Townsends Inc. - Executive Summary |
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EXECUTIVE SUMMARY FOR TOWNSENDS, INC - MILLSBORO PLANT 1. Accidental Release Prevention and Emergency Response Policies We at Townsends, Inc., Millsboro facility, 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, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release. 2. The Stationary Source and Regulated Substance Handled Out facility's primary activities encompass Poultry Processing. We have one (1) regulated substance present at our facility. This substance is anhy drous ammonia. The regulated substance at this facility has a singular use: refrigeration. Our ammonia refrigeration system is separated into two (2) systems containing approximately 20,000 lbs. of ammonia each. 3. 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 RMP COMP for the worst case scenario and ALOHA(R) for the alternate release scenario. The following paragraphs provide details of the chosen scenarios: Worst Case Scenario: A failure or puncture of the high pressure receiver of either system would release the greatest quantity of ammonia for our facility. About 20,000 pounds of ammonia would be released as a liquid which would then vaporize. It is assumed that the entire contents are released as a liquid, which vaporizes and spreads out from the plant as a vapor cloud. The distance to the toxic endpoint of 0.14mg/L (Basis ERPG-2) is 2.2 miles. The distance extends beyond the facility boundary, encompasses several businesses and residences, schools, and an adult care facility . Alternative Scenario: A leak from a short pipe or valve in a horizontal cylindrical tank would release 1,789 lbs. over a three minute release duration and would reach an offsite receptor. The distance to the endpoint of 0.14mg/L is 0.3 miles. The distance is beyond the facility boundaries and encompasses only one offsite public receptor, a private residence 0.3 miles offsite. 4. The General Acciden tal Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all of the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NEPA-58 Standard, 1967 Edition. The ammonia refrigeration process at this facility is subject to the OSHA PSM standard under 29 CFR 1910.119. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Townsends, Inc. maintains a detailed record of 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 controlled efficiently. The methodology used to carry ou t these analyses is "What-if". The studies are undertaken by a team of qualified personnel with experience in engineering and process operations and are revalidated at a regular interval of five (5) years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purpose of safely conducting activities within our covered processes, Townsends Millsboro facility maintains written operating procedures. These procedures address various modes of operations 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 in the process. Training Townsends Millsboro facility has a training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provide d at least every three (3) years and more frequently as needed. Mechanical Integrity Townsends Millsboro facility carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown 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 Townsends Millsboro facility to manage changes in process chemicals, technology, equipment and procedures. Process operators, 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-startup safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Townsends Millsboro 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 Townsends Millsboro 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 (3) and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Townsends Millsboro facility promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are unde rtaken 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 Townsends Millsboro facility truly believes that process safety management and accident prevention is a team effort. Company 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 a part of the facility's implementation of the RMP rule, including information resulting from process hazard analysis in particular. Contractors On occasion, our company 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. Townsends Millsboro facility has a strict policy of informing the contractors of known potential haz ards related to the contractor'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 Townsends Millsboro facility has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period that have resulted in offsite impacts or injuries. 6. Emergency Response Plan Townsends Millsboro facility carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affecte d areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 7. Planned Changes to Improve Safety Some developments and findings have resulted from the implementation of the various elements of our accidental release prevention program along with the continuous development happening under our Process Safety Program. At the forefront of any improvements are advancements made in the area of employee awareness. Any step forward in accident prevention must include the participation and intimate involvement of our employees. The continued efforts to refine our mechanical integrity program and improve upon a sound, well run inspection, test and preventative maintenance program is essential to preventing equipment failures that could result in a release. |