FIELDALE FARMS CORNELIA COMPLEX - Executive Summary |
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1.0 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES AT FIELDALE FARMS CORPORATION, WE ARE COMMITTED TO OPERATING AND MAINTAINING ALL OF OUR PROCESSES (ESPECIALLY THOSE USING HAZARDOUS SUBSTANCES) IN A SAFE AND RESPONSIBLE MANNER. wE USE A COMBINATION OF ACCIDENTAL RELEASE PREVENTION PROGRAMS AND EMERGENCY RESPONSE PLANNING PROGRAMS TO HELP ENSURE THE SAFETY OF OUR EMPLOYEES AND THE PUBLIC AS WELL AS PROTECTION OF THE ENVIRONMENT. THIS DOCUMENT PROVIDES A BRIEF OVERVIEW OF THE COMPREHENSIVE RISK MANAGEMENT ACTIVITIES THAT WE HAVE DESIGNED AND IMPLEMENTED, INCLUDING: * A DESCRIPTION OF OUR FACILITY AND USE OF SUBSTANCES REGULATED BY EPA'S RMP REGULATION * A SUMMARY OF RESULTS FROM OUR ASSESSMENT OF THE POTENTIAL OFFSITE CONSEQUENCES FROM ACCIDENTAL CHEMICAL RELEASES * AN OVERVIEW OF OUR ACCIDENTAL RELEASE PREVENTION PROGRAMS * A FIVE-YEAR ACCIDENT HISTORY FOR ACCIDENTAL RELEASES OF CHEMICALS REGULATED BY EPA'S RMP RULE * AN OVERVIEW OF OUR EMERGENCY RESPONSE PROGRAM * AN OVERVIEW OF PLANNED IMPROVEMENTS AT THE FACILITY TO HELP PREVENT ACCIDENTAL CHEMICAL RELEASES FROM OCCURRING AND ADVERSELY AFFECTING OUR EMPLOYEES, THE PUBLIC, AND THE ENVIRONMENT 2.0 STATIONARY SOURCE AND REGULATED SUBSTANCES THIS FACILITY PROCESSES POULTRY. ANHYDROUS AMMONIA IS USED IN THE REFRIGERATION EQUIPMENT TO KEEP THE POULTRY COOL OR FROZEN DURING PROCESSING OR STORAGE. ANHYDROUS AMMONIA HAS BEEN IDENTIFIED BY THE EPA AS HAVING THE POTENTIAL TO CAUSE SIGNIFICANT OFFSITE CONSEQUENSES IN THE EVENT OF A SUBSTANTIAL ACCIDENTAL RELEASE. OUR FACILITY QUALIFIES AS A RISK MANAGEMENT PROGRAM 3 FACILITY BECAUSE WE ALSO ARE COVERED BY OSHA'S PROCESS SAFETY MANAGEMANT RULE (29 CFR 1910.119). TOXICS ANHYDROUS AMMONIA IS A TOXIC GAS REGULATED BY EPA UNDER THE CLEAN AIR ACT SECTION112(R) RISK MANAGEMENT PROGRAM (RMP) RULE. FIELDALE FARMS CORPORATION HAS ANHYDROUS AMMONIA IN VARIOUS INTERCONNECTED VESSELS, PIPING AND EQUIPMENT WHICH MAKE UP OUR AMMONIA REFRIGERATION SYSTEM. OU R REFRIGERATION SYSTEM CONTAINS IN EXCESS OF THE 10,000-POUND THRESHOULD QUANTITY AND IS REQUIRED TO COMPLY WITH 40 CFR 68 IN ADDITION TO 29 CFR 1910.119. OUR ACCIDENTAL RELEASE PREVENTION PROGRAMS AND OUR CONTIGENCY PLANNING EFFORTS HELP US EFFECTIVELY MANAGE THE HAZARDS THAT ARE POISED TO OUR EMPLOYEES, THE PUBLIC, AND THE ENVIRONMENT BY OUR USE OF THESE CHEMICALS. 