Gibbon Packing, Inc. - Executive Summary

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EXECUTIVE SUMMARY 
 
Accident Release Prevention Program and Emergency Response Policy 
It is the policy of Rosen's Diversified, Inc., Gibbon Packing, 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 potential impact to Gibbon Packing 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 Gibbon Packing owned activies at this facility. Gibbon Packing's management is committed to providing the resources necessary to implement this policy. 
 
Facility Description 
Gibbon Packing operates a cow slaughter, processing, and hide washing and 
curing facility at this location. Cows are trucked to the facility , slaughtered, and processed. Gibbon Packing operates rendering systems for dried blood, low protein beef byproducts, and inedible tallow. Support operations include cold storage 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 and 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 releaserate 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 fact 
ors 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.  
Due to the presence of trees, hills, and/or other structures in the immediate vicinity of the Gibbon, Nebraska facility, an urban dispersion environment was assumed. 
 
Ammonia 
The data provided in the document "Model Risk Management 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 " (May1996) 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 tupical mateorological conditions. 
 
The worst-case release scenario for an anhydrous ammonia release included a release of all the contents of the high-pressure receiver in a 10-minute period (per EPA guidelines).This release translates to a release of 16,751 pounds of ammonia in 10 minutes or 1,675.1 lbs/min. Other assumptions included in the worst-case assessment are: the ammomia is a liquefied gas ; the high pressure accumulator is not diked; the release does not take place indoors; the nearfield dispersion environment is characterized as urban; 10-minute averaging period; the wind speed is 1.5 meters/sec and the atomospheric stability is classified as F (stable). The results of the worst-case assessment for ammonia show that the plume must travel 1.48 miles ( 
2.38 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 compressure unit. The largest relief valve in the system was used in this scenario. The largest reliefvalve has a relief rate of 57.7 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 57.7 pounds of air per minute corrleates to a release rate of 41.4 pounds of ammonia vapor per minute. This release rate was applied to a release from the Bac Tower relief valve located approximately 10 feet above the ground surface.  
 
The ammonia refrigeration document provides calculated endpoint distances for a typical meteorological conditions (3 m/s wind speed, D atmospheric stability, 50% relative humidity). It has beem determined, through a review of Gibbon Packing's operational history, that  
the total release would likely be 500 lbs of ammonia. Based on the release rate of 41.1 lbs/min, the mitigation measures are currently in place and an urban 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 0.06 miles (97 meters) from the release point. 
 
General Accidental Release Prevention Program and Chemical Specific Prevention Steps 
The Gibbon, Nebraska facility is governed by a set of OSHA and USEPA regulations 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 
 40 CFR Part 112 
 40 CFR Part 264 
 29 CFR Part 119 
 40 CFR Part 302 
The concepts in Gibbon Packing's release prvention program are employee participation, 
appropriate design and maintenance of equipment, and appropriate training of all employees. Gibbon Packing 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 Gibbon Packing management. Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the ammonia systems. Gibbon Packing employees are also members of the emergency response team. 
Gibbon Packing policy is to construct all new equipment, systems, and facilities to insure the appropriate  safety and release prevention systems are included from the begining of each project. Gibbon Packing maintains a computerized program of maintenance activities to ensure that key systems are maintained appropriately to minimize the risk of a release.  
Gibbon Packing is commited to proving appropriate t 
raining to all employees regarding safety procedures. Each new employee is provided comprehensive safety training during their ininial orientation for the facility. In addition, Gibbon Packing 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 Gibbon Packing emergency response team receive annual training to ensure that response actions are promptly and safely completed. 
 
Five Year Accident History 
Gibbon Packing has had one release of ammonia from the Gibbon, Nabraska facility that resulted in one OSHA recordable injury. During routine rounds, an employee entered the engine room and immediately smelled ammonia. The employee went to the guard shack and called Gibbon Pack management and maintenance. The employee later reported that they lost consciousness. There were no witnesses to htis event. The incident occured on February 3, 1998 and the release did n 
ot affect the public or the environment. Gibbon Pack does not have records of the time and duration of the release or the release quanity. Gibbon Pack has process alarms in the room where the release occured. If the concentration of ammonia reaches 20 parts per million the alarm will sound. During this incident the alarms did not activate. Therefore, because the alarms did not sound, Gibbon Pack beleives the release quanity was small. Gibbon Pack has assumed, after reasonable inquiry, the time of the incident is 12:00 PM, lasted one minute, and released one pound of ammonia.  
Gibbon Packing has not had an OSHA recordable incident related to the ammonia system since the system revisions were completed. 
 
Emergency Response Program 
Gibbon Packing has personnel trained in emergency response at the facility 24 hours per day, seven days a week. These personnel receive annual training on emergency procedures and response tecchniques. 
 
Planned Changes to Improve Safety 
Gibbon Packing completes 
a thorough review of the ammonia systems each time a design change is implemented. Gibbon Packing is committed to using these methods to identify and implement ways to improve the safety of these systems.
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