Seaboard Farms of Guymon, OK - Executive Summary |
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A. Accidental Release Prevention and Emergency Response Policies Seaboard Farms recognizes management's responsibility in protecting its employees, equipment, property, and the environment. The safety and health of all personnel are very important. The control of accidents has been and will continue to be a basic responsibility of all personnel at the Guymon facility. To accomplish the company's goal in controlling accidental losses, the facility has a Plant Safety Program in place. The objectives of the Plant Safety Program are to: maximize efficiency and safety performance, reduce losses associated with damage of property, eliminate human suffering and the economic burden resulting from injuries and accidents. One of the activities associated with the Plant Safety Program has been the development and implementation of accidental release prevention and emergency response programs which are designed to comply with OSHA's Process Safety Management (PSM) standard (Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119), and EPA's Risk Management Program (RM program) regulation (Risk Management Programs for Chemical Accidental Release Prevention, 40 CFR Part 68). Mr. Dennis Estenson, Refrigeration General, is responsible for implementation of the Risk Management Program. The purpose of the accidental release prevention and emergency response programs is 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. The accidental release prevention and emergency response programs help 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 a ccepted by all employees at the facility. B. Stationary Source and Regulated Substances Handled Seaboard Farms Inc. operates a pork facility in Guymon, OK. The facility operates two ammonia refrigeration systems (i.e the main refrigeration system and the auxiliary freezer system) to provide cooling and freezing capabilities. The amount of anhydrous ammonia (CAS #7662-41-7) contained in these systems is above the EPA threshold of 10,000 pounds. The maximum amount of ammonia in the main refrigeration system and the auxiliary freezer system is 167,000 and 35,000 pounds, respectively. Since ammonia releases from these systems could pose a risk of offsite public impact and they are regulated under the OSHA PSM standard (29 CFR 1910.119), the systems are subject to the Program 3 requirements of the EPA's RM program. C. Summary of Worst-Case and Alternative Release Scenarios Main Refrigeration System The worst-case release scenario for the main refrigeration system at the Guy mon facility involves the release of 84,627 pounds of ammonia over a 10 minute period due to the failure of the Low Pressure Accumulator. This quantity represents the full capacity of the vessel, which is a conservative assumption as the liquid level within the accumulator is normally within the 20-30% range. Under worst-case weather conditions, ammonia could travel 5.23 miles before dispersing enough to no longer pose a hazard to the public. This distance is calculated based on the method provided in the Risk Management Program (40 CFR 68) Guidance for Ammonia Refrigeration. The worst-case release scenario related to the main refrigeration system is unlikely for the following reasons: The worst-case weather conditions which were used for this scenario are not typical; The Low Pressure Accumulator is located on a pad in an area with minimal traffic (e.g., forklifts); Industry standards have been followed for the manufacture and quality control of the accumulator; Ammo nia is not corrosive in this service and the vessel is relatively new; Pressure safety valves limit operating pressure in the accumulator; The facility has a preventive maintenance program in place to maintain the on-going integrity of vessels; The facility has a training program designed to ensure that the system is operated by qualified personnel; and, The facility emergency response procedures enable trained personnel to respond quickly to isolate any potential releases. The alternative release scenario considered for the main plant refrigeration system involves the release of 20,485 pounds of ammonia over a 10 minute period due the development of a 1"-diameter leak on a high pressure liquid pipe used for cooling the compressors. Under alternative release weather conditions, ammonia could travel 0.81 miles before dispersing enough to no longer pose a hazard to the public. This distance is calculated based on the method provided in the Risk Management Program Guidanc e for Ammonia Refrigeration. The alternative release scenario for the main refrigeration system is unlikely for the following reasons: Industry standards have been followed for the manufacture and quality control of these lines; Ammonia is not corrosive to the equipment in this service; Most of the lines are elevated to minimize potential damage from fork lifts; The facility has a preventive maintenance program in place to maintain the on-going integrity of the system; The facility has a training program designed to ensure that the system is operated by qualified personnel; and, The facility emergency response procedures enable trained personnel to respond quickly to isolate any potential releases by closing isolation valves in the liquid lines. Auxiliary Freezer System The worst-case release scenario for the auxiliary freezer system at the Guymon facility involves the release of 19,095 pounds of ammonia over a 10 minute period due to the failure of the High Pres sure Receiver. This quantity represents the full capacity of the vessel, which is a conservative assumption as the liquid level within the accumulator is normally within the 20-30% range. Under worst-case weather conditions, ammonia could travel 2.53 miles before dispersing enough to no longer pose a hazard to the public. This distance is calculated based on the method provided in the Risk Management Program Guidance for Ammonia Refrigeration. The worst-case release scenario related to the auxiliary freezer system is unlikely for the following reasons: The worst-case weather conditions which were used for this scenario are not typical; The High Pressure Receiver