Cromwell Processing Plant Facility #83 - Executive Summary |
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Executive Summary Perdue Farms Incorporated ? Background Perdue Farms Incorporated, founded in 1920, is the largest poultry producer in the Northeast and the third largest in the United States. Headquartered in Salisbury, Maryland, the family owned, privately held company has operations in 14 states. Twenty processing facilities produce about 50 million pounds of poultry products each week. Perdue also has grain storage and merchandising operations and is ranked among the top 20 largest U.S. grain companies. Perdue also manufactures edible oils, specialty feeds, livestock feed ingredients and premium pet food ingredients. ? Chemical Management Program As a concerned member of the communities in which Perdue facilities are located, the company takes its role as a responsible corporate citizen very seriously. All Perdue facilities are operated to protect employees, contractors and the public from injury and illness, and to minimize environmental impact. A company-wide safety and wellness program stresses safe conditions and safe practices. Perdues policy is to inspect, maintain and operate equipment and facilities to prevent accidents, including release of hazardous materials; and to train employees in prevention, as well as to prepare them to respond rapidly and effectively should an accident occur. Perdue Farms has developed and implemented Spill Prevention Control and Countermeasures (SPCC) and Process Safety Management (PSM) plans at each operations facility as part of an overall chemical management program. The program involves a wide range of senior management personnel, including the Director of Environmental Services and the Director of Safety and Security. Additionally, Perdue conducts regular safety meetings and provides a wide variety of environmental, health and safety training to its staff. ? RMP Communications Plan As part of its Risk Management Program, Perdue Farms has developed an RMP Communications Plan. The goal s of this plan are (1) to educate the public on the potential risk of regulated substances used by Perdue; (2) to respond to any concerns that RMP disclosures may cause with honest, fact-based communication; and (3) to be fully prepared to effectively respond to any accidental chemical release scenario. Proactive materials about the disclosure information, how the company is prepared to deal with an accident, how the community should respond to an accident, and a process for announcing that an accident has occurred (to be used as needed) are being prepared. In addition, training and information materials for Perdue managers and employees, community officials, civic groups, the media, environmental groups, emergency response personnel and the public in general will be available. Cromwell Processing Plant Facility #83 The Perdue Farms, Cromwell Processing Plant Facility #83 is a poultry-processing plant located approximately 0.7 miles northwest of the intersection of Cromw ell Road and Highway 231 in Cromwell, Kentucky. This facility began operation in February 1996 and is currently bounded on all sides by farmland. Perdue Farms currently has four (4) processes that contain regulated substances covered by EPAs 40 CFR Part 68. Accidental Release Prevention and Emergency Response Policies Perdue Farms has developed and implemented SPCC and PSM plans as part of the overall chemical management program. The programs involve a wide-range of senior management personnel (including Environmental Services Manager and Safety Supervisor). Additionally, Perdue conducts regular safety meetings that involve many levels of personnel. The facility also maintains a process safety management program as part of the overall chemical safety program. Lastly, Perdue provides a wide variety of environmental, health & safety training to staff as part of the emergency response team. Description of Facility and the Regulated Substances 1. Refrigeration (anhydro us ammonia) Ammonia is used for refrigeration purposes. The facility operates a three- temperature, single-stage, anhydrous ammonia refrigeration system. The refrigeration system is a closed loop liquid re-circulation system with a total system storage capacity of 32,000 pounds. The majority of the refrigeration components are located in the mechanical room, with the exception of the condensers located on the roof and piping located throughout the facility. 2. Water Treatment Plant (chlorine) The facility operates a water treatment plant (WTP) with a maximum capacity of 3 million gallons per day (MGD). Currently, the WTP treats approximately two-MGD for the facility and will later begin treatment of an additional one MGD for public water supply. Raw water withdrawn from the Green River is treated by the addition of conventional water treatment chemicals to aid in the flocculation of solids. Chlorine gas is injected into the water for disinfection purposes. Four, 1-t on containers are stored in the Chlorine Storage Room at the WTP. Two of the containers are interconnected by an automatic switchover system for the distribution of chlorine gas to the water flow while the other two containers are either full or empty 3. Process Facility (chlorine) Perdue Farms boosts the chlorine concentration from the water treatment plant 20 to 40 ppm for use in the sanitation of process equipment. The chlorination process involves withdrawing chlorine gas from a container under vacuum and injecting the gas to the process water for use throughout the facility. The total quantity of chlorine used in this process is 8,000 pounds in