IBP, inc. - Executive Summary |
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EXECUTIVE SUMMARY Accident Release Prevention Program and Emergency Response Policy It is the policy of the IBP Foods, Inc. Detroit, Michigan 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 risk of a release of a hazardous material and if a release occurs, to minimize the potential impact to IBP Foods 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. IBP Foods' management is committed to providing the resources necessary to implement this policy. Facility Description IBP Foods, Inc. operates a deli and smoked meat-processing facility a t this location. Support operations include cold storage, an analytical laboratory, 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 release rate 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 factors 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. Under 40 CFR 68 Subpart B ?68.22(e), the RMP rule identifies surface roughness as a parameter to be used in the hazard assessment to determine the physical setting of the site, urban or rural. "Urban means there are many obstacles in the immediate area; obstacles include buildings or trees. Rural means there are no buildings in the immediate area and the terrain is generally flat and unobstructed." Due to the presence of trees, hills, and/or other structures in the immediate vicinity of the Detroit, Michigan facility, an urban dispersion environment was assumed. Ammonia The data provided in the document EPA's guidance document "Risk Management Program Guidance For Ammonia Refrigeration" (November 1998) was used to estimate the toxic endpoint distance for the wo rst-case ammonia release scenario. 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 typical meteorological conditions. The worst-case release scenario for an anhydrous ammonia release included a release of all the contents of the high pressure receiver number in a 10-minute period (per EPA guidelines). This release translates to a release of 6,623 pounds of ammonia in 10 minutes or 662.3 lbs/min. Other assumptions included in the worst-case assessment are: the ammonia is a liquefied gas; the high pressure receiver 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 atmospheric stability is classified as F (stable). The results of the worst-case assessment for ammonia show that the plume must travel 0.96 miles (1.55 kilometers) before dispersing to the endpoint concentration of 201 ppm. The data provided in the document EPA's guidance document "Risk Management Program Guidance For Ammonia Refrigeration" (November 1998) was used to estimate the toxic endpoint distance for the alternative ammonia release scenario. The ammonia refrigeration document provides calculated endpoint distances for typical meteorological conditions (3 m/s wind speed, D atmospheric stability, 50% relative humidity). The selected alternative-release scenario for the ammonia systems is a liquid release from a failure of a process vessel. The process vessel failure would result in a release of 1,900 pounds of ammonia in 12 minutes. Therefore, the release rate would be 165 lbs/minute. The table from the ammonia refrigeration document (Exhibit 4-5, page 4-15) was used to determine the endpoint distance for the worst-case re lease scenario. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The Detroit, Michigan 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, Accidental Release Prevention * 40 CFR Part 112, Spill Prevention, Control and Countermeasure * 29 CFR Part 119, Process Safety Management * 40 CFR Part 302, Emergency Planning and Community Right-to-Know Act (EPCRA) The key concepts in IBP Foods' release prevention program are employee participation, appropriate design and maintenance of equipment, and appropriate training of all employees. IBP Foods has developed and documented these elements in their process safety management plan (PSM). The PSM plan is in corporated with this document by reference. Employee participation in the release prevention program is encouraged and supported by IBP Foods management. Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the ammonia systems. IBP Foods employees are also members of the facility emergency response team. IBP Foods policy is to construct all new equipment, systems, and facilities to ensure the appropriate safety and release prevention systems are included from the beginning of each project. IBP Foods is committed to providing appropriate training to all employees regarding safety procedures. Each new employee is provided comprehensive safety training during their initial orientation for the facility. In addition, IBP Foods conducts regularly scheduled safety training for all employees each year. Additional training is provided to maintenance personnel for the systems they are responsible for. Five Year Accident Hi story Three OSHA recordable accidents related to the ammonia system have occurred at the facility during the five years prior to program submittal. Emergency Response Program IBP Foods has personnel at the facility 24 hours per day, seven days per week. In the event of a release of ammonia, IBP Foods will notify off-site responders. Planned Changes to Improve Safety IBP Foods completes a thorough review of the ammonia systems each time a design change is implemented. IBP Foods is committed to using these methods to identify and implement ways to improve the safety of these systems. |