Patrick Cudahy, Inc. - Executive Summary |
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RMP/PSM EXECUTIVE SUMMARY Patrick Cudahy Inc. 3500 E. Barnard Cudahy, WI 53110 This is to inform all interested persons, including employee's that Patrick Cudahy Inc., is complying with the Occupational Safety and Health Administrations (OSHA) Process Safety Management (PSM) Regulation, Title 29 Code of the Federal Regulations (CFR) 1910.119, and the Environmental Protection Agency (EPA) Risk Management Program (RMP) Regulations, Title 40 code of the Federal Regulations (CFR) Part 68. These Regulations deal with the risk involved with the storage, handling, and processing of hazardous chemicals. In complying this way, we promote overall facility, employee, and public safety. Patrick Cudahy's program enables our facility to prevent the occurrence of, and minimize the consequences of, significant releases of toxic substances as well as fires, explosions, and other types of catastrophic accidents. Overall, these programs are in place to prevent the potential for accidental injury, illnes s, death, and to avoid the potential for property and environmental damage. Patrick Cudahy's safety programs are applied to all activities involving hazardous chemicals including use, storage, handling, or the on-site movement of chemicals. Any group of vessels interconnected and separate vessels which are located such that a hazardous chemical could be involved in a potential release shall be considered a single process. Patrick Cudahy's safety programs prevent accidents because they focus on the rules, procedures, and best practices that govern processes, activities, and or pieces of equipment. These rules are detailed and revised as necessary. All information is communicated to employees of Patrick Cudahy Inc. through training and documentation. Patrick Cudahy Inc. is a processing and packaging company that utilizes approximately 83,000 pounds of Anhydrous Ammonia in its refrigeration system to cool the facility's production and shipping area's. In a Worst Case Scenario, failu re of the high-pressure receiver under worse case weather conditions would release approximately 30,000 pounds of ammonia over a ten-minute period. The release would travel up to 2 miles before no longer posing a significant hazard to the public. However, this scenario is highly unlikely for the following reasons: Worst case weather conditions are uncommon The vessel is in a protected area clear of vehicular and pedestrian traffic Industry standards for the construction and quality control of pressure vessels Safety relief values preventing over-pressurization of the vessel are in use. Bach-up rupture disks are also in place Accident prevention programs in place Mechanical integrity program, inspection and testing procedures are in place. Emergency alerting alarms integrated into the process system Emergency response and action plans in place at the facility In an alternative case scenario, mechanical pump seal deterioration under pressure could release approximately 3,830 p ounds of ammonia over a ten-minuet period before no longer posing a significant threat or hazard. The vapor could travel as far as .22 miles. Mechanical deterioration of an ammonia pump seal was chosen as an alternative release because of its higher likelihood that it could occur. This scenario even though potentially possible, is unlikely for the following reasons: Emergency shut-down procedures Regular maintenance seal and valve upgrade Inspection and rounds made daily of the process system to ensure safe operation Emergency response plan and refrigeration personnel on-site around the clock Patrick Cudahy's accidental release prevention programs are based on safe work practices as referenced by the Occupational Safety and Health Administration, Environmental Protection Agency, American National Safety Standards, and the International Institute of Ammonia Refrigeration (2 - 1992). Key elements of this prevention program are comprised of: 7 Equipment design, installation, an d operation of ammonia process systems (ANSI / IIAR 2) 7 Emergency Response and Action Plan Program (OSHA 29CFR1910.120, 1910.38, and EPA 40 CFR Part 68.) 7 Mechanical intergrity, Emergency shutdown procedures, and inspection program (OSHA 29CFR 1910.119). Patrick Cudahy, Inc. has not had any accidental releases in the past 5years that have resulted in offsite consequences. The facility emergency response program is based on OSHA's Regulations for Emergency Action Plans (1910.38 and 1910.119) and HAZWOPER (29CFR1910.120). Patrick Cudahy Inc. has an on-site trained emergency response team (HAZMAT) and maintains a written emergency response plan that is reviewed annually. This plan is coordinated with the Local Emergency Planning Committee, Fire Department, Police and Emergency Medical facilities to ensure communication with all potential or actual involved resources should their involvement be necessitated by a release. Through Process Hazard Analysis, Inspections, annual reviews, and audits, Patrick Cudahy Inc. continuously improves it's process system, procedures, programs, and training to ensure mitigation, control, technology, equipment, and organizational changes remain consistent and in force. Through this initiative, Patrick Cudahy Inc. can ensure the utmost safeguards are utilized as it relates to it's process system and programs for the overall safety and well being of the employees, facility, and the environment. |