Gold Kist Sumter Processing Plant - Executive Summary |
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Executive Summary Gold Kist South Carolina Division Sumter, SC Processing Plant 1. Accidental Release Prevention and Emergency Response Policies Management of the Gold Kist South Carolina Division processing plant in Sumter (GK-Sumter) is strongly committed to employee and public safety and environmental protection. This commitment is demonstrated by our comprehensive accidental release prevention program which includes equipment design and installation, operating and maintenance procedures and employee training. Our employees implement appropriate controls to prevent possible releases of regulated substances. If a release does occur, trained emergency response personnel are present to control and mitigate the effects of the release. We also coordinate with the Sumter Fire Department for additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled GK-Sumter is a poultry processing plant which uses two regulated substances, ammonia and m ethane, in its operations. Ammonia is used as a refrigerant to ensure wholesome products. Methane is a byproduct of the wastewater treatment system. It is generated in the covered anaerobic treatment lagoon and is burned off through a waste gas burner. 3. The Worst Case Release and Alternative Release Scenarios In evaluating worst case and alternative release scenarios, look-up tables and equations provided by the EPA in the RMP Guidance for Ammonia Refrigeration and the RMP Guidance for Wastewater Treatment Plants were used. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from the ammonia refrigeration system. The scenario involves the release of ammonia in a gaseous form from the largest vessel over a ten-minute period. The release is modeled under worst case meteorological conditions, has a maximum distance to endpoint of 2.3 miles and could have off-site impacts. One alternative release scenario will be submitted for each toxic substance present in Program 2 and Program 3 processes cumulatively. The alternative release scenario for ammonia involves a release from Receiver 2 in the ammonia refrigeration process. The scenario involves the release of ammonia in a gaseous form from a 3/4-inch hole in a high pressure pipe or vessel located outdoors over a ten-minute period. Under neutral weather conditions, this release scenario has a maximum distance to endpoint of 0.24 miles and could have off-site impacts. The worst case release scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release from the anaerobic lagoon treatment process. The scenario involves the release of the total volume of methane stored under the lagoon cover. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity particip ating in a vapor cloud explosion. Under worst case weather conditions, this release scenario has a maximum distance to 1 psi overpressure of 0.32 miles and could have off-site impacts. The alternative release scenario submitted for Program 2 and 3 flammable substances involves a release of methane from the anaerobic lagoon flare. The release, which occurs over a 180-minute period, results in a vapor cloud explosion. It is assumed that the vapor finds an ignition source and that 10 percent of the released quantity participates in the vapor cloud explosion. Under neutral weather conditions, this release scenario has a maximum distance to 1 psi overpressure of 0.1 miles, and does not have off-site impact. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps The GK-Sumter facility is in compliance with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The refrigeration process is subject to the OSHA PS M standard under 29 CFR 1910.119 and subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information- Detailed records of safety information which describe chemical hazards, operating parameters and equipment designs associated with all operations are maintained at the facility. Process Hazard Analysis Personnel with engineering and processing expertise conduct comprehensive studies to ensure that hazards associated with our operations are identified and controlled efficiently. Findings related to the hazard analysis are addressed in a timely manner. The methodology used to perform these analyses is the What If/ Checklist method. The studies are validated every five years. Operating Procedures Written operating procedures are in place to ensure safe plant operations. These procedures address various modes of operation including in itial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a planned shutdown. The procedures are reviewed regularly and are readily accessible to employees involved in the operations. Training A comprehensive training program ensures that employees are competent in the operating procedures associated with their jobs. Refresher training is provided every three years and more frequently as needed. Mechanical Integrity Documented maintenance checks are conducted on equipment to ensure proper operations. Equipment examined includes pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Equipment deficiencies identified during maintenance checks are corrected in a safe and timely manner. Plant maintenance is performed by qualified, trained personnel who are provided specialized training as needed. Management of Change Written procedures are in place to manage changes in process chemicals, technology, equipment and procedures. Equipment operators, maintenance personnel or other employees whose jobs are affected by plant modifications are notified and trained. Pre-startup Reviews Pre-startup safety reviews of new processes and modifications of established processes are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Regular audits are conducted every three years to determine compliance with the provisions of the RMP and PSM regulations. Any corrective actions needed are undertaken in a safe and prompt manner. Incident Investigation Any incident that results in or could result in a catastrophic release of a regulated substance is investigated to identify the situation leading to the incident and corrective actions needed to prevent the incident from occurring in the future. Reports of the inv estigation are retained for five years. Employee Participation Plant safety and accident prevention are team efforts. Company employees are encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, employees have access to all information created as part of the facility's implementation of the RMP rule, including process hazard analyses. Contractors On occasion, contractors are hired to conduct specialized maintenance and construction activities. The selection process for contractors includes an evaluation of their safety performance. Contractors are notified of known potential hazards related their work and the emergency response procedures to follow in case of an accidental release of a regulated substance. 5. Five-year Accident History During the past five years, the GK-Sumter has had one RMP recordable release of ammonia in December 1995. Several people were sent to the local hospital for observation, but all were released the same day. No serious injuries or environmental damage occurred. 6. Emergency Response Plan A written emergency response plan is in place to deal with accidental releases of hazardous materials. This plan includes first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, and post-incident decontamination. The plan is updated as needed to reflect changes operations. All emergency response equipment is regularly inspected and serviced to ensure proper operation. 7. Planned Changes to Improve Safety There are currently no planned changes to improve safety at this facility. |