is located on a pad in an area with minimal traffic (e.g., forklifts, trucks etc.); Industry standards were followed for the manufacture and quality control of the receiver; Ammonia is not corrosive to equipment in this service and the vessel is relatively new; Pressure safety valves limit operating pressure in the receiver; The facility has a preventive maintenance program in place to maintain the on-going integrity of vessels; The facility has a training program designed to ensure that the system is operated by qualified personnel; and, The facility emergency response procedures enable trained personnel to respond quickly to isolate any potential releases. The alternative release scenario for the auxiliary freezer system involves the release of 8,070 pounds of ammonia over a 30 minute period due to a 1/2"-diameter seal leak on the pump associated with the High Suction Accumulator. Under alternative release weather conditions, ammonia could travel 0.30 miles before dispersing enough to no longer pose a hazard to the public. This distance is calculated based on the method provided in the Risk Management Program Guidance for Ammonia Refrigeration. The alternative release scenario is unlikely for the following reasons: Industry standards have been followed for the manufactu re and quality control of the pumps; Ammonia is not corrosive in this service and the pumps are relatively new; The facility has a preventive maintenance program in place to maintain the on-going integrity of the system, including inspection and maintenance on the pumps; The facility has a training program designed to ensure that the system is operated by qualified personnel; and, The facility emergency response procedures enable trained personnel to respond quickly to isolate any potential releases. There have been no ammonia-related incidents from the auxiliary freezer system within the last five years that have resulted in any onsite or offsite impacts. D. Description of the Accidental Release Prevention Program The prevention program consists of the following elements: Employee Participation: This program involves the employees in establishing and implementing the program. Employees are also to be involved when a process hazard analysis is conducted. The p rogram also ensures that all employees have complete access to the program. Process Safety Information: Written information has been collected which enables the employees to identify and understand the potential hazards in the system. The written information includes the ammonia MSDS and a description of the design of the ammonia refrigeration system. Process Hazard Analysis: Formal studies using the What-If Technique have been conducted to look at the system and identify potential hazards. Operating Procedures: Written, detailed procedures have been developed which describe the steps which should be followed to safely operate the ammonia refrigeration system. Training: A training program has been developed which ensures that employees are trained on all aspects of the system and on the duties which they should perform to ensure the safe operation of the ammonia refrigeration system. Contractors: All contractors are screened and evaluated before they perform work o n or near the ammonia refrigeration system. The contractors are also periodically evaluated to ensure that they perform work by following safe work practices. Pre-Startup Safety Review: A pre-startup safety review is completed for all new ammonia projects to verify that all safety programs are in place, training has been performed, and construction has been completed according to design standards before the project is put into use. Mechanical Integrity: This program ensures that the ammonia refrigeration systems are built and maintained using preventive maintenance procedures to minimize unexpected breakdowns or failures. Hot Work Permit: These procedures ensure that a signed permit is obtained prior to any cutting, welding, or burning. Management of Change: The procedures are designed to ensure that all changes made to the ammonia refrigeration system are properly reviewed. Incident Investigation: The procedures ensure that any incidents (and near misses) are inv estigated, reviewed, and documented using an investigation team. Compliance Audits: There are procedures to conduct regular audits of the RM program to ensure that the program is in place and working properly. E. Five-Year Accident History One ammonia-related incident was identified for the main refrigeration system in the previous five years. On July 13, 1996 approximately 200 pounds of ammonia vapor was released to the atmosphere due to the development of a crack on a low-stage suction line. The release was estimated to occur over a 90 minute period. The incident did not result in any onsite injuries, property damage or offsite impacts. There have been no ammonia-related incidents identified for the auxiliary freezer system within the last five years that have resulted in any onsite or offsite impacts. F. Description of the Emergency Response Program An emergency response program has been implemented at the Guymon facility. This program contains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures. The program has been coordinated with the Guymon Fire Department. The emergency response program consists of the following elements: Organization Plan and Responsibilities Communications Procedures Detailed Action Plans First Aid Procedures Emergency Medical Treatment Procedures Evacuation Plans Description of Outside Assistance Available Site Re-Entry Procedures Training Programs and Drills G. Planned Changes to Improve Safety The following changes are planned to improve safety conditions and further strengthen the ongoing safety efforts at the Seaboard Farms facility: Addition of sound and air insulating seals on the control room door Initiation of a preventive maintenance (PM) program for the pumpout compressor Addition of wind socks to indicate the wind direction Placement of guard rails along the perimeter of the ammonia accumulators Addition of eye wash and shower station inside the auxiliary freezer system engine room Provision of an alternate rear door to the auxiliary freezer engine room |