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, inc. (IBP) Council Bluffs, Iowa 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 OSHAs 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 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. This plan covers all IBP owned activities at this facility. IBPs management is committed to providing the resources necessary to implement this policy. Facility Description IBP operates a pork pr ocessing facility at this location. Hog products are trucked to the facility and fabricated. IBP operates rendering systems for pork byproducts, lard and grease. Support operations include cold storage 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, volatil ity, 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 Council Bluffs, Iowa facility, an urban dispersion environment was assumed. Ammonia The data provided in the document Model Risk Management Program and Plan for A mmonia Refrigeration (May 1996) was used to estimate the toxic endpoint distance for the worst-case and alternative ammonia release scenarios. The EPAs RMP Off-site Consequence Analysis Guidance (May 1996) was not used to determine the toxic endpoint since it classifies ammonia as a neutrally buoyant gas. 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 #1 control pressure receiver in a 10-minute period (per EPA guidelines). This equals a release of 13,995 pounds of ammonia in 10 minutes or 1,399.5 lbs/min. Other assumptions included in the worst-case assessment are: the ammonia is a liquefied gas; the #1 control 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 1.37 miles (2.21 kilometers) before dispersing to the endpoint concentration of 201 ppm. The selected alternative-release scenario for the ammonia systems is a release from a relief valve due to overpressure of a compressor unit. The largest relief valve in the system was used in this scenario. The largest relief valve has a relief rate of 431 pounds of air per minute. As a matter of convention, the specified release rate of any relief valve is always in pounds of air per minute. The release rate of 431 pounds of air per minute correlates to a release rate of 305.9 pounds of ammonia vapor per minute. This release rate was applied to a release from the ammonia header on top of the building. The ammonia refrigeration document provides calculated endpoint distances for typical meteorological conditions (3 m/s wind speed, D atmospheric stability, 50% relative humidity). It has been determined, through a review of IBPs operational history, that the total release would likely be 500 pounds of ammonia. Based on the release rate of 305.9 lbs/min, the duration for a 500-pound release is 1.6 minutes. Other assumptions include that no active or passive mitigation measures are currently in place and an urban dispersion environment in the nearfield. The results of the alternative-release scenario for an ammonia release indicates that the endpoint concentration of 201 ppm is reached at 0.22 miles (360 meters) from the release point. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The Council Bluffs, Iowa facility is governed by a set of OSHA and USEPA regulations that require planning a nd 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 ? 40 CFR Part 264, Hazardous Waste Contingency Plan ? 29 CFR Part 119, Process Safety Management ? 40 CFR Part 302, Emergency Planning and Community Right-to-Know Act (EPCRA) The key concepts in IBPs release prevention program are employee participation, appropriate design and maintenance of equipment, and appropriate training of all employees. IBP has developed and documented these elements in their process safety management plan (PSM). The PSM plan is incorporated with this document by reference. Employee participation in the release prevention program is encouraged and supported by IBP management. Key personnel are respo nsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the ammonia systems. IBP employees are also members of the facility emergency response team. IBP 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 maintains a computerized program of maintenance activities to ensure that key systems are maintained appropriately to minimize the risk of a release. IBP 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 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 History IBP has not had a release of ammonia from the Council Bluffs, Iowa facility that has affected the public or the environment. Emergency Response Program IBP personnel will provide access to the facility to the Council Bluffs Fire Department in the event of an incident requiring off-site response. IBP personnel may assist the Council Bluffs Fire Department in a non-responding capacity. Planned Changes to Improve Safety IBP completes a thorough review of the ammonia systems each time a design change is implemented. IBP is committed to using these methods to identify and implement ways to improve the safety of these systems. |