3.0 KEY OFFSITE CONSEQUENCES ANALYSIS SCENARIOS EPA'S RMP RULE REQUIRES THAT WE PROVIDE INFORMATION ABOUT THE WORST-CASE RELEASE SCENARIO(S) AND ALTERNATIVE RELEASE SCENARIO(S) FOR OUR FACILITY. THE FOLLOWING ARE BRIEF SUMMARIES OF THESE SCENARIOS, INCLUDING INFORMATION ABOUT THE KEY ADMINISTRATIVE CONTROLS AND MITIGATION MEASURES TO LIMIT THE EXPOSURE DISTANCES FOR EACH SCENARIO: WORST-CASE RELEASE SCENARIO(S)--REGULATED TOXIC CHEMICALS OUR WORST CASE TOXIC RELEASE SCENARIO IS THE FAILURE OF OUR LARGEST STORAGE TANK WHEN FILLED TO THE GREATEST AMOUNT OF ANHYDROUS AMMONIA. THIS SCENARIO WOULD RELEASE 12,950 POUNDS OF ANHYDROUS AMMONIA IN 10 MINUTES TO FORM A TOXIC VAPOR CLOUD. COMPANY POLICY (ADMINISTRATIVE CONTROL) AND PRACTICES PUBLISHED BY THE INTERNATIONAL INSTITUTE OF AMMONIA REFRIGERATION (IIAR-CONSENSUS STANDARD) LIMIT THE MAXIMUM FILLING CAPACITY OF THIS TANK TO 80 PERCENT AT APPROXIMATELY 70 DEGREES F. ACCORDING TO EPA'S OFFSITE CONSEQUENCE ANALYSIS LOOKUP TABLES AND GEORGIA EPD's RMP COMP, THE DISTANCE TO THE TOXIC ENDPOINT (200 PPM) IS 1.0 MILES. THERE WERE APPROXIMATELY 536 PEOPLE LIVING WITHIN A 1.0-MILE RADIUS OF OUR PLANT ACCORDING TO THE 1990 U.S. BUREAU OF THE CENSUS. THERE ARE SEVERAL SCHOOLS, A COUNTY AIRPORT, SEVERAL BUSINESSES, RECREATION AREA, AND NUMEROUS RESIDENCES WITHIN THIS DISTANCE. WE HAVE IDENTIFIED NO ENVIRONMENTAL RECEPTORS WITHIN THIS DISTANCE. ALTERNATIVE RELEASE SCENARIO(S)--REGULATED TOXIC CHEMICALS THE ALTERNATIVE TOXIC RELEASE SCENARIO FOR OUR FACILITY IS A RELIEF VALVE FAILURE RESULTING IN A TOXIC GAS RELEASE. WE ASSUME THE 600-POUND RELEASE OF ANH YDROUS AMMONIA WOULD BE LIMITED BY APPLICATION OF PROPER EMERGENCY SHUTDOWN OPERATING PROCEDURES. THIS POTENTIAL RELEASE RESULTS IN A DISTANCE TO TOXIC ENDPOINT (200 PPM) AT 0.10 MILES (528 FEET). ACCORDING TO THE 1990 U.S. CENSUS AND RECORDED IN LANDVIEW III SOFTWARE OBTAINED FROM THE U.S. CENSUS BUREAU, APPROXIMATELY 59 PEOPLE WERE LIVING WITHIN THIS DISTANCE. THERE IS AN INDUSTRY AND NUMEROUS RESIDENCES WITHIN THAT DISTANCE. WORST-CASE RELEASE SCENARIO(S)--REGULATED FLAMMABLE CHEMICALS NOT APPLICABLE (DIESEL TANKS ON SITE ARE DOWNHILL, CONTAINED AND WOULD NOT IMPACT AN ACCIDENTAL AMMONIA RELEASE). ALTERNATIVE RELEASE SCENARIO(S)--REGULATED FLAMMABLE CHEMICALS NOT APPLICABLE (DIESEL TANKS ON SITE ARE DOWNHILL, CONTAINED AND WOULD NOT IMPACT AN ACCIDENTAL AMMONIA RELEASE). 4.