the form of two, 1-ton containers connected in series and two additional 1-ton chlorine containers stored adjacent to the interconnected containers. These two additional containers may be either full or empty depending on the time of delivery or container replacement. All four of the chlorine containers are stored outs ide and are surrounded by a 6 foot chain-link fence. As one container is emptied, the second container is manually switched on-line. 4. Emergency Heating Fuel (propane) Perdue Farms stores propane to fuel the back-up heating system at the facility in the event of an extended power failure. Bulk propane is stored in an 18,000-gallon aboveground storage tank (AST) located to the north of the processing facility. Worst-Case Release Scenarios 1. Refrigeration (ammonia) The predicted worst-case scenario for this process is the catastrophic failure of the high temperature recirculator pressure vessel (V3) located in the mechanical room of the facility. This vessel has a storage capacity of 5,304 gallons. However, high- level alarms limit the maximum liquid ammonia within the vessel to 55% of the total capacity, or approximately 2,917 gallons. Using a specific gravity of ammonia of 0.77 at 0 degrees Celsius, 18,740 pounds of liquid ammonia is predicted to be released over a 10- minute period. During a release, the migration of ammonia vapor off-site will be limited due to the fact that the mechanical room will assist in the containment of the release of ammonia to the atmosphere (outside the facility). Using RMP*Comp Version 1.06 software, the distance to a toxic endpoint of 0.14 mg/l is predicted to be 1.8 miles. To obtain the number of public and environmental receptors located within this radius, the facility was located on the 7.5 USGS Topographic Map (Cromwell Quad, 1971) and a circle having a radius of 1.8 miles was inscribed with the center located at the corresponding latitude and longitude coordinates of the above-mentioned ammonia pressure vessel. Additional topographic maps were used as necessary to complete the radius of influence. The receptors were then manually counted, and a population multiplier of 3.5 (residents per household) was applied to arrive at the approximate population estimate within this radius of influence. This radius encompasses approximately 291 residences, one school and one recreation facility, with a total population estimate of approximately 1,000 people. 2. Water Treatment Plant (chlorine) The predicted worst-case release scenario for this process is a catastrophic release of one 2,000-pound chlorine container stored in the cinder block enclosure. This enclosure will limit the dispersion of both liquid and vapor to the atmosphere during a release. For this scenario, 2,000 pounds of chlorine liquefied under pressure are assumed to be released in 10 minutes. Using RMP*Comp Version 1.06 software, the distance to a toxic endpoint of 0.0087 mg/l is predicted to be 2.2 miles. The method of estimating the population and number of receptors located within this 2.2-mile radius is the same as that used for the ammonia worst-case release scenario. This radius encompasses approximately 358 residences, one school, and one recreation facility, with a total population estimate of ap proximately 1,300 people. A multiplier of 3.5 residents per household was assumed in obtaining this population estimate. 3. Process Facility (chlorine) The predicted worst-case scenario is the catastrophic release of one 2,000-pound chlorine container within 10 minutes. Using RMP Comp modeling software (Version 1.06), the distance to a toxic endpoint of 0.0087 mg/l is predicted to be 3.0 miles. The method of estimating the population and number of receptors located within this 3.0-mile radius is the same as that used for the ammonia worst-case release scenario. This radius encompasses approximately 388 residences, one school, and one recreation facility, with a total population estimate of approximately 1,400 people. A multiplier of 3.5 residents per household was assumed in obtaining this population estimate. 4. Emergency Heating Fuel (propane) The proposed worst-case release scenario for this process is an explosion of the 18,000-gallon propane AST resulting in a pro pane vapor-cloud. The storage capacity of the AST is 18,000 gallons; however, the corresponding maximum quantity of propane is 67,000 pounds or 88% capacity of the AST. The total quantity of propane was obtained from Table 2 (page 10) of the EPAs Risk Management Program Guidance for Propane Storage Facilities. Using RMP Comp modeling software (Version 1.06), the distance to 1-psi overpressure is predicted to be 0.3 miles. The number of receptors and population located within this radius was obtained using a Garmin Model GPS 12 hand-held global positioning unit. EMPE personnel obtained the latitude and longitude coordinates of the storage tank, then walked in a direct path to the residence observed to be nearest to the propane tank. At the time of this report, the direct line distance to the nearest residence obtained by this method is greater than the distance to the 1-psi overpressure of 0.3 miles. There are no apparent off-site public or environmental receptors loc ated within this radius. Alternative Release Scenarios 1. Refrigeration (ammonia) The predicted alternative release scenario for this process is the rupture of a chiller resulting from impact of a motorized forklift. Because the facility was constructed in 1995 and utilizes a preventative maintenance program, mechanical or equipment failure is not anticipated to be the most probable alternative release scenario. Rather, it appears that the most probable alternative release scenario, at this time, would result from human error. Perdue Refrigeration Department personnel described the potential impact of the chiller located in a traffic area as the most probable release scenario. Perdue Refrigeration Department personnel also indicated that such an impact would result in a release of approximately 75 pounds before automatic pressure monitors would shut the system down. This release would occur within one minute and the release would be somewhat mitigated by the enclosed fa cility. Using RMP Comp modeling software (Version 1.06), the distance to a toxic endpoint of 0.14 mg/l is 0.1 miles. There are no apparent public or environmental receptors within this radius. 