Cagle's, Inc. - Executive Summary |
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A) Accidental Release Prevention and Emergency Response Policies This ammonia refrigeration system was designed and installed to meet ANSI/ASHRAE 15-1992 Safety Code for Mechanical Refrigeration and the ANSI/IIAR 1984 standard, Equipment Design and Installation of Ammonia Mechanical Refrigeration Systems or the existing code at the time of installation. Trained Refrigeration Technicians are available to respond to any situation requiring emergency actions. The facility is also coordinated with Houston County Fire Department which would provide additional emergency response expertise. B) The Stationary Source and Regulated Substance Handled The primary activities of this facility is poultry slaughtering and processing. Ammonia is used solely as a refrigerant in a closed loop refrigeration system. The volume of ammonia stored at the facility is approximately 70,000 pounds. C) The Worst Case Scenario and Alternate Release Scenario Including Administrative Controls and Mitigation M easures to Limit the Distance for Each Reported Scenario RMP Comp software was used to develop worst case and alternate release scenarios. The worst case scenario is based on the loss of the entire contents of the largest ammonia receiving vessel during a ten minute period. The release would be mitigated by building structure. Administrative controls, such as emergency shut down procedures have been developed, and the operators have been trained on those procedures. This scenario is required by EPA to assume unfavorable atmospheric conditions such as a wind speed of 1.5 meters/second and an atmospheric stability class of F. The affected zone would find an endpoint at 1.70 miles. The two areas of concern within the area-to-endpoint are Sand Bed Baptist Church and Kings Chapel School. With the prevailing winds, these two locations would not be in the area-to-endpoint. Census Block Group Proration method was used to determine the estimated number of persons living within the area -to-endpoint. Although those census tracts show 9860 persons would be affected, a study of the area shows it to be rural/agricultural and much less densely populated. The alterante release scenario is based on a more realistic release from a pipe leak inside the ammonia compressor room. This release would be mitigated by the building structure and the emergency shut down procedures which have been developed and implemented. This scenario assumes more realistic atmospheric conditions such as a wind speed of 3.0 meters/second and an atmospheric stability class of D. This affected zone would find an endpoint at 0.20 miles. With the prevailing winds, the endpoint wound not extend beyond the site property boundary. Census Block Group Proration method was used to determine the estimated number of persons living within the area-to-endpoint. Although those census tracts show that 165 persons would be expsected to live within that area, a study of the area identifies no houses within t he area-to-endpoint. D) The General Accident Release Prevention Program and Chemical Specific Prevention Steps This facility has adopted a Level 3 Prevention Program and is fully compliant with OSHA Process Safety Management standard. The following paragraphs briefly descibe the elements of the prevention program implented at this facility. Process Safety Information Cagle's, Inc. maintains a detailed record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with the process. Process Hazard Analysis Cagle's, Inc. conducts comprehensive studies to ensure that hazards associated with our process are identified and controlled efficiently. The methodology used to carry out this analysis is WHat If-Checklist. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a five-year interval. Any findings related to the hazard analysis are ad dressed in a timely manner. Operating Procedures For the purpose of safely conducting activities within our covered process, Cagle's, Inc. maintains written operating procedures. These procedures address various modes of operation such as initial start up, normal operations, temporary operations, emergency shut down, emergency operations, normal shut down, and start up after a turnaround. The information is regularly reviewed and is accessible to operators involved with the process. Training Cagle's, Inc. has a comprehensive training program in place to ensure that employees who are operating the process are completely competent in the operating procedures associated with the process. Refreasher training is provided at least every three years and more frequently as needed. Mechanical Integrity Cagle's, Inc. carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes pressure vesels, storag e tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance procedures are carried out by qualified personnel with a strong backgound in maintenacne practices. Specialized training is provided to the personnel as needed. Any equipment deficiencies identified during maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Cagle's, Inc. to manage changes in process chemicals, technology, equipment, and procedures. Process operators, maintenance personnel and all other employees whose job tasks are affected by a change in a process are promptly made aware of and offered training to deal with the changes. Pre-startup Reviews Pre-startup safety reviews related to new processes and to modifications in the established process are conducted as a regular practice at Cagles', Inc. These reviews are conducted to confirm that construction, equipment, operating and maintenance proce dures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Cagle's, Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP Rule are being implemented. These audits are conducted at least every three years. Any corrective actions required by an audit are undertaken in a sfe and timely manner. Incident Investigation Cagle's, Inc. promptly investigates any incident that has resulted in, or could reasonably result in a catostrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident, as well as any corrective actions to prevent the release from recurring. All reports are maintained for at least five years. Employee Participation Cagle's, Inc. truly believes that process safety management and accident prevention are a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information collected as part of the facility's compliance with the RMP Rule including information resulting from process hazard analysis. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Cagle's, Inc. has a strict policy of informing the contractors of known potential hazards related to the contractor's work. Contractors are informed of all procedures for emergency response to an accidental release of a regulated substance. Hot-Worpk Permits Cagle's, Inc. strictly regulates hot work activities in process areas and on process equipment. Appropriate safety precautions are instituted before work begins. Additionally, the work to be completed is evaluated to determine if Management of Change procedures are applicable. E) Five year Accident History This is a newly renovated facility with production startup scheduled for the fall of 2000. There have been no releases. F) The Emergency Response Program The plan calls for production employees to evacuate the building in the event of a release that warrents evacuation in response to training received to comply with 29 CFR 1910.38. A wind sock on the roof would allow assembly upwind from the release. Refrigeration personnel have been trained to respond and stop a leak in the ammonia system as required by 29 CFR 1910.120(q). The plan calls for coordination with Houston County Fire Department through the 911 emergency service, and the National Response Center (1-800-424-8802) should the release have off-site impact, a reportable quantity (RQ) is released (100 pounds), or additional assistance is otherwise needed. An on-site health clinic is staffed during al production hours to attend to minor employee injuries and illnesses. Any affected employee would be trea ted by this clinic or transported to an emergency room should the situation warrent more acute care. G) Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Continued training and program reviews are some of the major steps we want to take to improve the safe operation of our facility and process. These changes are expected to be implemented in a timely manner. |