Taylor Packing Co., Inc. - Executive Summary |
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Executive Summary for Taylor Packing Co., Inc. Taylor Packing produces beef products at our plant in Wyalusing. We have a strong commitment to operate our facility in a safe and responsible manner and the facility has been recognized as an OSHA Merit site in the VPP program. Ammonia is used at the facility as the refrigerant, similar to the function Freon plays in a home or car air conditioning system. Ammonia is used to keep air temperatures in our process areas, coolers, and freezers in specified ranges. These temperatures are required to assure food safety. The ammonia is contained in a closed loop system; it is designed to remain inside the piping and vessels in our facility. We believe that ammonia provides the safest and most efficient cooling choice for our operation. Chlorine is used at the facility for water treatment in our water supuply and wastewater treatment systems. The chlorine is contained in a closed system under vacuum. A. Describe the Accident Release Pr evention and Emergency Policies Taylor Packing takes many precautions to prevent or minimize accidental releases of ammonia from the refrigeration systems and chlorine from the water treatment systems. These precautions include safety controls (alarms and automatic shutdown devices) which are designed to identify and prevent potentially unsafe conditions like pressure increases that could cause a system failure. We also have a preventive maintenance program designed to maintain the on-going integrity of the systems, a training program designed to ensure that the systems are operated by qualified personnel, and to respond quickly to system upsets. The Safety Supervisor is responsible for the management of the ammonia and chlorine safety programs. B. Stationary Source and Regulated Substances Handled The facilty operates two refrigeration systems with an ammonia inventory of approximately 52,000 and 11,480 pounds respectively. The facility also operates two chlorine systems with a chlorine inventory of 4,000 and 750 pounds respectively. Ammonia and chlorine are the only substances covered by the Accidental Release Prevention Regulations handled at the Wyalusing plant. C. Summary of Worst-Case and Alternative Release Scenarios EPA requires us to define the worst case release scenario from the Wyalusing plant as the release of all the ammonia from the largest vessel on site. At our Wyalusing plant, this would be 29,000 pounds of ammonia over a 10 minute period due to the failure of the high-pressure receiver. The 29,000 pounds represents the maximum amount of ammonia that would be contained in the receiver at any time. EPA also requires us to assume that the weather conditions are such that there is almost no wind and no mixing in the atmosphere. The alternative release scenario at the Wyalusing plant would involve the release of 5,400 pounds of ammonia over a 10-minute period due to the rupture of a 1/2" high pressure liquid line. The duration of the r elease was estimated for the alternative release scenario by estimating the amount of time required to stop the leak. Again, EPA required us to estimate the impacts of this release under low wind and stable weather conditions. Both of these releases are unlikely for many reasons. Our equipment and systems were designed using industry standards for ammonia refrigeration. We have taken precautions to protect our equipment from obvious threats, like vehicular traffic. We have a preventive maintenance program to maintain the on-going integrity of the refrigeration equipment. Training programs are in place to ensure that qualified personnel operate the systems, and our emergency response procedures allow us to respond quickly in the event of an accident. And lastly, the weather conditions used in estimating the extent of the releases are uncommon. EPA requires us to define the worst case release scenario from the Wyalusing plant as the release of all the chlorine from the largest ve ssel on site. At our Wyalusing plant, this would be 2,000 pounds of chlorine over a 10-minute period due to the failure of the 1-ton cylinder. The 2,000 pounds represents the maximum amount of chlorine that would be contained in the cylinder at any time. EPA also requires us to assume that the weather conditions are such that there is almost no wind and no mixing in the atmosphere. The alternative release scenario at the Wyalusing plant would involve the release of 1,170 pounds of ammonia over a 39-minute period due to failure of the regulator. The duration of the release was estimated for the alternative release scenario by estimating the amount of time required to stop the leak. Again, EPA required us to estimate the impacts of thes release under low wind and stable weather conditions. Both of these releases are unlikely for many reasons. Our equipment and systems were designed using industry standards for chlorine. We have taken precautions to protect our equipment from obv ious threats, like vehicular traffic. We have a preventive maintenance program to maintain the on-going integrity of the refrigeration equipment. Training programs are in place to ensure that qualified personnel operate the systems, and our emergency response procedures allow us to respond quickly in the event of an accident. And lastly, the weather conditions used in estimating the extent of the releases are uncommon. D. Description of the Accidental Release Prevention Program The facility has an accident release prevention program that complies with Occupational Safety and Health Act's Process Safety Management Standard and EPA's Risk Management Program Regulation. The prevention program consists of the following elements: - Employee Participation Program - Process Safety Information - Process Hazard Analysis - Operating Procedures - Training Program - Contractor Safety Program - Pre-Startup Safety Review Procedures - Mechanical Integrity Program - Hot Work Permit Pr ocedures - Management of Change Procedures - Incident Investigation Procedures - Compliance Audit Procedures E. Five Year Accident History There have been no ammonia or chlorine related accidents at the Wyalusing plant in the past five years. F. Description of the Emergency Response Program An emergency response program has been implemented at the Wyalusing plant. This program contains procedures describing how the facility will respond to ammonia and chlorine releases and other emergencies, including evacuation procedures. The plant response team utilizes employees who are trained to enter and stop an accidental ammonia or chlorine release. G. Planned Changes to Improve Safety Taylor Packing is committed to operating our ammonia refrigeration and chlorine systems in a safe and responsible manner. We are continually evaluating our equipment and procedures to meet this objective. Planned improvements include replacement and relocation of the chub chiller heat exchanger t o the roof of the building. We are also planning to upsize relief vent line (installed before current guidance) to current requirements. |