Pierre Foods, Inc. - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICY It is the policy of Pierre Foods, Inc. to conduct business in a manner that is safe to the employees, the community and the environment. The Company's officers, managers and supervisors are accountable to carry out the policies of the Company relevant to the prevention of accidental releases of hazardous materials. Pierre Foods has made a determined effort to develop a plan to prevent releases of extremely hazardous substances. Procedures to assist in the prevention of extremely hazardous material releases are set forth in EPA's Risk Management Program. In the event of a release, the Emergency Response Plan will be the guidance for responding to, containing and reporting such releases. The Response Plan includes an incident command system for decision-making authority for each stage of a release situation. The Company will coordinate with public responders and emergency services in ensuring safety of the public. FACILI TY DESCRIPTION AND THE REGULATED SUBSTANCES Pierre Foods, Inc. processes portion controlled frozen meats and poultry products. Raw meats are brought into the facility, portioned, cooked and frozen. To prevent contamination with harmful bacteria and to freeze the final product, ammonia is used. Ammonia is used as a refrigerant to maintain cool to freezing temperatures in the various stages of the process. The refrigeration system is a closed loop system, meaning the ammonia is continually reused. RELEASE SCENARIOS Pierre Foods, Inc. has developed models of the releases at this facility and the potential affected areas. A commercial computer model, Phast Professional, was used to develop the models. The worst-case release of ammonia involves the sudden failure of a Recirculator when used as a storage vessel which has the capacity to hold 60,500 pounds of ammonia. Depending on wind direction, residences, schools, hospitals and businesses at a distance of 2.51 miles could be affec ted. Approximately 23,000 people live within a 2.7 mile radius of the facility. This type release is not likely to occur because of the stringent construction codes for pressure vessels and annual inspections of the pressure vessels. The alternative release of ammonia involves the failure of a 3/4 inch line on the Recirculator releasing 25,000 pounds of liquid ammonia over a 60 minute period. Residences up to .28 mile from the release would be affected. This release was selected because appurtenances are more likely to be broken. Protective devices are put in place to protect lines from traffic and accidental breaking. RELEASE PREVENTION PROGRAM Pierre Foods, Inc. has set forth in its policies the importance of operating safely. The Company has aggressively developed programs, policies and materials requirements to minimize the possibility of releases. These programs include compliance with appropriate OSHA and EPA regulations and sound safety practices. Stringent material a nd contractor requirements have been developed to assure that materials and work conform to recognized standards. Training for employees is conducted to maintain a high level awareness when working with hazardous materials. As part of the Prevention Program, Pierre Foods has developed a method to evaluate the Risk Management Program. This method includes periodic evaluation of the Program utilizing a Process Hazard Analysis, and Compliance Audits. The Process Hazard Analysis has identified deficiencies in the Standard Operating Procedures (SOP) currently in use at the facility. Plans are in place for an outside consultant to assist in the upgrading of the refrigeration SOP. FIVE YEAR ACCIDENT HISTORY Pierre Foods, Inc. has an accidental release as defined in 40 CFR 68.42(a) during the last five years. EMERGENCY RESPONSE PLAN On-site emergency response teams train to respond to releases to effectively minimize the release. Joint response training is conducted with local emerge ncy service organizations (i.e. fire, police, rescue, etc.) Drills are conducted periodically for on-site response teams and annually with outside organizations. SAFETY IMPROVEMENTS Future changes to improve release prevention include: improved maintenance procedures and periodicity; addition of new technology as it becomes available; and continued training of plant and response personnel. |