Harrison Poultry - Executive Summary |
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RISK MANAGEMENT SUBMISSION STATEMENT Harrison Poultry P.O. Box 550 Bethlehem, GA 30620 This is to inform all interested persons, including employees that Harrison Poultry, Bethlehem, GA is complying with OSHA's Process Safety Management Standard (called Process Safety Management or PSM), Title 29 Code of Federal Regulations (CFR) 1910.119, and EPA's Risk Management Program regulations (called RM Program), Title 40 CFR Part 68, to deal with the risks involved with the storage, handling, and processing of hazardous chemicals. In this way we promote overall plant, worker, and public safety. These programs enable our facility to prevent the occurrence, and minimize the consequences, of significant releases of toxic substances as well as fires, explosions, and other types of catastrophic accidents. Overall, these programs prevent accidental fatalities, injuries and illnesses and avoid physical property damage. Our safety programs are applied to any activity involving hazard ous chemicals including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. Any group of vessels which are 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. Our safety programs prevent accidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment. These rules are detailed and improved as necessary. They are also communicated to and accepted by all employees at the facility. WORST CASE SCENARIO: Failure of the high pressure receiver containing 14,550 lbs. of ammonia with the receiver quantity limited to 80 % of the vessel capacity by facility procedures resulting in a ten minute release. Under worst-case weather conditions, ammonia could travel 2.2 miles before dispersing enough to no longer pose a hazard to th e public. This scenario is unlikely for the following reasons: worst-case weather conditions are uncommon; the vessel located in a protected area below the evaporative condensers, was recently installed with all new valves and piping to industry standards for the manufacture and quality control of pressure vessels, thus a mechanical failure is unlikely; ammonia is not corrosive in this service; pressure safety valves limit operating pressure in this vessel; the accident prevention program in place at the facility including the mechanical integrity program for regular maintenance, inspection and testing, and replacement of equipment, if necessary; and the emergency response plan and equipment in place at the facility. ALTERNATIVE RELEASE SCENARIO: Failure of a compressor high pressure cutout switch causes a safety valve to release ammonia to the atmosphere at a rate of 26 lbs. per min. for 60 minutes before detection and control, resulting in a 1560 lbs. release of ammoni a. Under common weather conditions, ammonia could travel .1 miles before dispersing enough to no longer pose a hazard to the public. This particular case was chosen as an alternative scenario because of the number of compressors with pressure switches that could be struck or possibly mechanically fail. This scenario is unlikely for the following reasons: travel and activity within the compressor room is restricted; the facility accident prevention program in place including operating procedures to have maintenance personnel present 24 hours per day, and the mechanical integrity program for regular maintenance, inspection and testing, and replacement of equipment, if necessary; and the emergency response plan and equipment in place at the facility. ACCIDENT HISTORY: There were two reportable accidents in the past five years. Only one resulted in minor injury to one worker. On July 6, 1999, a holiday period, 125 lbs. was released during a 10 minute interval with no known risk s or required evacuation. On March 29, 1999, a vessel overpressure occurred causing a oil pot's safety valve to release approximately 200 lbs. of ammonia gas to the atmosphere. The release, during working hours, required a plant evacuation and one worker incurred minor injuries. Within the past five years, the ammonia refrigeration processes have had no accidental releases that have caused offsite impacts provided in the risk management program rule {40CFR 68.10(b)(1)}. EMERGENCY RESPONSE PROGRAM: This facility's emergency response program is based on the OSHA requirements for Emergency Action Plans (29 CFR 1910.38 and 1910.119) and HAZWOPER (29 CFR 1910.120). We have trained employees for emergency response and maintain a written emergency response plan. This plan is coordinated with the Local Emergency Planning Committee (LEPC) and the local fire department. We conduct annual drills for implementation of the emergency response plan at the facility with the participatio n of the LEPC and the fire department. The facility has an action plan to alert the community of an emergency. The last training at the plant was on March 31, 1999. Certification Letter Certification Statement for Program 1 Process(es) Based on the criteria in 40 CFR 68.10, the distance to the specified endpoint for the worst-case accidental release scenario for the following process(es) is less than the distance to the nearest public receptor: [insert description for first program 1 process from executive summary] [insert description for second program 1 process from executive summary]] etc. Within the past five years, the process(es) has (have) had no accidental release that caused offsite impacts provided in the risk management program rule (40 CFR 68.10(b)(1)). No additional measures are necessary to prevent offsite impacts from accidental releases. In the event of fire, explosion, or a release of a regulated substance from the process(es), entry within the distance to the specified endpoints may pose a danger to public emergency responders. Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RMP. The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate, and complete. _________________________________ _______________________ Signature Print Name _________________________________ _____________ Title Date |