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 Wells, Minnesota 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 computerized 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 an Emergency Response Program which is to ensure the safety of its employees', the community, and the environment. This detailed emergency response program includes procedures for handling an emergency - the established action plan and appropriate personnel involved in containing an ammonia release - HAZMAT Team. All of these components make the Emergency Response Program a thorough and comprehensive plan for emergency response. The emergency response policies at the Armour Swift-Eckrich facility ensure that ther e 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 Armour Swift-Eckrich is a producer of prepared meat products. The NAICS code for the processes at this facility is 311615. 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 approximately 8,063 pounds. The process does not exceed the threshold quantity of 10,000 pounds as set by 40 CFR 68; however Armour Swift-Eckrich requested that a Risk Management Program be developed for the Wells plant. 3.0 WORST-CASE AND ALTERNATIVE RELEA SE 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. Ammonia is readily absorbe d 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 Wells plant. The largest potential release of ammonia would occur with a one inch diameter puncture in the liquid portion of the high pressure receiver. 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 high pressure receiver. The total quantity of ammonia that can be stored in the high pressure receiver is 8,015 pounds during pumpout of the system. Administrative controls are not applicable to this scenario. It i s assumed that the entire 8,015 pounds is released to the atmosphere in 10 minutes. For the worst-case release, regulations dictate that the release height is at ground level. Therefore, the worst-case release of 8,015 pounds is modeled as if it originates 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 a high pressure liquid pipe located on the roof. The release scenario considers a contractor working on the roof dropping material on a pipe rack of ammonia piping. The material con tacts a high pressure liquid pipe on the rack and creates an opening of three-eighths of an inch in the pipe. The horizontal discharge is located at approximately twenty feet above ground level. Administrative 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. 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 Management 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 work order is signed off by both the operator/mechanic and their supervi sor. In the event a PM or T/I procedure is not completed 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 an OSHA hazardous substance emergency response program called Emergency Action Plan (EAP). This document was developed in accordance with 29 CFR 1910.38 and 29 CFR 1910.120. Armour Swift-Eckrich's EAP is a detailed document which discusses the role of employees and management in an emergency situation. All emergency response personnel (HAZMAT Team) undergo emergency response training. The plan outlines specific procedures for evacuations and incident alarms by means of an alarm system. For all emergencies, the plan activates the Emergency Team Coordinator, the Assistant Emergency Team Coordinator, and the Safety Coordinator. This team is responsible for implementing the EAP and controlling all aspects of the plan and personnel. This document contains specific procedures for: 1) emergency notification procedures, evacuation instructions, personnel accounting procedures as well as notification of response groups; 2) emergency medical treatment; 3) HAZMAT-chemical spills and releases (includes roles and lines of authority, emergency recognition and prevention, safe distances and places of refuge, site security and control, medical/first-aid, decontamination, personal protective equipment, and emergency equipment); and 4) critique of response and follow up. 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: During the site visit there was a significant amount of insulation missing from the High Temperature Recirculator (HTR) vessel and its piping, resulting in considerable frost accumulation on the exposed surfaces. The reinsulation was completed by May 1999. |