Capitol Wholesale Meats - Executive Summary

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1. Accidental Release Prevention and Emergency Response Policies  
 
We at Capitol Wholesale Meats are strongly committed to employee, public and environmental safety.  This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility.  It is our policy to implement appropriate controls to prevent possible releases of regulated substances.  Unforeseeably, if such a release does occur, we are completely coordinated with emergency responders to provide highly trained emergency response personnel to control and mitigate the effects of the release. 
 
2.  The Stationary Source and the Regulated Substances Handled 
 
We have the following regulated substance present at our facility. 
 
         Substance:  Anhydrous Ammonia 
         Maximum Inventory:  15,500 pounds  
         Exceeds 40 CFR Part 68 Threshold:  Yes 
 

.  The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario. To perform the required offsite consequence analysis for our facility, we have used material provided by the EPA in the RMP Guidance for Waste Water Treatment Plants.  The following paragraphs provide details of the chosen scenarios. 
 
The worst case release scenario submitted for ammonia involves a catastrophic release from the largest vessel connected to the refrigeration process.  The scenario involves the release of 4100 pounds of ammonia in a gaseous form over 10 minutes.  Under worst case weather conditions, namely Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 0.8 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. 
 
One alternative release scenario has been submitted for ammonia as well.  This alternative release scenario involves a release from a valv 
e used in the process.  The scenario involves the release of 2,400 pounds of ammonia in a gaseous form over 1 minute.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L is 0.3 miles. 
 
4.  The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
 
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under both 40 CFR part 68 of the EPA and the OSHA PSM standard under 29 CFR 1910.119.  The following sections briefly describe the elements of our prevention program that are in place at our facility. 
 
Process Safety Information 
The facility maintains a detailed record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. 
 
Process Hazard Analysis 
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlle 
d efficiently.  The methodology used to carry out these analyses follow the HAZOP.  The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of every five years, or more frequestly if necessary.  Any findings related to each analysis are addressed in a timely manner. 
 
Operating Procedures 
For the purposes of safely conducting activities related to the covered process, the facility maintains written operating procedures.  These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround.  The information is regularly reviewed and is readily accessible to operators involved with the process. 
 
Training 
The facility has a comprehensive training program in place to ensure that employees that are operating the process are completely competent in the operati 
ng procedures associated with the process.  New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently.  Refresher training is provided annually and more frequently as needed. 
 
Mechanical Integrity 
The facility carries out highly documented maintenance checks on process equipment to ensure proper functions.  Process equipment examined by these checks includes among others; storage tanks, piping systems, relief and vent systems, controls and pumps.  Maintenance operations are carried out by qualified personnel with previous training in maintenance practices.  Furthermore, these personnel are offered specialized training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
 
Management of Change 
Written procedures are in place at the facility to manage changes in process chemicals, technology, equipment and procedures.  Process operator 
s, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. 
 
Pre-startup Reviews 
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at the facility.  These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. 
 
Compliance Audits 
The facility conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented.  These audits are carried out at least every three years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. 
 
Incident Investigation 
The facility promptly investigates any incident that has resulted in, or could reasonably result in a catastroph 
ic release of a regulated substance.  These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring.  All reports are retained for a minimum of five years. 
 
Employee Participation 
The facility truly believes that process safety management and accident prevention is a team effort.  Employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements.  In addition, our employees have access to all information created as part of the facility's implementation to both the PSM standard and RMP rule. 
 
Contractors 
On occasion, the facility hires contractors to conduct specialized maintenance and construction activities.  Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out.  The facility has a strict policy of informing the contractors of known potential hazards related to the contracto 
r's work and the processes.  Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 
 
5.  Five-year Accident History 
 
The facility has had an excellent record of preventing accidental releases over the last five years.  Due to our stringent release prevention policies, no accidental releases have occurred during this period. 
 
6.  Emergency Response Plan 
 
The facility carries a written emergency action plan to deal with accidental releases of hazardous materials.  The plan includes aspects of emergency response including adequate first aid and medical treatment, evacuations, and notification of local emergency response agencies and the public.
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