ConAgra Poultry of Chattanooga (Further Processing - Executive Summary |
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This report contains the Risk Management Plan (RMP) for the ammonia refrigeration systems located at the ConAgra Poultry of Chattanooga poultry processing facility in Chattanooga, TN. 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 of Chattanooga recognizes management's responsibility in protecting its employees, equipment, property, and the environment. The safety and health of all peronnel 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 associate d with damage 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. Coats, Maintenance Manager, is responsible for implementation of the Risk Management Program. The purpose of the accidental release prevention and emergency response programs is to prevent the occurence, 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 illnesses 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 of Chattanooga operates a poultry processing facility in Chattanooga, TN. 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 Managem ent 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 ammonia from the high pressure receiver, over a 10 minute period due to the failure of the receiver. This is a conservative assumption as the liquid level within the unit is normally less than this amount. The worst-case release scenario related to the refrigeration system is unlikely for the following reasons: 1.) The Worst-Case weather conditions which were used for this scenario are not typical; 2.) The high pressure receiver is located in an adrea with minimal traffic (e.g. forklifts); 3.) Industry standards have been followed for the manufacturer and quality of the high pressure receiver; 4.) Ammonia is not corrosive in this service; 5.) Pressure safety valve limit operating pressure in the unit; 6.) The facility has preventive maintenance program in place to maintain the on-going integrity of vesse ls; 7.) The facility has a training program designed to ensure that the system is operated by qualified personnel, and; 8.) 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 ammonia over a 15 minute period due to the development of a release from a leaking seal on a pump. The alternative release scenario for the refrigeration system is unlikely for the following reasons: 1.) Industry standards have been followed for the manufacturer and quality control of these units; 2.) Ammonia is not corrosive to the equipment in this service; 3.) Most of the lines are elevated to minimize potential damage from fork lifts; 4.) The facilitly has preventive maintenance program in place to maintain the on-going integrity of the system; 5.) The facility has a training program designed to ensure that the system is operated by qualified personnel, and; 6.) 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 hazard analysis is 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 pote ntial hazards. Operating Procedures: Written, detailed procedures have been developed which descibes 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 evaluated before they perform work on or near the ammonia refrigeration system. The contractors are also periodically evaluated to ensure 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 facili ty will respond to ammonia spills and other emergencies, including evacuation procedures. This program has been coordinated with the local fire department and the Chattanooga/Hamilton County LEPC. 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 Site Re-entry Procedures Training Programs and Drills G. Planned Changes to Improve Safety Recommendations were made for either the equipment (hardware) or the system operating procedures (procedural) when the most recent process hazard analysis (PHA) study was conducted. The recommended changes have been evaluated by management and are being addressed and resolved in a timely manner. |