Cutler Egg Products, Inc. - Executive Summary
1.0 Accidental release prevention and emergency response policies at Cutler Egg Products, Inc. - Abbeville, AL ('68.155(a) ). |
Cutler Egg Products, Inc. prevents accidental ammonia releases through on the job training of refrigeration / maintenance personnel and ongoing inspection and maintenance of the refrigeration system. A PSM program has been developed to further reduce the likelihood or severity of an accidental release. Refrigeration system components are located in areas that are not as likely to become damaged (i.e., tanks placed away and protected from forklift and truck traffic). The facility has a written Emergency Action Plan and key personnel receive OSHA HAZWOPER training.
2.0 Source and regulated substances handled ('68.155(b)).
Approximately 24,000 lbs. of anhydrous ammonia is contained within the refrigeration system on site at Cutler Egg Products, Inc., Abbeville, AL. The EPA requires a Risk Management Plan be developed and maintained when the total amount of
anhydrous ammonia exceeds the threshold quantity of 10,000 lbs. No other substances, in quantities subject to EPA RMP certification requirements, are located at the Cutler Egg Products, Inc., Abbeville, Alabama facility.
3.0 Ammonia Worst Case and Alternate Case Release Scenarios ('68.155(c)).
3.1 Worst Case Scenario (WCS)
The high-pressure receiver, located outside adjacent to the compressor pad, contains the largest total quantity of anhydrous ammonia, on site, on a predictable worst case basis. This vessel is typically maintained at less than 60% full. However, during some shutdown operations, this vessel is used for pumping down the system. During these operations, this vessel could be filled to approximately 90% capacity or 5,920 pounds of anhydrous ammonia, under an internal pressure and temperature of approximately 114 psig and 70 0F. The Worst Case Scenario as required by EPA, assumes that the tank's contents are fully released as a gas/vapor over a 10-minute per
The EPA RMP Ammonia Guidance Document Endpoint Tables predicted, with a wind speed of 1.5 m/s (3 mph) and atmospheric stability class F, the anhydrous ammonia release may travel 1.4 miles from the point of release (See Section 8 and Appendix C). Approximately 183 people, as determined by Landview Census data, in the surrounding community, reside within the radius to the toxic endpoint (level of concern = 200 ppm, anhydrous ammonia). There are residences and one recreation complex, as reportable by EPA RMP criteria, which lie within the radius to the toxic endpoint. There are no environmental receptors, as reportable by EPA RMP criteria, within the radius to the toxic endpoint.
3.2 Alternate Case Scenario (ACS)
The Alternate (more realistic) Case Release Scenario for the Cutler Egg Products, Inc., Abbeville, AL facility was selected to involve a 3/4 inch relief valve lifting at 250 psig. Anhydrous ammonia (at approximately 250 psi and 113 0F) was estimated to have a flow rat
e of approximately 92 lbs./min., determined from the EPA alternate case ammonia release table. It is estimated that the relief valve could be isolated, or the overpressure condition corrected, in approximately 10 minutes by trained operators on site, with a corresponding anhydrous ammonia quantity released of approximately 920 lbs.
The EPA RMP Ammonia Guidance Document Endpoint Tables predicted, with a wind speed of 3 m/s (6 mph) and atmospheric stability class D, that the anhydrous ammonia release may travel approximately 0.2 miles. There are 13 people, as determined by Landview Census data, within the radius to the toxic endpoint (level of concern = 200 ppm, anhydrous ammonia). There are no other public or environmental receptors, as reportable by EPA RMP criteria, within the radius to the toxic endpoint.
4.0 Accidental release prevention program ('68.155(d)).
The Cutler Egg Products, Inc., Abbeville, AL facility standard policy requires daily monitoring and inspection of the
anhydrous ammonia refrigeration system by trained employees. An OSHA Process Safety Management (PSM) program has been developed for this facility. Additional accidental ammonia release prevention practices at the Cutler Egg Products, Inc., Abbeville, Alabama facility include:
7 Safe work practices followed.
7 Refrigeration system repairs made in a prompt, safe manner.
7 Operator training.
7 Preventive maintenance program.
7 OSHA HAZWOPER training.
5.0 5 year accidental history ('68.155(e)).
No releases or accidents, involving ammonia, that are reportable in accordance with 40 CFR Part 68 (RMP Rule), have occurred at this facility.
6.0 Emergency response program ('68.155(f)).
During normal workday operation, the facility emergency response plan consists of employee notification (alarm) and evacuation, followed by notification of the Abbeville Volunteer Fire Department by dialing "9-1-1" on a plant phone line. In the event of a Hazardous Materials incident, the Abbeville Volun
teer Fire Department can contact the Dothan Fire Department for assistance at "1-334-793-0372". Additional emergency support and notification is made with the Henry County EMA (LEPC) at "1-334-585-6702".
Sheltering Services can be coordinated through the Dothan Chapter of the American Red Cross by calling "1-334-792-9852".