Armour Swift-Eckrich - Executive Summary |
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EXECUTIVE SUMMARY 1.0 RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Armour Swift-Eckrich Brown-N-Serve (BNS) facility in St. Charles, Illinois has a good record in preventing releases of anhydrous* ammonia. As part of their release prevention program, the plant has an excellent and very detailed preventative maintenance program. More information about these aspects of the prevention program is discussed in Section 4.0 of this Executive Summary. The facility has implemented an Emergency Action Plan and a HAZMAT Response Plan which provide information to safely deal with an ammonia release. This detailed emergency response program includes procedures for handling an emergency - the established response plan and appropriate personnel involved in containing an ammonia release - HAZMAT Team. The Emergency Action Plan coupled with the HAZMAT Response program constitute a thorough and comprehensive plan for release prevention and emergency response. The emergency response poli cies at the Armour Swift-Eckrich facility ensure that there is emergency response coverage 24 hours - 7 days per week. *From this point in the Executive Summary, anhydrous ammonia will be synonymous with ammonia. 2.0 PROCESS DESCRIPTION AND REGULATED SUBSTANCES The Armour Swift-Eckrich St. Charles BNS Plant produces pre-browned breakfast sausage. The NAICS code for the processes at this facility is 311612. Many areas of the plant are refrigerated to preserve the meat products. Armour Swift-Eckrich has one regulated substance under 40 CFR 68: ammonia. Ammonia is used as a refrigerant in the refrigeration of the products in the various areas of the plant. The ammonia threshold for triggering applicability to 40 CFR 68 is 10,000 pounds. The total quantity of ammonia stored in the refrigeration process is documented as approximately 8,745 pounds. The process does not exceed the threshold quantity of 10,000 pounds as set by 40 CFR 68. As part of a "good-faith" effort however Armou r Swift-Eckrich has developed a Risk Management Program. This program meets and exceeds the requirements of Section 112 (r) (1) "General Duty Clause". 3.0 WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS The ammonia refrigeration system has associated hazards that can potentially affect on-site employees and the general public off-site if there is a release from the system. Described below are the associated hazards and the worst-case and alternative release scenario for the regulated chemical. Though there may be other scenarios possible, EPA only requires that one worst-case and one alternative scenario be reported for each regulated chemical. Ammonia is classified as a Group 2 Refrigerant per ASHRAE Standard 34-1989. The dominant characteristic of this chemical is its toxicity. It is a self-alarming chemical by its distinctive pungent odor. Due to this odor, persons exposed to ammonia vapor will not voluntarily stay in areas of even small concentrations. Ammonia will burn at a very narrow and high range of concentrations accompanied with a high ignition temperature. Although ammonia is not poisonous, it is corrosive to human tissue. Ammonia is readily absorbed into the moisture of the skin and, at high concentrations, can cause severe burns. The risks to persons in an accidental release of ammonia include: 1. Corrosive attack of skin and other tissue (including lung tissue) 2. Freezing of skin and other body tissue when contacted by liquid ammonia 3. Eye contact Below is a description of the release scenarios for ammonia and their off-site consequences: 3.1 Worst-Case Scenario Description One worst-case scenario has been developed for the St. Charles BNS Plant. The largest potential release of ammonia would occur with a 7/8 inch diameter puncture in the liquid portion of the High Pressure Receiver. Taking the specific definition of the worst-case from 40 CFR 68.25, this is the vessel that can store the largest quantity of ammonia. The total quan tity of ammonia that can be stored in the High Pressure Receiver is 7,056 pounds. Therefore, the worst-case release quantity will be 7,056 pounds. Administrative and passive controls are not applicable to this scenario. It is assumed that the entire 7,056 pounds is released to the atmosphere in 10 minutes. For the worst-case release, regulations dictate that the release height is at ground level. Under Section 68.25(c)(1), a regulated toxic substance such as ammonia that is normally a gas at ambient temperature and handled as a liquid under pressure shall be considered to be released as a gas over a 10 minute period. Thus, ammonia's physical state in the worst-case scenario is a gas. Since this facility is located in a populated area, the worst-case release scenario distance-to-endpoint will reach off-site public receptors. 