Jimmy Dean Foods - Executive Summary |
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Background Data In accordance with Title 40 of the Code of Federal Regulations Chapter 68 (40 CFR 68) promulgated by the Environmental Protection Agency (EPA), Jimmy Dean Foods (JDF) submits this Risk Management Plan (RMP) for operations at their Newbern, Tennessee facility. JDFs operations include the manufacturing of pork sausage for public consumption packaged under the familiar brand name of Jimmy Dean Sausage. JDF has been in operation at this facility for over eleven years providing quality meat products and over 700 jobs to the local community. Accidental Release Prevention and Emergency Response Policy JDF is committed to protecting the health of its employees, the surrounding community, and the environment; therefore it is JDFs policy to manage a safe and healthy workplace, protect the environment, and maintain compliance with safety, health and environmental regulations: 40 CFR 68 as well as Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Federal Regulations, Chapter 1910, Section 119 (29 CFR 1910.119), and OSHAs Hazardous Operations and Emergency Response regulations (29 CFR 1910.120). Stationary Sources and Regulated Substances JDF is required to maintain low temperatures in the food processing areas of the plant that are within standards required by the United States Department of Agriculture (USDA) to ensure quality in the final products. JDF uses anhydrous ammonia (the 112(r) regulated substance) as a refrigerant to maintain the 275,000 ft2 facility within the required range of operating temperatures. Anhydrous ammonia is an industry-standard refrigerant for meat processing plants. JDFs refrigeration system, consisting of receivers, compressors, evaporators, condensers, and piping, can contain a maximum amount of 51,166 pounds of anhydrous ammonia. Worst Case Release Scenario As required by 40 CFR 68 Subpart B, JDF has evaluated a worst-case release scenario for anhydrous ammonia using the parameters specified by the EPA. JDFs worst case release scenario is the rupture of the largest single receiver (51,166 pounds when filled to 100% capacity) over a 10-minute period. Using the International Institute of Ammonia Refrigeration (IIAR) document, Risk Management Program Guidance (40 CFR Part 68) for Ammonia Refrigeration (Guidance), the maximum distance to the toxic endpoint extends offsite and includes public receptors. The worst-case release scenario was developed following EPA regulations and is not considered to be a likely release scenario. During normal operations, JDF maintains the receiver at no more than 50% capacity. Only during pump-down operations does the receiver have the potential to be filled to 100% of capacity. The receiver is operated in pump-down mode only 2 days per year. Alternative Release Scenario A more realistic release scenario (alternative release) was considered by JDF taking into account the 11-year history of operations experience and the hazards identified in the process hazard analyses (PHAs) conducted to ensure that JDFs hazards are identified and minimized. These analyses were conducted under the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Federal Regulations Chapter 1910, Section 119 (29 CFR 1910.119). Using the International Institute of Ammonia Refrigeration (IIAR) document, Risk Management Program Guidance (40 CFR Part 68) for Ammonia Refrigeration (Guidance), JDF considers the standard scenario presented in Section 4.2, to be a valid and acceptable representation of an alternative scenario for the Newbern, TN, facility. Per the Guidance document, the maximum distance to the toxic endpoint extends offsite and includes public receptors. Accidental Release Prevention Program The ammonia refrigeration system is designed and constructed in accordance with ANSI/IIAR 2- 1992 Standard for Equipment, Design, and Installation of Ammonia Mechanical Refrigerating Systems. To prevent and mitigate accidental releases of anhydrous ammonia, JDF has implemented several precautionary measures, such as process/equipment controls, standard operating procedures, preventative maintenance programs, employee training and audit programs. JDF has developed and implemented a PSM program pursuant to OSHA regulations and as such, has evaluated the system for the potential of anhydrous ammonia releases. Some of the controls installed to prevent catastrophic releases of ammonia are process equipment (vents, pressure relief valves, backup pumps, and manual shutoffs) and automated controls (automatic shut-offs, ammonia leak detection system, and electrical distribution system grounding). In addition, JDF has trained approximately 13 personnel to respond to potential ammonia releases (HazMat team). JDF has developed standard operating procedures for all employees and co ntractors that have contact with the ammonia refrigeration system that incorporate safety measures into the procedures. These safety procedures were developed by refrigeration system operators and are reviewed at a frequency sufficient to assure that they reflect current operating practice, including changes that result from changes in the process chemicals, technology, and equipment, and changes to the facility. JDF encourages employee participation in development of the control measures used at the plant by means of company memoranda and training sessions. Pursuant to written management of change procedures established by JDF, any changes to the operating procedures are to be communicated to affected employees. JDF understands that maintaining the refrigeration system in good working order is essential to preventing accidental releases; therefore JDF has implemented a preventative maintenance program. The preventative maintenance program is scheduled, documented and managed usi ng log sheets to ensure that regular maintenance occurs on the system. These log sheets are maintained in the Refrigeration office for three years. Also, to ensure the mechanical integrity of critical refrigeration system components, equipment tests are performed. Specifically, the equipment is tested to detect corrosion. This equipment consists of pressure vessels, headers, and piping. To ensure that JDFs control measures are effective in maintaining the safe operation of the plant, regularly scheduled audits are performed on the ammonia refrigeration system: 7 In accordance with the PSM program, JDF conducts detailed PSM compliance audits every three years. Each audit incorporates review of process safety information, process hazard analysis, operating procedures, training programs, system mechanical integrity, management of change, pre-start up review procedures, compliance audit procedures, incident investigation procedures, employee participation programs, hot work permit procedures, and contractor safety procedures. 7 In addition, JDF is audited by the local fire department on an annual basis. 7 The USDA maintains a daily presence for monitoring the JDF facility. 7 JDFs insurance carrier also conducts independent audits on an annual basis. Five-Year Accident History Over the last five years, JDF has not experienced an accidental off-site release of anhydrous ammonia from the ammonia refrigeration system causing any on-site death, injury or significant property damage, or known off-site death, injury property damage, environmental damage, evacuations or sheltering in place. Emergency Response Program JDF has developed a comprehensive emergency response program designed to protect both employees and the community in the event of a release. This program is fully described in a document entitled Emergency Planning & Response Action Plan (EPRA Plan) in order to facilitate response efforts in the event of an off-site anhydrous ammonia release. Incl uded in the EPRA Plan are measures to be taken internally by JDF as well as measures to be taken by off-site response agencies. JDF has trained approximately 13 on-site personnel to respond to accidental ammonia releases. These personnel are trained in accordance with 29 CFR 1910.120, OSHAs Hazardous Operations and Emergency Response regulations according to their duties and function. These personnel receive initial training and annual update training thereafter. To assure that the local governmental response agencies are familiar with JDFs emergency response procedures, JDF will provide copies of the EPRA Plan and future major revisions for review and approval by the local agencies. The following local agencies are included for EPRA Plan review and approval: 7 Newbern Fire Department 7 Newbern Police Department 7 Dyer County Emergency Planning Committee To plan for an ammonia release with off-site effects, JDFs EPRA Plan includes procedures/equipment to mitigate the release, procedures to inform local response agencies, transportation maps for response agencies, evacuation route maps, and procedures for public communication. In the event of an anhydrous ammonia release with off-site effects, the general public will be warned using one or more of the following methods: 7 Police and fire vehicles equipped with public address systems |