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) Boise, Idaho 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. IBPs management is committed to providing the resources necessary to implement this policy. Facility Description IBP, inc. operates a cattle slaughter and processing facility and a wastewater treatment pl ant at this location. Cattle are trucked to the facility and slaughtered. IBP operates rendering systems to produce dried blood, meat and bonemeal byproducts, and tallow. Support operations include a wastewater treatment system, 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, RMP. 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 complete a 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 sev eral factors including molecular weight, volatility, heat of combustion, and physical setting (urban or rural). The alternative release scenario for each covered process 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 absence of trees, hills, and structures (other than the IBP facility) in the immediate vicinity of the Boise, Idaho facility, a rural dispersion environment was assumed. Amm onia The data provided in the document Model Risk Management Program and Plan for Ammonia 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 recirculator in a 10-minute period (per EPA guidelines). This release translates to a release of 16,071 pounds of ammonia in 10 minutes or 1,607.1 lbs/min. Other assumpti ons included in the worst-case assessment are: the ammonia is a liquefied gas; recirculator is not diked; the release does not take place indoors; the nearfield dispersion environment is characterized as rural; 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 2.25 miles (3.62 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 68.5 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 68.5 pounds of air per minute correlates to a release rate of 48.6 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 48.6 lbs/min, the duration for a 500 pound release is 10.3 minutes. Other assumptions include that no active or passive mitigation measures are currently in place and a rural 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 0.14 miles (225 meters) from the release point. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The Boise, Idaho facility is governed by a se t 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 ? 40 CFR Part 264, Hazardous Waste Contingency Plan ? 29 CFR Part 119, Process Safety Management ? Section 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. Employee participation in the release prevention program is encouraged and supported by IBP management. Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the ammonia s ystem. 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. Members of IBPs emergency response team receive annual training to ensure that response actions are promptly and safely completed. Five Year Accident History IBP has not had a rel ease of ammonia from the Boise, Idaho facility that has affected the public or the environment. Emergency Response Program IBP has personnel trained in emergency response at the facility 24 hours per day, seven days per week. These personnel receive annual training on emergency procedures and response techniques. Additional information will be added to this section after discussions between IBP and off-site responders. Planned Changes to Improve Safety IBP completes a thorough review of the ammonia system 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. |