Seneca Foods Corporation - Executive Summary |
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The EPA published Title 40 of the Code of Federal Regulations, Part 68 (40 CFR Part 68) to meet the requirements of the Clean Air Act (CAA), Section 112 (r). The CAA amendments were passed to prevent accidental releases of toxic and flammable chemicals. 40 CFR Part 68 requires facilities using a regulated substance in excess of a regulatory threshold quantity (TQ) to develop and implement a risk management program. Seneca Foods Corporation (Seneca Foods) stores up to 30,000 pounds of anhydrous ammonia at the plant located at 600 Fifth Street Southeast, Montgomery, Minnesota (the Property). Ammonia is used as a refrigerant at the facility. The quantity stored exceeds the 10,000-pound TQ for ammonia, and is therefore regulated under 40 CFR Part 68. Seneca Foods contracted Northern Environmental to prepare a Risk Management Program for ammonia at the Montgomery facility. The Risk Management Program consists of five elements: the management system, hazard assessment, prevention program, e mergency response, and the risk management plan (RMP) submittal. The Seneca Foods management system lists Mr. Jon Brekken, Plant Manager, as having overall responsibility for the risk management program implementation. Mr. Rick Makepeace, Safety Manager, and Mr. Tim Nelson, Plant Superintendent, assist the operations manager as delegated. The hazard assessment included an off-site consequence analysis (OCA) and a summary of the 5-year accident history. The OCA's worst-case release scenario was the loss of 7000 pounds of ammonia from the refrigeration system, resulting in a distance to toxic endpoint of 1.0 miles. According to 1990 census data, there is a total population of 296 persons residing within the worst case release vulnerable zone. The OCA's selected alternative release scenario was a release of 1820 pounds of ammonia in ten minutes and a distance to toxic endpoint of 0.1 miles. A total of 0 persons reside within the alternative release vulnerable zone. Commercial/office/ind ustrial areas are located within both the worst case and alternative release vulnerable zones. There have not been any accidents within the last five years that resulted in deaths, injuries, property damage, or environmental damage. Since ammonia is also regulated under the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Standard (29 CFR 1910.119), the prevention program elements under Program 3 of 40 CFR Part 68 apply. These elements are safety information, process hazard analysis, operating procedures, training, mechanical integrity, management of change, pre-startup review, compliance audits, incident investigation, employee participation, hot work permit, and contractors. These elements are being implemented at the facility under the existing PSM program. The Montgomery facility also has an existing Emergency Action Plan (EAP) designed to meet the requirements of: 7 29 CFR 1910.119 (n) - Emergency Planning and Response 7 29 CFR 1910.38 (a) - Emergency Action Plan 7 29 CFR 1910.38 (b) - Fire Prevention Plan Based upon a review of the existing PSM and EAP, and discussion with facility management, specific items must be addressed to ensure continued compliance with the requirements of 40 CFR Part 68. The items are described in this report. The final major component of the risk management program is the submittal of the risk management plan (RMP), a summary document which must be submitted to the EPA by June 21, 1999. RMPs must be submitted on diskette (USEPA (b), November 1998). A certification statement must also be signed by a person with overall responsibility for implementing the risk management program, to be submitted with the diskette. A certification statement for Seneca Foods' signature is presented in Appendix H, and a diskette is provided with this report for your submittal to the reporting center. |