Goodmark Foods, Inc. - Executive Summary |
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I. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICY: It is the written policy of Goodmark Foods, Inc. to maintain a comprehensive safety and health program in the plant. This comprehensive safety program includes hazcom, physical hazards, powered vehicles, PPE, hearing protection, respiratory protection, emergency egress, confined space, and emergency response programs. The program details procedures that are to be implemented and assignment of resposible parties should there be a release of highly hazardous chemical. All safety program information is reviewed annually and a copy of the emergency resonse program is sent to the local Fire Department/ LEPC for review and comment. The Company provides emergency responder "level A" equipment and training to members and supervisors of the emergency response team. Goodmark Foods, Inc. also maintains an ongoing OSHA PSM program with current maintenance and operating procedures for the single on-site ammonia refrigeration system . Mechanical integrity of the ammonia system is assured with a computerized preventative maintenance/ parts tracking program. II. DESCRIPTION OF THE FACILITY AND HIGHLY HAZARDOUS CHEMICALS HANDLED: Goodmark Foods Inc. is a meat further processing plant located on an approximately 10 acre site. The processing plant is a two story building used to house mixing, conveying, cooking, freezing, packaging and warehousing facilities. The product (processed meat) requires refrigeration for processing and storage.Anhydrous Ammonia is used as the refrigerant for freezers and processing areas used in the process. Freon refrigerant is used in other area cooling and raw material storage refrigeration. There is 29,000 pounds of anhydrous ammonia contained in the system. Propane (LPG) is stored for emergency use in a 20,000 gallon and a 30,000 gallon tank. III. THE WORST CASE RELEASE SCENARIO(S) AND THE ALTERNATIVE RELEASE SCENARIO(S): The worst case release scenario for ammonia has b een determined through materials balance and process hazard analysis (RMP-PHA) to be a rupture of the high pressure reciever (HPR) which could contain the entire system volume of ammonia. This vessel failure would release the system volume into the engine room that is open to atmosphere and release the entire system volume to atmosphere on the plant site with an offsite impact. ALOHA/MARPLOT was used for the dispersion model. Based on industry literature (IIAR) there is no passive or active mitigation. The worst case release scenario for the flammable liquid (propane) is determined to be the complete loss of containment of the largest 30,000 gallon storage vessel and subsequent vapor cloud explosion. Dispersion modelling was done with RMP COMP. The alternate release scenario for ammonia was determined from an RMP-PHA. The Pump Reciever Unit (PRU) for the + 40 degree freezer holds more than 2000 pounds of ammonia, the largest volume under normal operating conditions, at the n ormal processing refrigerant level. It is conceivable that the vessel could rupture at a nozzle attachment releasing a known quantity of ammonia refrigerant to the engine room which is open to atmosphere. ALOHA/ MARPLOT/ Landview III was used for the dispersion model. Based on available IIAR technical information no passive or active mitigation was considered. The most likely alternative release scenario for propane storage system was determined to be a pipe failure of the fill system after pull away with a hose still connected to the fill line. IV. THE GENERAL ACCIDENTAL RELEASE PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS: The accidental release program is dependent on the plant maintaining good mechanical integrity through application of its computerized preventative maintenance (PM) program. Preventive maintenance scedules and procedures were determined following equipment manufacturer's guidelines and industry (IIAR) trade associattion recommendations. This informatio n was incorporated into the plant PMS computer preventative maintenance program. Ammonia detectors are installed in process areas to alert the security and maintenance personnel that a release is in progress and to allow timely restoration of containment. There has been no release of any kind to date. All safety relief valves are installed in tandem. V. FIVE YEAR ACCIDENT HISTORY: There have been no accidents or incidents involving the ammonia refrigeration system since it was installed more than 5 years ago. VI. THE EMERGENCY RESPONSE PROGRAM: Goodmark Foods, Inc.safety program is designed to identify, evaluate and control safety and health hazards and provides for emergency response in the event of a hazardous chemical spill. The site specific safety and health program has an organizational structure headed by the Plant Manager, a comprehensive workplan, a training program to train employees in recognizing and abating safety and health hazards before they are required to begin a new job assignment, medical surveillance of employees, standard operating procedures for all equipment in normal and emergency situations, and written communication of safety and procedural information between the plant and contract personnel. Initial and annual refresher training is conducted along with medical surveillance examinations for all HazMat team members. Anhydrous ammonia is the only listed highly hazardous chemical on the plant site. It remains in a closed loop system, therefore there is no waste. VII. PLANNED CHANGES TO IMPROVE SAFETY: Additional ammonia vapor monitoring points will be added to the site. Additional labelling will be added to the piping system in the plant overhead pipe runs. The existing computer monitoring and data logging system will be reviewed/ updated in 1999. |