Equity Group - North Carolina Division - Executive Summary |
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I. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICY: It is the written policy of Keystone Foods Corporation to maintain a comprehensive safety and health program in each plant. This comprehensive safety program includes hazcom, physical hazards, powered vehicles, PPE, hearing protection, respiratory protection, emergency egress, confined space, and emergency response programs. The program details procedures that are to be implemented and assignment of resposible parties should there be a release of highly hazardous chemical. All safety program information is reviewed annually and a copy of the emergency resonse program is sent to the local Fire Department/ LEPC for review and comment. The Company provides emergency responder "level A" to members and supervisors of the emergency response team. Equity Group - NC Divison also maintains an OSHA PSM program with current maintenance and operating procedures for the single on-site ammonia refrigeration system. Mechanical integr ity of the ammonia system is assured with a computerized preventative maintenance/ parts tracking program. II. DESCRIPTION OF THE FACILITY AND HIGHLY HAZARDOUS CHEMICALS HANDLED: Equity Group - NC Division is a poultry further processing plant located on an approximately 10 acre site. The processing plant is a two story building used to house mixing, conveying, coating, frying, freezing, packaging and warehousing facilities. The product (processed chicken meat) requires refrigeration for processing and storage.Anhydrous Ammonia is used as the refrigerant for the large automated freezers used in the process. Freon refrigerant is used in other area and raw material storage refrigeration and cooling. There is 13000 pounds of anhydrous ammonia contained in the system. III. THE WORST CASE RELEASE SCENARIOS AND THE ALTERNATIVE RELEASE SCENARIO: The worst case release scenario has been determined through materials balance and process hazard analysis (RMP-PHA) to be a rupture of the high pressure reciever (HPR) which could contain the entire system volume of ammonia. This vessel failure would release the system volume into the engine room that is open to atmosphere and release the entire system volume to atmosphere on the plant site with an offsite impact. ALOHA/MARPLOT was used for the dispersion model. The alternate release scenario was determined from an RMP-PHA. The Pump Reciever Unit (PRU) holds 6600 pounds of ammonia, the largest volume under normal operating conditions, at the normal processing refrigerant level of 69%. It is conceivable that the vessel could rupture at a nozzle attachment releasing a known quantity of ammonia refrigerant to the engine room which is open to atmosphere. ALOHA/MARPLOT was used for the dispersion model. Based on available technical information no passive or active mitigation was considered. IV. THE GENERAL ACCIDENTAL RELEASE PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS: The accidental release program is depende nt on the plant maintaining good mechanical integrity through application of its computerized preventative maintenance (PM) program. Preventive maintenance scedules and procedures were determined following equipment manufacturer's guidelines and industry (IIAR) trade associattion recommendations. This information was incorporated into the plant PMS computer preventative maintenance program. The plant has installed a controlled purge system in the event of a catastrophic fire to allow a controlled release of ammonia from the system and prevent a possible explosion in a sudden vessel failure due to large scale fire exposure. Ammonia detectors are installed in process areas and on remote safety vents to alert the security and maintenance personnel that a release is in progress and to allow timely restoration of containment. There has been no release of any kind to date. All safety relief valves are installed in tandem. V. FIVE YEAR ACCIDENT HISTORY: There have been no accidents or i ncidents involving the ammonia refrigeration system since it was installed in September 1994. VI. THE EMERGENCY RESPONSE PROGRAM: Equity Group - NC Division has a written safety program designed to identify, evaluate and control safety and health hazards and provides for emergency response in the event of a hazardous chemical spill. The site specific safety and health program has an organizational structure headed by the Plant Manager, a comprehensive workplan, a training program to train employees in recognizing and abating safety and health hazards before they are required to begin a new job assignment, medical surveillance of employees, standard operating procedures for all equipment in emergency situations, and written communication of safety and procedural information between the plant and contract personnel. Initial and annual refresher training is conducted along with medical surveillance examinations for all HazMat team members. Anhydrous ammonia is the only listed highl y hazardous chemical on the plant site. It remains in a closed loop system, therefore theree is no waste. VII. PLANNED CHANGES TO IMPROVE SAFETY: Additional ammonia vapor monitoring points will be added to the site. The manual vent system will be protected from physical damage in the parking lot. Additional labelling will be added to the piping system in the plant mezzanine pipe runs. The xisting computer monitoring and data logging system will be updated in January 1999. |