Butterball Turkey Company - Executive Summary |
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EXECUTIVE SUMMARY 1.0 RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Butterball facility in Wallace, North Carolina has a good record in preventing releases of anhydrous* ammonia. As part of their release prevention program, the plant has implemented a preventative maintenance program. More information about these aspects of the prevention program is discussed in Section 4.0 of this Executive Summary. The facility has implemented an Emergency Action/Response Plan which is to provide information and guidance to safely deal with an ammonia release. This emergency response program is all encompassing, covering all facets of known or potential emergency situations which could possibly develop such as fire, medical, hazardous substance, bomb threats, and acts of nature. The emergency response policies at the Butterball facility ensure that there is emergency response coverage 24 hours - 7 days per week. *From this point in the Executive Summary, anhydrous ammonia will be syn onymous with ammonia. 2.0 PROCESS DESCRIPTION AND REGULATED SUBSTANCES The Butterball Wallace plant eviscerates turkeys and produces whole turkey products for retail sale. The NAICS code for the processes at this facility is 311615. Many areas of the plant are refrigerated to preserve the meat products. Butterball has one regulated substance under 40 CFR 68: ammonia. Ammonia is used as a refrigerant in the refrigeration of the products in the various areas of the plant. The ammonia threshold for triggering applicability to 40 CFR 68 is 10,000 pounds. The total quantity of ammonia stored in the refrigeration process is documented as approximately 63,160 pounds. The process exceeds the threshold quantity of 10,000 pounds as set by 40 CFR 68 and thus is regulated by the Risk Management Program. 3.0 WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS The ammonia refrigeration system has associated hazards that can potentially affect on-site employees and the general public off-site if there is a release from the system. Described below are the associated hazards and the worst-case and alternative release scenario for the regulated chemical. Though there may be other scenarios possible, EPA only requires that one worst-case and one alternative scenario be reported for each regulated chemical. Ammonia is classified as a Group 2 Refrigerant per ASHRAE Standard 34-1989. The dominant characteristic of this chemical is its toxicity. It is a self-alarming chemical by its distinctive pungent odor. Due to this odor, persons exposed to ammonia vapor will not voluntarily stay in areas of even small concentrations. Ammonia will burn at a very narrow and high range of concentrations accompanied with a high ignition temperature. Although ammonia is not poisonous, it is corrosive to human tissue. Ammonia is readily absorbed into the moisture of the skin and, at high concentrations, can cause severe burns. The risks to persons in an accidental release of ammonia include: 1. Corrosive attack of skin and other tissue (including lung tissue) 2. Freezing of skin and other body tissue when contacted by liquid ammonia 3. Eye contact Below is a description of the release scenarios for ammonia and their off-site consequences: 3.1 Worst-Case Scenario Description One worst-case scenario has been developed for the Butterball plant. The largest potential release of ammonia would occur with a 1 3/4 inch diameter puncture in the liquid portion of the high pressure receiver 1. Taking the specific definition of the worst-case from 40 CFR 68.25, the vessel that can store the largest quantity (18,996 lbs.) of ammonia is the high side accumulator. However, since this vessel is indoors, the building will mitigate some of the release quantity (only 6,078 pounds would be released to the outdoors). The high pressure receiver is located outdoors and can hold 9,792 pounds which will produce a larger distance to endpoint than the high side accumulator vessel release. T herefore, the worst-case release quantity will be 9,792 pounds. It is assumed that the entire quantity is released in 10 minutes. Administrative and passive controls are not applicable to this scenario. For the worst-case release, regulations dictate that the release height is at ground level. Under Section 68.25(c)(1), a regulated toxic substance such as ammonia that is normally a gas at ambient temperature and handled as a liquid under pressure shall be considered to be released as a gas over a 10 minute period. Thus, ammonia's physical state in the worst-case scenario is a gas. The worst-case release scenario distance-to-endpoint will reach off-site public receptors. 3.2 Alternative Release Scenario Description The alternative release scenario is an ammonia release from the high pressure liquid piping on the roof. The release scenario considers piping component failure on the high pressure liquid line. The opening is assumed be equivalent to a 3/8 diameter orifice, and is located 25 feet above ground level. Administrative and passive controls are not applicable to this scenario. Active mitigation of the release is human intervention. The alternative release scenario distance-to-endpoint will reach off-site public receptors. 4.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Butterball has developed an OSHA (PSM) program for their ammonia refrigeration system. At Butterball, ammonia falls under the RMP Program 3 Prevention Program which is identical to the OSHA PSM program. EPA has said that if the process is in compliance with OSHA PSM, then it is compliance with RMP Program 3. Thus, Butterball's ammonia PSM system has been reviewed and the PSM system elements are being implemented for the RMP document. Listed below are the key aspects of the ammonia prevention program: The Butterball plant uses a Computerized Maintenance Management System (CMMS) for control scheduling and accomplishment of preventat ive maintenance on components of the refrigeration system. The scope of preventative maintenance (PM) and testing/inspection (T/I) for refrigeration components is based on individual vendor recommendations and generally accepted engineering practices with regard to types of preventative maintenance and inspections and their recommended frequencies. Individual work tasks for each type of PM and T/I associated with the refrigeration system are being created. These tasks are included on the individual work order generated by the CMMS. This system ensures that each operator mechanic is aware of the pertinent safety precautions required for a PM procedure as well as the step-by-step actions required to complete the procedure. The operator/mechanic and their supervisor sign off the completed work order. Specific results of each PM and T/I is not completed satisfactorily, the operator/mechanic notes it on the work order, and follow-up work order is generated to address the specific defi ciency. 5.0 FIVE-YEAR ACCIDENT HISTORY The review of Butterball's accident history includes the following range of dates: June 21, 1994 - June 21, 1999. According to 40 CFR Part 68.42(a), there have been no accidental releases at this facility. 6.0 EMERGENCY RESPONSE PROGRAM As mentioned previously, the Butterball facility has developed an Emergency Action/Response Plan. The emergency plan is a detailed document which discusses the role of employees in an emergency situation. The plan outlines specific procedures for evacuations of plant personnel. The Emergency Action Plan contains specific information regarding: purpose, local emergency phone numbers, coordination with local authorities, training, emergency response plan outline, organization, communication, site security, USDA notification, plant evacuation plan, emergency evacuation routes, visitors/contractors, news media, evacuation drills, and critique of emergency response, hazardous substances, rescue and medical dutie s, emergency recognition and prevention, decontamination, PPE and emergency equipment, and EPA release reporting procedures. 7.0 PLANNED CHANGES TO IMPROVE SAFETY Based on the completed Process Hazard Analysis (PHA) for ammonia, a list of action items to improve safety was developed and their status monitored to ensure that implementation was accomplished. An example of safety improvements made at the plant is discussed below: The plant has completed several projects in the past two years that have improved the safety and efficiency of their ammonia refrigeration system. These include the installation of two new rechillers outside the plant, which will ultimately replace three existing rechillers inside the plant. This modification will result in a reduction of both ammonia piping and equipment on the interior of the plant and the hazards associated with them. The plant has also installed both an ammonia detection and emergency shutdown system. Additionally, the plant has comp leted labeling and tagging of the ammonia system as well as improved access platforms and crossovers on the roof. |