3.2 Alternative Release Scenario Description The alternative release scenario is an ammonia release from a high pressure liquid line on the high pressu re receiver. In the release scenario the pipe is damaged creating an opening which is equivalent to a 3/16 diameter orifice, and is located 8 feet above ground level. Administrative and passive controls are not applicable to this scenario. Active mitigation of the release is human intervention. Since this facility is located in a populated area, the alternative release scenario distance-to-endpoint will reach off-site public receptors. 4.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Armour Swift-Eckrich has developed an OSHA (PSM) program for their ammonia refrigeration system. At Armour Swift-Eckrich, ammonia falls under the RMP Program 3 Prevention Program which is identical to the OSHA PSM program. EPA has said that if the process is in compliance with OSHA PSM, then it is compliance with RMP Program 3. Thus, Armour Swift-Eckrich's ammonia PSM system has been reviewed and the PSM system elements are being implemented for the RMP d ocument. Listed below are the key aspects of the ammonia prevention program: The BNS plant uses a Computerized Maintenance Management System (CMMS) for control scheduling and accomplishment of preventative maintenance on components of the refrigeration system. The scope of preventative maintenance (PM) and testing/inspection (T/I) for refrigeration components is based on individual vendor recommendations and generally accepted engineering practices with regard to types of preventative maintenance and inspections and their recommended frequencies. Individual work tasks are used for each type of PM and T/I associated with the refrigeration system. These tasks are included on the individual work order generated by the CMMS. This system ensures that each operator/mechanic is aware of the pertinent safety precautions required for a PM procedure as well as the step-by-step actions required to complete the procedure. The operator/mechanic and their supervisor sign off the completed w ork order. Specific results of each PM and T/I procedure are recorded on the work order. In the event a PM or T/I procedure is not completed satisfactorily, the operator/mechanic notes it on the work order, and a follow-up work order is generated to address the specific deficiency. 5.0 FIVE-YEAR ACCIDENT HISTORY The review of Armour Swift-Eckrich's accident history includes the following range of dates: June 21, 1994 - June 21, 1999. According to 40 CFR Part 68.42(a), there have been no accidental releases at this facility. 6.0 EMERGENCY RESPONSE PROGRAM As mentioned previously, the Armour Swift-Eckrich facility has developed an Emergency Action Plan and a HAZMAT Response Plan. The emergency plans are detailed documents which discuss the role of employees in an emergency situation. The plans also outline specific procedures for evacuations for plant personnel. The Emergency Action Plan contains specific information regarding: emergency phone numbers, emergency information spo kesperson, organizational list, evacuation plan procedures, emergency evacuation instructions, personnel accounting procedures, personnel confirmation, notification of response groups, emergency shutdown, preventative maintenance, critique of evacuations, and spill prevention control and countermeasures. The HAZMAT Response Plan contains specific information regarding: standard operating procedures, roles/responsibilities and lines of authority, coordination with local authorities, emergency recognition and prevention, decontamination, entry team procedures, tests for alarm system, training, site security and control, medical and first aid, personal protective equipment, and debriefing. 7.0 PLANNED CHANGES TO IMPROVE SAFETY Based on the completed Process Hazard Analysis (PHA) for ammonia, a list of action items to improve safety was developed and their status monitored to ensure that implementation was accomplished. An example of safety improvements made at the plant is discussed b elow: The plant has completed several projects that have improved the safety and efficiency of their ammonia refrigeration system. They have installed an ammonia detection system, an upgraded ventilation system, spring loaded oil drain valves and steel shielded coils on solenoid valves. Additionally, the plant is in the process of installing an emergency shut-down system for the ammonia equipment. The shut-down system is scheduled to be operational in July, 1999. The plant also has a long term project to install new insulation in the engine room during Fiscal Year 2000. |