Cagle's - Keystone Foods, LLC - Executive Summary

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Executive Summary 
1.    Accidental Release Prevention and Emergency Response Policies 
We at Cagle's - Keystone Foods are strongly committed to employee, public and environmental safety.  This commitment is demonstrated by our comprehensive accidental release prevention program 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.  We are also completely coordinated with Clinton County Fire Department which provides additional emergency response expertise. 
2.    The Stationary Source and the Regulated Substances Handled 
Our facility's primary activities revolve around slaughtering, and processing poultry.  Anhydrous ammonia and propan 
e are the two regulated substances present at our facility.  All of the ammonia inventory is attributed to its use as a refrigerant.  The propane is used as a fuel for the facility. 
The maximum inventory of ammonia at our facility is 23,266 pounds.  The maximum propane inventory would be 111,000 pounds stored in a 30,000 gallon (water capacity) vessel. 
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 evaluate the worst case and alternative release scenarios for ammonia we have used the methodology given in the Model Risk Management Program and Plan for Ammonia Refrigeration by SAIC.  The following paragraphs provide details of the chosen scenarios. 
The worst case release scenario submitted for the Program 3 toxic substance as a class involves a catastrophic release from ammonia used as a refrigerant.  The scenario involves the release of 7,127  
pounds of ammonia in a gaseous form over 10 minutes.  At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 1.06 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. 
One alternative release scenario has been submitted for the toxic substance present in the Program 3 process. 
The alternative release scenario for Ammonia involves a release from Storage Tank in the ammonia refrigeration process.  The scenario involves the release of 400 pounds of ammonia in a gaseous form over 10 minutes.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia is 0.20 miles. 
To evaluate the worst case scenarios for propane, we have used Equations from Appendix D of the EPA's Offsite Consequence Analysis Guidance.  For alternative release scenario analyses, we have employed EPA's OCA Guidance Reference Tables.  The following paragraphs provide details of the chosen scenarios. 
The worst case release scenario submitted f 
or Program 2 and 3 flammable substances as a class involves a catastrophic release from Propane Receiver in the Propane process.  The scenario involves the release of 111,000 pounds of Propane.  It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion.  Under worst case weather conditions, the maximum distance of 0.39 miles is obtained corresponding to an endpoint of 1 psi overpressure.   
The alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Propane Receiver in the Propane process.  The release is assumed to result in a Vapor Cloud Explosion.  The scenario involves the release of 18,951 pounds of Propane in 10 minutes.  Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 PSI overpressure is 0.2 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 40 CFR Part 68 of the EPA.  In addition, our facility is subject to the OSHA PSM standard under 29 CFR 1910.119.  Our facility is also subject to EPCRA Section 302 notification requirements.  The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. 
Process Safety Information 
Cagle's - Keystone Foods maintains a detailed record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with all the 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 out these analyses is What If-Checklist.  The studies are undertaken by a team of qualified personnel with expertis 
e in engineering and process operations and are revalidated at a regular interval of 5 years.  Any findings related to the hazard analysis are addressed in a timely manner. 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, Cagle's - Keystone Foods 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 each process. 
Cagle's - Keystone Foods has a comprehensive training program in place to ensure that employees who are operating the processes are completely competent in the operating procedures associated with each process.  Refresher training is provided at least every three (3) years and more frequently as needed. 
Mechanical Integrity 
Cagle's - 
Keystone Foods carries out highly documented maintenance checks on process equipment to ensure proper operations.  Process equipment examined by these checks includes pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps.  Maintenance procedures are carried out by qualified personnel with a strong background in maintenance practices.  Specialized training is provided to the personnel as needed.  Any equipment deficiencies identified during maintenance checks are corrected in a safe and timely manner. 
Management of Change 
Written procedures are in place at Cagle's - Keystone Foods to manage changes in process chemicals, technology, equipment and procedures.  Process operators, maintenance personnel and all other employees whose job tasks are affected by a change in a process are promptly made aware of and offered training to deal with the changes. 
Pre-startup Reviews 
Pre-start up safety reviews related to new processe 
s and to modifications in the established process are conducted as a regular practice at Cagle's - Keystone Foods.  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 
Cagle's - Keystone Foods 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 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. 
Incident Investigation 
Cagle's - Keystone Foods promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic 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 mi 
nimum of 5 years. 
Employee Participation 
Cagle's - Keystone Foods 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 collected as part of the facility's compliance with the RMP Rule including information resulting from process hazard analyses. 
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. Cagle's - Keystone Foods has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes.  Contractors are also informed of all the procedures for emergency response to an accidental release of a regulated substance. 
5.    Five-year  
Accident History 
Cagle's - Keystone Foods has an excellent record of preventing accidental releases over the last year (this is a new facility built in 1998).  Due to our stringent release prevention policies, there has been no accidental release during this period. 
6.    Emergency Response Plan 
Cagle's - Keystone Foods has 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 agencies and the public, as well as post-incident decontamination of affected 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 
Several developments and findings have res 
ulted from the implementation of the various elements of our accidental release prevention program.  Continued training, and program reviews are some of the major steps we want to take to improve safety at our facility.  These changes are expected to be implemented in a timely manor.
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