high pressure liquid line. The opening is assumed to have a diameter of one-quarter inch, and is located fifteen feet above ground level. Administrative and passive controls are not applicable to this scenario. Active mitigation of the release is human intervention. Since this facility is located in a populated area, the alternative release scenario distance-to-endpoint will reach off-site public receptors. 4.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Hebrew National Kosher Foods has developed an OSHA Process Safety Management (PSM) program for their ammonia refrigeration system. At Hebrew National Kosher Foods, 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, Hebrew National Kosher Foods' ammonia PSM system has been reviewed and t he PSM system elements are being implemented for the RMP document. The plant has created a very thorough and well-documented written PSM program which includes the following elements: 1) employee participation, 2) process safety information, 3) process hazard analysis, 4) operating procedures, 5) training, 6) contractor safety, 7) pre-startup review, 8) mechanical integrity, 9) hot work permit, 10) management of change, 11) incident investigation, 12) emergency planning and response, and 13) compliance audit. 5.0 FIVE-YEAR ACCIDENT HISTORY The review of Hebrew National Kosher Foods' accident history includes the following range of dates: June 21, 1994 - June 21, 1999. According to 40 CFR Part 68.42(a), there have been no accidental releases at this facility. 6.0 EMERGENCY RESPONSE PROGRAM As mentioned previously, the Hebrew National Kosher Foods facility has developed an OSHA hazardous substance emergency response program called Emergency Action Plan "Ammonia Response." The p lan describes procedures for the response to an ammonia release. This plan contains specific procedures for: coordination with local authorities, emergency communication, emergency notification procedures, emergency evacuation procedures, personnel accounting procedures, notification of response groups, roles and lines of authority, emergency recognition and prevention, site security and control, medical first aid, decontamination, safe distances and places of refuge, personal protective equipment and emergency equipment (anhydrous ammonia emergencies), and critique of emergency action plan and follow-up. The Emergency Action Plan consists of all notifications and plant evacuation procedures in the event of an ammonia release. The purpose of this plan is to summarize the existing policies, procedures, and plans of action to protect the team members of this facility and the general public from dangers associated with these emergencies and provide for the notification in event of an emergency. 7.0 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 was accomplished. Examples of safety improvements made at the plant are discussed below: The plant has completed several projects that have improved the safety and efficiency of their ammonia refrigeration system. These include the removal of all ammonia equipment from the basement machine area. The compressors in this area were replaced by the compressors in the new machine room. Additionally, the plant has installed an ammonia detection system and spring loaded ball valves on their oil-pots. |