Butterball Turkey Company - Executive Summary |
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EXECUTIVE SUMMARY 1.0 RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Butterball Turkey Company (Butterball) facility in Carthage, Missouri has a good record in preventing releases of anhydrous* ammonia. As part of their release prevention program, the plant has an excellent and 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 which is to ensure the safety of its employees'. 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. The Emergency Action Plan is a thorough and comprehensive plan for release prevention and emergency response. The emergency response policies at the Butterball facility ensure that there is emergency response coverage 24 hours - 7 days per we ek. *From this point in the Executive Summary, anhydrous ammonia will be synonymous with ammonia. 2.0 PROCESS DESCRIPTION AND REGULATED SUBSTANCES The Butterball Carthage Plant kills, eviscerates, debones, and cooks whole turkeys. The NAICS code for the processes at this facility is 311615. Many areas of the plant are refrigerated to preserve the poultry products. Butterball 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 has not been officially calculated. The current estimate based on purchases is 52,000 pounds. The process uses more than 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 refri geration 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 are 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 ski n 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 Carthage plant. The largest potential release of ammonia would occur with a 1 1/4 inch diameter puncture in the liquid portion of a high pressure receiver. Another high pressure receiver is interconnected and therefore, if there were a puncture in one tank, the contents of both receivers would be released. These high pressure receivers have been used in pump down conditions previously. The total quantity of ammonia that can be stored in the two high pressure receivers and interconnecting piping is 12,893 pounds. Administrative and passive controls are not applicable to this scenario. It is assumed that the entire 12,893 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 a high pressure liquid line on the roof. The release scenario is construction activity on the roof which results in creasing the line, creating a split in the pipe wall. The split is assumed to be equivalent to a = inch orifice, and is located 25 feet above ground l evel. 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 Butterball has developed an OSHA (PSM) program for their ammonia refrigeration system. At Butterball, 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, Butterball'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: The Carthage 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 generated by the CMMS. This system ensures that each operator/mechanic is aware of the pertinent procedure. The operator/mechanic and their supervisor sign off the completed work 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 Butterball's accident history includes the following range of dates: June 21, 1994 - June 21, 1999. According to 40 CFR Part 68.42(a), there has been one accidental release at this facility. 6.0 EMERGENCY RESPONSE PROGRAM As mentioned previously, the Butterball facility has developed an OSHA hazardous substance emergency response program called Emergency Action Plan (EAP). Butterball's EAP is a detailed document which discusses the role of employees and management in an emergency situation. The plan outlines specific procedures for evacuations for plant personnel. All emergency response personnel (HAZMAT Team) undergo emergency response training. For all emergencies, the plan activates the Incident Command Team and the HAZMAT Team. These teams are responsible for implementing the EAP and controlling all aspects of the plan and personnel. This document contains specific procedures for: 1) emergency notification procedures, evacuation instructions, personnel accounting procedures as well as notification of r esponse groups; 2) emergency medical treatment; 3) HAZMAT-chemical spills and releases (includes roles and lines of authority, emergency recognition and prevention, safe distances and places of refuge, site security and control, medical/first-aid, decontamination, personal protective equipment, and emergency equipment); and 4) critique of response and follow up. 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 upgraded the engine room ventilation and has engine room ammonia detectors. An additional ongoing project is the installation of catwalks, ladders and crossover for improved access to refrigeration components on the roof. The plant has also replaced some corroded piping and is completing pipe labe ling and valve tagging in accordance with IIAR requirements. |