Armour Swift-Eckrich Deli Foodservice Company - Executive Summary |
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EXECUTIVE SUMMARY 1.0 RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Armour Swift-Eckrich facility in Omaha, Nebraska has a good record in preventing releases of anhydrous* ammonia. As part of their release prevention program, the plant has an excellent and very detailed preventative maintenance program. More information about these aspects of the prevention program is discussed in Section 4.0 of this Executive Summary. The facility has implemented a Chemical Release Response Plan which is to provide information and guidance to safely deal with an ammonia release. This detailed emergency response program includes procedures for handling an emergency - the established response plan and appropriate personnel involved in containing an ammonia release - HAZMAT Response Team. These components make the Chemical Release Response Plan a thorough and comprehensive plan for release prevention and emergency response. The emergency response policies at the Armour Swift-Eckrich facil ity ensure that there is emergency response coverage 24 hours - 7 days per week. *From this point in the Executive Summary, anhydrous ammonia will be synonymous with ammonia. 2.0 PROCESS DESCRIPTION AND REGULATED SUBSTANCES The Armour Swift-Eckrich Omaha Plant produces various meats including: dry sausage, pepperoni, salami, and proscuitto ham. The NAICS code for the processes at this facility is 311612. Many areas of the plant are refrigerated to preserve the meat products. Armour Swift-Eckrich has one regulated substance under 40 CFR 68: ammonia. Ammonia is used as a refrigerant in the refrigeration of the products in the various areas of the plant. The ammonia threshold for triggering applicability to 40 CFR 68 is 10,000 pounds. The total quantity of ammonia stored in the refrigeration process is documented as 29,524 pounds. The process exceeds the threshold quantity of 10,000 pounds as set by 40 CFR 68 and thus is regulated by the Risk Management Program. 3.0 WORST-CAS E AND ALTERNATIVE RELEASE SCENARIOS The ammonia refrigeration system has associated hazards that can potentially affect on-site employees and the general public off-site if there is a release from the system. Described below are the associated hazards and the worst-case and alternative release scenario for the regulated chemical. Though there may be other scenarios possible, EPA only requires that one worst-case and one alternative scenario be reported for each regulated chemical. Ammonia is classified as a Group 2 Refrigerant per ASHRAE Standard 34-1989. The dominant characteristic of this chemical is its toxicity. It is a self-alarming chemical by its distinctive pungent odor. Due to this odor, persons exposed to ammonia vapor will not voluntarily stay in areas of even small concentrations. Ammonia will burn at a very narrow and high range of concentrations accompanied with a high ignition temperature. Although ammonia is not poisonous, it is corrosive to human tissue. Amm onia is readily absorbed into the moisture of the skin and, at high concentrations, can cause severe burns. The risks to persons in an accidental release of ammonia include: 1. Corrosive attack of skin and other tissue (including lung tissue) 2. Freezing of skin and other body tissue when contacted by liquid ammonia 3. Eye contact Below is a description of the release scenarios for ammonia and their off-site consequences: 3.1 Worst-Case Scenario Description One worst-case scenario has been developed for the Omaha plant. The largest potential release of ammonia would occur with a 1 = inch diameter puncture in the liquid portion of the south high back accumulator. Taking the specific definition of the worst-case from 40 CFR 68.25, the vessel that can store the largest quantity of ammonia is the south high back accumulator. The total quantity of ammonia that can be stored in the south high back accumulator is 7,716 pounds. Therefore, the worst-case release quantity will be 7,716 pounds. Administrative and passive controls are not applicable to this scenario. It is assumed that the entire 7,716 pounds is released to the atmosphere in 10 minutes. For the worst-case release, regulations dictate that the release height is at ground level. Under Section 68.25(c)(1), a regulated toxic substance such as ammonia that is normally a gas at ambient temperature and handled as a liquid under pressure shall be considered to be released as a gas over a 10 minute period. Thus, ammonia's physical state in the worst-case scenario is a gas. Since this facility is located in a populated area, the worst-case release scenario distance-to-endpoint will reach off-site receptors. 3.2 Alternative Release Scenario Description The alternative release scenario is an ammonia release from piping on the roof. The release scenario considers a contractor dropping an object causing a pump liquid line to crack The opening in the damaged pipe is assumed be equivalent to a = diameter o rifice, and is located 40 feet above ground level. Administrative and passive controls are not applicable to this scenario. Active mitigation of the release is human intervention. Since this facility is located in a populated area, the alternative release scenario distance-to-endpoint will reach off-site receptors. 4.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Armour Swift-Eckrich has developed an OSHA (PSM) program for their ammonia refrigeration system. At Armour Swift-Eckrich, ammonia falls under the RMP Program 3 Prevention Program which is identical to the OSHA PSM program. EPA has said that if the process is in compliance with OSHA PSM, then it is compliance with RMP Program 3. Thus, Armour Swift-Eckrich's ammonia PSM system has been reviewed and the PSM system elements are being implemented for the RMP. Listed below are the key aspects of the ammonia prevention program: The plant uses a Computerized Maintenance Managemen t System (CMMS) for control scheduling and accomplishment of preventative maintenance on components of the refrigeration system. The scope of preventative maintenance (PM) and testing/inspection (T/I) for refrigeration components is based on individual vendor recommendations and generally accepted engineering practices with regard to types of preventative maintenance and inspections and their recommended frequencies. The plant has created work tasks for each type of PM and T/I associated with the refrigeration system. These tasks are included on the individual work order generated by the CMMS. This system ensures that each operator/mechanic is aware of the pertinent safety precautions required for a PM procedure as well as the step-by-step actions required to complete the procedure. The operator/mechanic and their supervisor sign off the completed work order. Specific results of each PM and T/I procedure are recorded on the work order. In the event a PM or T/I procedure is not c ompleted satisfactorily, the operator/mechanic notes it on the work order, and a follow-up work order is generated to address the specific deficiency. 5.0 FIVE-YEAR ACCIDENT HISTORY The review of Armour Swift-Eckrich's accident history includes the following range of dates: June 21, 1994 - June 21, 1999. According to 40 CFR Part 68.42(a), there have been no accidental releases at this facility. 6.0 EMERGENCY RESPONSE PROGRAM As mentioned previously, the Armour Swift-Eckrich facility has developed a Chemical Release Response Plan. The response plan is a detailed document which discusses the role of employees in an emergency situation. The plan outlines specific procedures for evacuations for plant personnel. All emergency response personnel (HAZMAT Response Team) undergo emergency response training. For all emergencies, the Incident Commander has operating authority for emergency response at the site of the release and has the authority to obtain resource support from within all d epartments of Armour Swift Eckrich in order to effect a quick and proper response. This team is responsible for implementing the response plan and controlling all aspects of the plan and personnel. This document contains specific procedures for: incident response guidelines; responsibilities and lines of authority; coordination with other emergency response plans; testing of alarms; chemical release drills; HAZMAT Response Team; training; communication with outside agencies; evacuation routes, safe distance and places of refuge; site security and control; emergency medical treatment and first aid; PPE and emergency equipment; decontamination; and critique of response operations. 7.0 PLANNED CHANGES TO IMPROVE SAFETY Based on the completed Process Hazard Analysis (PHA) for ammonia, a list of action items to improve safety was developed and their status monitored to ensure that implementation was accomplished. An example of safety improvements made at the plant is discussed below: The plant has nearly completed all of its valve tagging and line labeling for the ammonia system. |