Cagle's, Inc. - Executive Summary |
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A) Accidental release prevention and emergency response policies at the stationary source. This system was designed and installed to meet the ANSI/ASHRAE 15-1992 Safety Code for Mechanical Refrigeration and the ANSI/IIAR 1984 standard, Equipment Design, and Installation of Ammonia Mechanical Refrigeration Systems or the exsisting code at the time of installation. Trained Refrigeration Technicians are available to respond to any situation requiring emergency actions. B) The stationary source and regulated substances handled. This process is a closed loop mechanical refrigeration system utilizing ammonia as the refrigerant. C) The worst-case scenario and alternate release scenario including administrative controls and mitigation measures to limit the distance for each reported scenario. The worst-case scenario is based on the loss of the entire contents of the largest ammonia receiving vessel during a ten-minute period. The release would be mitigated by the building structure. Ad ministrative controls to mitigate a release such as emergency shut down procedures have been developed, and the operators have been trained on those procedures. This scenario is required by EPA to assume unfavorable atmospheric conditions such as a wind speed of 1.5 meters/second and an atmospheric stability class of F. The affected zone would find an endpoint at 0.80 miles. The alternate release scenario is based on a more relistic release from a pipe leak inside the compressor room. This release also would be mitigated by the building structure and the emergency shut down procedures which have been developed and implemented. This scenario assumes more realistic atmospheric conditions such as a wind speed of 3.0 meters/second and an atmospheric stability class of D. The affected zone would find an endpoint at 0.10 miles. With the prevailing winds, the endpoint would not extend beyond the site property boundary. D) The general accidental release prevention program and chemical specific prevention steps. This facility has adopted a Level 3 Prevention Program. A Process Hazard Analysis (PHA) was conducted using the What If/Checklist method. Process controls including relief valves, manual shutoffs, automatic shutoffs, alarms and procedures, backup compressor, and rupture disks have been designed and installed to lessen the probability and severity of a release. Mitigation systems such as enclosure and sprinklers have been designed and installed to lessen the severity of a release. Operating procedures, including emergency operating procedures, have been developed, and operators have been trained on those procedures. Process area monitors have been installed to alarm in case of a release in order to alert response pesonnel and lessen the severity of a release. Maintenance procedures have been developed and implemented to ensure the mechanical integrity of the equipment. Compliance audits are conducted to ensure full implementation of the Prevention Program. E ) The five year accident history. Cagle's, nc. has operated this facility only since November of 1997. There have been no accidental releases to report. F) The emergency response program. The plan calls for production employees to evacuate the building in the event of a release that warrants evacuation in response to training received to comply with 29 CFR 1910.38. Refrigeration personnel have been trained to respond and stop a leak in the ammonia system as required by 29 CFR 1910.120 (q). The plan calls for coordination with the Fulton County Local Emergency Planning Committee, the Atlanta-Fulton County Emergency Management Agency, through the 911 emergency service, and the National Response Center (1-800-424-8802) should the release have an off-site impact, a reportable quantity (RQ) is released (100 pounds), or additional assistance is otherwise required. A nearby occupational health clinic has been contracted to attend to minor employee injuries and illnesses. Any affected e mployees would be seen by this clinic or transported to an emergency room shoud the situation warrant it. G) Planned changes to improve safety. None are planned at this time. |