Armour Swift-Eckrich - Executive Summary |
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EXECUTIVE SUMMARY 1.0 RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Armour Swift-Eckrich facility in Mason City, Iowa has a good record in preventing releases of anhydrous* ammonia. As part of their release prevention program, the plant has an excellent operator training program, and has a 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 Preparedness Program which is to ensure the safety of its employees', the community, and the environment. This detailed emergency response program includes procedures for handling an emergency - the established action plan and appropriate personnel involved in containing an ammonia release - HAZMAT Team. As part of this program, there is emergency response training and medical surveillance of the HAZMAT team prior to and after an incident. All of these components make the Emergen cy Preparedness Program a thorough and comprehensive plan for release prevention and emergency response. 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 ammonia. 2.0 PROCESS DESCRIPTION AND REGULATED SUBSTANCES Armour Swift-Eckrich is a producer of smoked meats. 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 approximately 42,099 pounds. The process exceeds the threshold quantity of 10,0 00 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 h igh 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 Mason City plant. The largest potential release of ammonia would occur with a two and seven eighths inch diameter puncture in the liquid portion of the high back accumulator. 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 high back accumulator. The total quantity of ammonia that can be stored in the high back accumulator is 24,664 pounds. Administrative and passive controls are not applicable to this scenario. It is assumed that the entire 24,664 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 evaporative condenser return piping below EC4. The release scenario considers a truck backing into the evaporative condenser return piping. The pipe is assumed to be damaged on the bottom half, and r esults in a liquid release at system pressure. The opening in the damaged pipe is assumed to have a diameter of one-half inch, and is located ten 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's 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: 1.) The training program incorporates an informal apprenticeship system with on-the-job training at the University of Wisconsin. Documentation of this training includes the date of achieved proficiency and by whom the proficiency was judged. This documentation is maintained in the individual operator's file. 2.) The 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. The plant has created work tasks for each type of PM and T/I associated with the refrigeration system. These tasks are included on the individual work order genera ted 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 work order is signed off by both the operator/mechanic and their supervisor. Specific results of each PM and T/I procedure are not recorded on the work order. In the event a PM or T/I procedure is not completely satisfactory, a follow-on 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 OSHA hazardous substance emergency response program called Emergency Preparedness Program. This document was developed in ac cordance with 29 CFR 1910.38 and 29 CFR 1910.120(q). It is divided into two primary sections: HAZMAT Program and Emergency Action Plan. The HAZMAT Program describes procedures for the response to an ammonia release. This section contains specific procedures for: 1.) Hazardous Material Response; 2.) Roles and Lines of Authority; 3.) Emergency Recognition and Prevention; 4.) Safe Distances and Places of Refuge; 5.) Site Security and Control; 6.) Medical First Aid; 7.) Decontamination; 8.) Personal Protective Equipment; and 9.) Critique of Emergency Action Plan and Follow-up. The Emergency Action Plan consists of all notifications and plant evacuation procedures in the event of an ammonia release. The Emergency Command Team flow chart is located in this section and gives a quick reference to emergency responders in the event of a release. The Emergency Team Coordinator has ultimate control of implementation of the emergency response plan. 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 recently taken steps to ensure the refrigeration system is operating safely and complies with the requirements of PSM. These steps include installation of an ammonia detection system. Ammonia detectors are installed in the engine room, which are tied into the operation of the engine room exhaust system. Additionally, emergency shutoff switches are being installed outside each entrance to the engine room. |