ConAgra Poultry / Elberton - Executive Summary |
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This report contains the Risk Management Plan (RMP) for the ammonia refrigeration systems located at the ConAgra Poultry / Elberton, poultry processing facility in Elberton, Ga. The RMP was prepared in accordance with the requirements of the U.S. Environmental Protection Agency (EPA) Risk Management Regulations for Chemical Accidental Release Prevention, 40 CFR Part 68. A. Accidental Release Prevention and Emergency Response Policies ConAgra Poultry / Elberton, recognizes management's responsibility in protecting its employees, equipment, property, and the environment. The safety and health of all personnel are very important. The control of accidents has been and will continue to be a basic responsibility of all personnel at the facility. To accomplish the company's goal in controlling accidental losses, the facility has a Plant Safety Program in place. The objective of the Plant Safety Program are to: maximize efficiency and safety performance, reduce losses associated with da mage of property, eliminate human suffering and the economic burden resulting from injuries and accidents. One of the activities associated with the Plant Safety Program has been the development and implementation of accidental release prevention and emergency response programs which are designed to comply with OSHA's Process Safety Management (PSM) standard (Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119), and EPA's Risk Management Program regulation (Risk Management Programs for Chemical Accidental Release Prevention, 40 CFR Part 68). Mr. Jim Barker, Plant Engineer, is responsible for implementation of the Risk Management Program. The purpose of the accidental release prevention and emergency response programs is to prevent the occurrence, and minimize the consequences of significant releases of toxic substances as well as fires, explosions, and other types of catastrophic accidents. Overall, these programs prevent accidental fatalities, injuries and ill nesses and avoid physical property damage. The accidental release prevention and emergency response programs help prevent accidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment. These rules are detailed and improved as necessary. They are also communicated to and accepted by all employees at the facility. B. Stationary Source and Regulated Substances Handled ConAgra Poultry / Elberton, operates a poultry processing facility in Elberton Ga. The facility operates ammonia refrigeration systems to provide cooling and freezing capabilities. The amount of anhydrous ammonia (CAS # 7662-41-7) contained in the system is above the EPA threshold of 10,000 pounds. Since ammonia releases from this system could pose a risk of offsite public impact and they are regulated under the OSHA PSM standard (29 CFR 1910.119), the systems are subject to the Program 3 requirements of the EPA's Risk Management Program. C. Summary of Worst-Case and Alternative Release Scenarios The worst-case release scenario for the refrigeration system at the facility involves the release of 30,655 pounds of ammonia over a 10 minute period due to the failure of the -55 degree recirculator vessel pump header. This is conservative assumption as the liquid level within the unit is normally less than this amount. Under worst-case weather conditions, ammonia could travel 2.2 miles before dispersing enough to no longer pose a hazard to the public. This distance is calculated using RMP Comp, a air modeling method allowable under the Risk Management Program. The worst-case release scenario related to the refrigeration system is unlikely for the following reasons: ? The Worst-case weather conditions which were used for this scenario are not typical' ? The -55 degree recirculator vessel is located in an area with minimal traffic (e.g., forklifts); ? Industry standards have been followed for the manufacture and quality of the -55 degree recirculator vessel; ? Ammonia is not corrosive in this service; ? Pressure safety valve limit operating pressure in the unit; ? The facility has preventive maintenance program in place to maintain the on-going integrity of vessels; ? The facility has a training program designed to ensure that the system is operated by qualified personnel; and, ? The facility emergency response procedures enable trained personnel to respond quickly to isolate any potential releases. The alternative release scenario considered for the refrigeration system involves the release of 19,168 pounds of ammonia over a 10.2 minute period due the development of a break in the sight glass drain of the high pressure receiving vessel . Under alternative release weather conditions, ammonia could travel 1 mile before dispersing enough to no longer pose a hazard to the public. This distance is calculated using RMP Comp, a air modeling method allowable under the Risk Management Program. The alternativ e release scenario for the refrigeration system is unlikely for the following reasons' ? Industry standards have been followed for the manufacture and quality control of these units; ? Ammonia is not corrosive to the equipment in this service; ? Most of the lines are elevated to minimize potential damage from fork lifts; ? The facility has preventive maintenance program in place to maintain the on-going integrity of the system; ? The facility has a training program designed to ensure that the system is operated by qualified personnel; and, ? The facility emergency response procedures enable trained personnel to respond quickly to isolate any potential releases by closing isolation valves and liquid lines. D. Description of the Accidental Release Prevention Program The prevention program consists of the following elements; ? Employee Participation: This program involves the employees in establishing and implementing the program. Employees are also to be involved when a process haz ard analysis in conducted. The program also ensures that all employees have complete access to the program. ? Process Safety Information: Written information has been collected which enables the employees to identify and understand the potential hazards in the system. The written information includes the ammonia MSDS and a description of the design of the ammonia refrigeration system. ? Process Hazard Analysis: Formal studies using the What-If Technique have been conducted to look at the system and identify potential hazards. ? Operating Procedures: Written, detailed procedures have been developed which describe the steps which should be followed to safely operate the ammonia refrigeration system. ? Training: A training program has been developed which ensures that employees are trained on all aspects of the system and on the duties which they should perform to ensure the safe operation of the ammonia refrigeration system. ? Contractors: All contractors are screened and evaluate d before they perform work on or near the ammonia refrigeration system. The contractors are also periodically evaluated to ensure that they perform work by following safe work practices. ? Pre-Startup Safety Review: A pre-startup safety review is completed for all new ammonia projects to verify that all safety programs are in place, training has been performed, and construction has been completed according to design standards before the project is put into use. ? Mechanical Integrity: This program ensures that the ammonia refrigeration systems are built and maintained using preventative maintenance procedures to minimize unexpected breakdowns or failures. ? Hot Work Permit: These procedures ensure that a signed permit is obtained prior to any cutting, welding, or burning. ? Management of Change: The procedures are designed to ensure that all changes made to the ammonia refrigeration system are properly reviewed. ? Incident investigation: The procedures ensure that any incidents ( and near misses) are investigated, reviewed, and documented using an investigation team. ? Compliance Audits: There are procedures to conduct regular audits of the Risk Management Program to ensure that the program is in place and working properly. E. Five Year Accident History No ammonia-related incident were identified for the previous five years. F. Description of the Emergency Response Program An emergency response program has been implemented at the facility. This program contains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures. This program has been coordinated with the Elbert County Emergency Planning Agency. The emergency response program consists of the following elements: ? Organization Plan and Responsibilities ? Communications Procedures ? Detailed Action Plans ? First Aid Procedures ? Emergency Medical Treatment Procedures ? Evacuation Plans ? Description of Outside Assistance Available ? Training Programs and Drills |