2. Water Treatment Plant (chlorine) The predicted alternative release scenario for this process assumes that the vacuum regulator is accidentally ruptured with the valve in the open position. As a result, chlorine vapor discharges for 30 minutes until the 1-ton container (approximately 2,000 pounds) is emptied. According to RMP*Comp Version 1.06 software, the distance to a toxic endpoint of 0.0087 mg/l is predicted to be 0.3 miles. The number of receptors and population located within this radius was obtained using a Garmin Model GPS 12 hand-held global positioning unit. EMPE personnel obtained the latitude and longitude coordinates of the chlorine containers as well as the surrounding residences that would most likely be affected. These lat/long data were then converted to Un iversal Transverse Mercator (UTM) coordinates using a Transverse Mercator Calculator available on the Internet at http://www.compulink.co.uk/~dmap//ll2tm.htm. The straight-line distance from the chlorine containers to each residence was then calculated. At the time of this report, the resulting calculations revealed two residences and no environmental receptors located within a radius of 0.3 miles, with an estimated population of seven people. A multiplier of 3.5 residents per household was assumed in obtaining this population estimate. 3. Process Facility (chlorine) The predicted alternative release scenario for this process assumes that the vacuum regulator is accidentally ruptured with the valve in the open position. As a result, chlorine vapor discharges for 30 minutes until the 1-ton container (approximately 2,000 pounds) is emptied. According to RMP Comp (Version 1.06), the distance to a toxic endpoint of 0.0087 mg/l is predicted to be 0.4 miles. The number of r eceptors and population located within this radius was obtained using a Garmin Model GPS 12 hand-held global positioning unit. EMPE personnel obtained the latitude and longitude coordinates of several reference points along Highway 231, while noting the location of the surrounding residences. These reference points were then plotted on a map depicting the radius of influence and the number of houses within this radius were counted. At the time of this report, there were 17 residences and no environmental receptors within this radius, with a total population estimate of approximately 60 people. A multiplier of 3.5 residents per household was assumed in obtaining this population estimate. 4. Emergency Heating Fuel (propane) Because this process is subject to Program Level 1 requirements, an alternative scenario is not required. General Accident Release Prevention Program The Perdue Farms facility maintains a Process Safety Management (PSM) of Highly Hazardous Chemical s plan prepared in accordance with the Occupational Health and Safety Administration (OSHA) regulation 29 CFR 1910.119. Perdue Farms also utilizes a preventative maintenance program for its system components. As part of this program, maintenance personnel inspect the refrigeration system operating parameters and monitoring system five times per shift with all observations logged on a checklist. Additionally, maintenance personnel have instituted a daily inspection of the chlorination system at each water treatment facility to ensure proper operation. Five-Year Accident History There have been no accidents involving chlorine, ammonia or propane at this facility nor off-site that have resulted in death(s), injuries, property damage, evacuations, environmental damage or sheltering in place. Emergency Response Program Perdue Farms has implemented a comprehensive Emergency Response Plan in accordance with the OSHA PSM regulations. The facility has a trained emergency respons e team that will respond in the event of a hazardous material release, fire or other emergency situation. The written Emergency Response Plan contains specific information regarding Emergency Response organization and procedures, as well as incident notification, mitigation, and incident preparedness. In addition, Perdue Farms training program includes annual refreshers. Also, the plant conducts a mock evacuation two times per year with at least one drill coordinated with local emergency responders (Cromwell and Beaver Dam Fire Departments). Planned Changes to Improve Safety Perdue Farms is in the process of installing an ammonia gas detection system and exhaust fans in the Mechanical Room. In order to minimize the exposure of facility personnel in the event of a release, two exhaust fans will be activated if the ammonia concentration is detected above 15 ppm. Also, the facility has implemented bi-annual vibration analysis to ensure the mechanical integrity of the refr igeration system. In addition, as part of Perdues continued improvement philosophy, all Perdue facilities continue to identify and update system components and techniques to ensure safety. Perdue Farms/Reports/ExecSum.doc |