IBP, inc. - Executive Summary
EXECUTIVE SUMMARY |
Accident Release Prevention Program and Emergency Response Policy
It is the policy of the IBP, inc. (IBP) Waterloo, Iowa facility management to implement the requirements of this Risk Management Program (RMP) in accordance with the USEPA regulations under 40 CFR Part 68 and with the corresponding regulations under OSHA's Process Safety Management (PSM) program. The objective is to minimize the risk of a release of a hazardous material and if a release occurs, to minimize the potential impact to IBP employees, the public and the environment. This objective will be accomplished by utilizing general good operating procedures, providing appropriate training to all employees, and coordinating response activities, as necessary, with the local emergency response providers. This plan covers all IBP owned activities at this facility.
IBP's management is committed to providing the resources necessary to implement this policy.
IBP operates a hog slaughter
and processing facility at this location. Hogs are trucked to the facility, slaughtered and fabricated. IBP operates rendering systems for pork byproducts and grease. Support operations include cold storage, an analytical laboratory and administrative offices.
One chemical is utilized at the facility in sufficient quantities to be subject to the requirements of 40 CFR Part 68. This chemical is ammonia. Ammonia is used as a refrigerant throughout the facility.
Worst-Case and Alternative-Release Scenarios
RMP regulations require that each facility identify worst-case and alternative case release scenarios. EPA has defined a worst-case release as the release of the entire contents of the largest vessel that contains a regulated substance in a 10-minute period. This release rate is then evaluated using modeling techniques and/or reference tables to define the distance to a specified endpoint (concentration or overpressure). The distance to the endpoint is affected by several facto
rs including molecular weight, volatility, heat of combustion, and physical setting (urban or rural).
The alternative release scenario must be one that is more likely to occur than the worst-case scenario and that reaches an endpoint offsite, unless no such scenario exists. The alternative release scenario is also evaluated to define the distance to the specified endpoint.
Under 40 CFR 68 Subpart B '68.22(e), the RMP rule identifies surface roughness as a parameter to be used in the hazard assessment to determine the physical setting of the site, urban or rural. "Urban means there are many obstacles in the immediate area; obstacles include buildings or trees. Rural means there are no buildings in the immediate area and the terrain is generally flat and unobstructed."
Due to the presence of trees, hills, and/or other structures in the immediate vicinity of the Waterloo, Iowa facility, a rural dispersion environment was assumed.
The data provided in the document "Model Risk Ma
nagement Program and Plan for Ammonia Refrigeration" (May 1996) was used to estimate the toxic endpoint distance for the worst-case and alternative ammonia release scenarios. The EPA's "RMP Off-site Consequence Analysis Guidance" (May 1996) was not used to determine the toxic endpoint since it classifies ammonia as a neutrally buoyant gas. Since the worst-case ammonia release would involve liquid and would come from a pressurized system containing liquid, the released gas should be classified as a dense gas (a result of evaporative cooling). The ammonia refrigeration document provides calculated endpoint distances for typical meteorological conditions.
The worst-case release scenario for an anhydrous ammonia release included a release of all the contents of the low-pressure accumulator in a 10-minute period (per EPA guidelines). This release translates to a release of 58,782 pounds of ammonia in 10 minutes or 5,878.2 lbs/min. Other assumptions included in the worst-case assessment
are: the ammonia is a liquefied gas; the low pressure accumulator is not diked; the release does not take place indoors; the nearfield dispersion environment is characterized as rural; 10-minute averaging period; the windspeed is 1.5 meters/sec and the atmospheric stability is classified as F (stable). The results of the worst-case assessment for ammonia show that the plume must travel 4.42 miles (7.11 kilometers) before dispersing to the endpoint concentration of 201 ppm.
The selected alternative-release scenario for the ammonia systems is a release from a relief valve due to overpressure of a compressor unit. The largest relief valve in the system was used in this scenario. The largest relief valve has a relief rate of 176.8 pounds of air per minute. As a matter of convention, the specified release rate of any relief valve is always in pounds of air per minute. The release rate of 176.8 pounds of air per minute correlates to a release rate of 125.5 pounds of ammonia vapor per
minute. This release rate was applied to a release from the ammonia header on top of the building.
The ammonia refrigeration document provides calculated endpoint distances for typical meteorological conditions (3 m/s wind speed, D atmospheric stability, 50% relative humidity). It has been determined, through a review of IBP's operational history, that the total release would likely be 500 pounds of ammonia. Based on the release rate of 125.5 lbs/min, the duration for a 500-pound release is 4 minutes. Other assumptions include that no active or passive mitigation measures are currently in place and an rural dispersion environment in the nearfield. The results of the alternative-release scenario for an ammonia release indicates that the endpoint concentration of 201 ppm is reached at 0.22 miles (350 meters) from the release point.
General Accidental Release Prevention Program and Chemical Specific Prevention Steps
The Waterloo, Iowa facility is governed by a set of OSHA and USEPA r
egulations that require planning and facility activities intended to prevent a release of hazardous material, or if a release inadvertently occurs, to minimize the consequences of a release to the employees of the facility, the public and to the environment. These regulations include:
* 40 CFR Part 68, Accidental Release Prevention
* 40 CFR Part 112, Spill Prevention, Control and Countermeasure
* 40 CFR Part 264, Hazardous Waste Contingency Plan
* 29 CFR Part 119, Process Safety Management
* 40 CFR Part 302, Emergency Planning and Community Right-to-Know Act (EPCRA)
The key concepts in IBP's release prevention program are employee participation, appropriate design and maintenance of equipment, and appropriate training of all employees. IBP has developed and documented these elements in their process safety management plan (PSM). The PSM plan is incorporated with this document by reference.
Employee participation in the release prevention program is encouraged and supported by IBP ma
nagement. Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the ammonia. IBP employees are also members of the facility emergency response team.
IBP policy is to construct all new equipment, systems, and facilities to ensure the appropriate safety and release prevention systems are included from the beginning of each project. IBP maintains a computerized program of maintenance activities to ensure that key systems are maintained appropriately to minimize the risk of a release.
IBP is committed to providing appropriate training to all employees regarding safety procedures. Each new employee is provided comprehensive safety training during their initial orientation for the facility. In addition, IBP conducts regularly scheduled safety training for all employees each year. Additional training is provided to maintenance personnel for the systems they are responsible for. Members of IBP's emergency response team recei
ve semiannual training to ensure that response actions are promptly and safely completed.
Five Year Accident History
Between August 1994 and April 1996, IBP had three releases of ammonia from the Waterloo, Iowa facility that resulted in five minor OSHA recordable injuries involving ammonia vapor inhalation. None of these releases affected the public or the environment. IBP does not have records of the time and duration of the releases or the release quantities. IBP has process alarms in the rooms where the releases occurred. If the concentration of ammonia reaches 20 parts per million the alarm will sound. During these incidents the alarms did not activate. Therefore, because the alarms did not sound, IBP believes the release quantity was small. The releases were small and did not require an incident investigation. IBP has assumed, after reasonable inquiry, the time of the incident is 12:00 PM, lasted one minute, and released one pound of ammonia.
Emergency Response Program
has personnel trained in emergency response at the facility 24 hours per day, seven days per week. These personnel receive annual training on emergency procedures and response techniques.
Planned Changes to Improve Safety
IBP completes a thorough review of the ammonia systems each time a design change is implemented. IBP is committed to using these methods to identify and implement ways to improve the safety of these systems.