Armour Swift-Eckrich Deli Foodservice - Executive Summary

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EXECUTIVE SUMMARY 
 
1.0    RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 
 
The Armour Swift-Eckrich facility in Jonesboro, Arkansas has a good record in preventing releases of anhydrous* ammonia.  As part of their release prevention program, the plant is implementing a 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 a Emergency Action Plan which is to provide information and guidance to safely deal with an ammonia release.  This emergency response program includes procedures for handling an emergency - the established response plan and appropriate personnel involved in containing an ammonia release - First Response Team. The emergency response policies 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 amm 
onia. 
 
2.0    PROCESS DESCRIPTION AND REGULATED SUBSTANCES 
 
The Armour Swift-Eckrich Jonesboro Plant produces deli meat products for deli and foodservice distribution. The NAICS code for the processes at this facility is 311615.   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 42,000 pounds.  The process exceeds the threshold quantity of 10,000 pounds as set by 40 CFR 68 and thus is regulated by the Risk Management Program. 
 
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 Jonesboro plant.  The largest potential release of ammonia would occur with a 1 3/4 inch diameter puncture in the liquid portion of the thermosyphon receiver.  Taking the specific definition of the worst-case from 40 CFR 68.25, the vessel that can store the largest quantity of ammonia is the 11 degree accumulator.  However, the thermosyphon receiver would be used as the primary liquid storage vessel during pumpout conditions.  The 11 degree accumulator would only be used to accommodate excess liquid from the thermosyphon receiver.  The total quantity of ammonia that can be stored in the thermosyphon receiver is 29,245 pounds.  Therefore, the worst 
-case release quantity will be 29,245 pounds.  Administrative and passive controls are not applicable to this scenario.  It is assumed that the entire 29,245 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. 
 
The worst-case release scenario distance-to-endpoint will reach off-site receptors. 
 
3.2    Alternative Release Scenario Description 
        
The alternative release scenario is an ammonia release from the HTRL line on the roof. The release scenario considers a contractor dropping an object causing the HTRL line to crack. The opening in the damaged pipe is assumed be equivalent to a = diameter orifice, an 
d is located 44 feet above ground level.  Administrative and passive controls are not applicable to this scenario.  Active mitigation of the release is human intervention.     
 
The alternative release scenario distance-to-endpoint will reach off-site receptors.     
 
4.0    GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS 
 
Armour Swift-Eckrich has developed an OSHA Process Safety Management (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' ammonia PSM system has been reviewed and the PSM system elements are being implemented for the RMP.   
 
Listed below are the key aspects of the ammonia prevention program: 
 
The ventilation in the engine room is adequate for both constant and emergency requireme 
nts.  Safety equipment includes ammonia detectors in both the engine room and the main plant.  Additionally, the plant has installed an emergency shutdown system with switches outside the engine room.  All ammonia piping and control groups are installed on the roof with minimal piping running to the evaporators installed in the plant.  The ammonia system is PLC controlled with remote PC based monitoring. 
 
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 a Emergency Action Plan. The response plan discusses the role of employees in an emergency situation. The plan outlines specific procedures for evacuations for plant personnel. All emergency response personnel (First Response Team) unde 
rgo emergency response training.  For all emergencies, the emergency protocols are described in the Emergency Action Plan. The incident commander will initiate the hazardous materials emergency response and direct all response activities from the initiation of the response through to conclusion, including cleanup and debriefing.  This team is responsible for implementing the response plan and controlling all aspects of the plan and personnel.  The Emergency Action Plan also has very specific procedures for responding to an ammonia release. 
 
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 below: 
 
The plant has been diligently working to implement their preventative maintenance program.  Several hazards identified by the PHA will be remove 
d once the equipment inspections are placed on the plants computerized maintenance system.
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