Hillshire Farm & Kahn's - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

1.  Accidental Release Prevention and Emergency Response Policies 
 
Hillshire Farm & Kahn's on Spring Grove Avenue in Cincinnati, Ohio complies with EPA's Accidental Release Prevention Program Rule (40 CFR Part 68), OSHA's Process Safety Management (PSM) Standard (29 CFR 1910.119) and OSHA Hazardous Waste Operations and Emergency Response (HAZWOPER) rules (29 CFR 1910.120).  The enclosed Risk Management Plan addresses the requirements of 40 CFR Part 68 as they relate to the storage, handling, and processing of a highly hazardous chemical, ammonia.  Through our compliance with Part 68 and 29 CFR 1910, we promote overall plant, worker and community safety.  Our Risk Management Program enables our facility to prevent the occurrence and minimize consequences of significant releases of ammonia, including leaks, spills, fires, explosions and other types of catastrophic accidents.   
 
In order to reduce the likelihood and severity of accidental chemical releases that may affect on-site workers  
and off-site populations and environmental receptors, the Company policy is to fully comply with the spirit and the letter of EPA's Chemical Accident Prevention Provisions rules (40 CFR Part 68).  The Company has developed a formal Risk Management Plan in compliance with 40 CFR Part 68.  All employees are expected to understand their role in developing and implementing the plan and to diligently adhere to its provisions.  The Cincinnati facility's Risk Management System has clearly defined lines of authority and designation of responsibilities to ensure that the risk management plans are developed, implemented, and revised.  Hillshire Farm & Kahn's safety and risk programs prevent accidents because they focus on the rules, procedures and practices which govern individual processes, activities, or pieces of equipment. 
 
2. Facility and Regulated Chemical Description 
 
Hillshire Farm & Kahn's meat processing facility, located at 3241 Spring Grove Avenue, CIncinnati, Ohio, is sugject to the 
requirements of 40 CFR Part 68, the Chemical Accident Prevention Provisions (112(r)) of the Clean Air Act, due to one on-site process containing a regulated chemical above its threshold quantity.  Anhydrous ammonia, a regulated toxic substance, is present in the facility refrigeration system in a quantity greater than its 10,000 pound threshold as established in the 112(r) regulations. 
 
Anhydrous ammonia is present as the refrigerant in the plant refrigeration system.  Preparation of the meat products, packaging, and storage operations require refrigeration to keep raw ingredients and products fresh.  The system consists of high pressure tanks, compressors, piping, pumps, chillers, and associated equipment located at various strategic locations throughout the plant.  The ammonia may exist as a gas or as a liquid in different parts of the system.  The total amount of ammonia present in the refrigeration system is approximately 77,700 pounds which represents the maximum amount of anhydr 
ous ammonia held in this process.  The maximum held in the single receiver is 50,515 lbs which is the maximum amount available for release as a worst case.  Because the overall system is pressurized, it is considered a single process. 
 
3.  Worst-Case and Alternate Case Scenarios 
 
Ammonia 
 
Worst-Case Scenario:  Failure of the receiver when the system is fully pressurized and filled to maximum inventory.  The entire contents of the receiver (50,515 lbs) are assumed to be released as vapor over ten minutes as per regulatory guidance.  The distance to the toxic concentration endpoint of 0.14 mg/L for the worst-case scenario is beyond the fence line and therefore has the potential for offsite impacts. 
 
Alternative Scenario:  A transfer hose at the unloading operation from a delivery truck breaks resulting in a release of ammonia.  The tank loses ammonia over a period of 15 minutes during which the leak is detected and mitigated.  The distance to the toxic concentration endpoint of 0.14 mg/L 
is beyond the fence line and therefore has the potential for offsite impacts.  The occurrence of this scenario is unlikely because operating procedures to prevent such an occurrence are in place and employees and drivers are trained to ensure that proper unloading procedures are followed. 
 
4.  Accidental Release Prevention Program 
 
The Cincinnati facility complies with EPA's Chemical Accident Prevention Provision rules and OSHA safety rules under 29 CFR 1910 for ammonia.  All elements of the accidental release prevention requirements under Part 68 have been developed and implemented for ammonia at the Cincinnati facility. 
 
The ammonia refrigeration system was designed and constructed in accordance with ANSI/IIAR 2-1992 Standard for Equipment, Design, and Installation of Ammonia Mechanical Refrigerating Systems.  A process hazard review was conducted for ammonia using a "What-If Checklist" and all identified problems were addressed.  Written operating procedures associated with all fac 
ets of ammonia storage, handling, and transfer are in place.  All persons working with ammonia or ammonia containing equipment have been trained on operating procedures and understand the consequences of deviation from the procedures.  A mechanical integrity program is in place for ammonia refrigeration and operations. 
 
5.  Five-Year Accident History 
 
No accidental releases of ammonia have occurred during the last five years that resulted in offsite impacts of any kind. 
 
6.  Emergency Response Program 
 
The emergency response program at the Cincinnati facility is based on the OSHA requirements for Emergency Action Plans (29 CFR 1910.38 and 1910.119) and HAZWOPER (29 CFR 1910.120).  We have trained employees for emergency response and maintain a written emergency response plan.  The plan is coordinated with the Hamilton County (Ohio) Local Emergency Planning Committee (LEPC), the Cincinnati Fire Division and the Greater Cincinnati Hazardous Materials Unit (GCHMU).  The Hillshire response 
team trains and drills quarterly.  We conduct annual reviews for implementation of the emergency response plan at the facility with the participation of the LEPC, the fire division, and the GCHMU.  The emergency response plan includes procedures for notification of the fire department who in turn would notify any potentially affected neighbors. 
 
7.  Planned Changes To Improve Safety 
 
As part of the Hillshire Farm & Kahn's continuous efforts to improve the safety of the system, several changes are planned at the facility to improve safety and prevent anhydrous ammonia releases.  These changes are scheduled to be implemented in the year 2000 and include refrigeration piping upgrades and continuing relocation of piping to the roof as well as compressor upgrades/replacement at the facility.
Click to return to beginning