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMCAL SPECIFIC PREVENTION STEPS WE TAKE A SYSTEMATIC, PROACTIVE APPROACH TO PREVENTING ACCIDENTAL RELEASES OF HAZARDOUS CHEMICALS. OUR MANAGEMENT SYSTEMS ADDRESS EACH OF THE KEY FEATURES OF SUCCESSFUL PREVENTION PROGRAMS INCLUDING: *PROCESS SAFETY INFORMATION *PROCESS HAZARD ANALYSIS *OPERATING PROCEDURES *TRAINING *MECHANICAL INTEGRITY *MANAGEMENT OF CHANGE *PRE-STARTUP REVIEW *COMPLIANCE AUDITS *INCIDENT INVESTIGATION *EMPLOYEE PARTICIPATION *HOT WORK PERMIT *CONTRACTORS AS PART OF OUR PREVENTION EFFORTS, WE HAVE IMPLEMENTED THE FOLLOWING CHEMICAL-SPECIFIC PREVENTION STEPS; 1. A PROCESS SAFETY MANAGEMENT PROGRAM UNDER 29 CFR 1910.199 THE PROCESS SAFETY MANAGEMENT (PSM) RULE. 2. AMMONIA REFRIGERATION SYSTEMS DESIGNED, INSTALLED AND MAINTAINED IN ACCORDANCE WITH INTERNATIONAL INSTITUTE OF AMMONIA REFRIGERATION (IIAR) CONSENSUS STANDARDS. 3. TRAINING, PREVENTIVE MAINTENANCE, AND OTHER SPECIFIC PROGRAMS WITHIN THE CONTEXT OF THE PSM RULE AND IIAR RECOMMENDED PRACTICE. THESE INDIVIDUAL ELEMENTS OF OUR PREVENTION PROGRAM WORK TOGETHER TO PREVENT ACCIDENTAL CHEMICAL RELEASES. OUR COMPANY AND OUR EMPLOYEES ARE COMMITTED TO THE STANDARD THAT THESE MANAGEMENT SYSTEMS SET FOR THE WAY WE DO BUSINESS, AND WE HAVE SPECIFIC ACCOUNTABILITIES AND CONTROLS TO ENSURE THAT WE ARE MEETING OUR OWN HIGH STANDARDS FOR ACCIDENT PREVENTION. 5.0 FIVE-YEAR ACCIDENT HISTORY WE KEEP RECORDS FOR ALL SIGNIFICANT ACCIDENTAL CHEMICAL RELEASES THAT OCCUR AT OUR FACILITY. WITHIN THE PAST FIVE YEARS, FIELDALE FARMS CORPORATION CORNELIA COMPLEX HAS NOT HAD AN ACCIDENT INVOLVING AMMONIA WHICH CAUSED DEATHS, PROPERTY, OR ENVIRONMENTAL DAMAGE, EVACUATIONS OR SHELTERINGS IN PLACE, 6.0 EMERGENCY RESPONSE PROGRAM WE MAINTAIN AN INTEGRATED PLAN, WHICH CONSOLIDATES ALL OF THE VARIOUS FEDERAL, STATE, AND LOCAL REGULATORY REQUIREMENTS FOR EMERGENCY RESPONSE PLANNING. OUR PROGRAM PROVIDES THE ESSENTIAL PLANNING AND TRAINING FOR EFFECTIVELY PROTECTING WORKERS, THE PUBLIC, AND THE ENVIRONMENT DURING EMERGENCY RESPONSE PLAN. IN THE EVENT OF AN EMERGENCY INVOLVING THE AMMONIA REFRIGERATION SYSTEMS, IT IS OUR POLICY TO NOTIFY BOTH THE HABERSHA M COUNTY EMA AND THE CITY OF CORNELIA FIRE DEPARTMENT. NORMALLY, WE REACH THEM BY TELEPHONE (911). WE REQUEST THEY RESPOND TO THE EMERGENCY. WE HAVE DISCUSSED THIS POLICY WITH THE FIRE DEPARTMENTS AND MEMBERS OF THE FIRE DEPARTMENTS HAVE BEEN INVITED TO VISIT OUR FACILITY. 7.0 PLANNED CHANGES TO IMPROVE SAFETY NONE |