Cagle's, Inc. - Executive Summary |
A) Accidental release prevention and emergency response policies at the stationary source. The system was designed and built in accordance with ANSI/ASHRAE 15-1992, Safety Code for Mechanical Refrigeration and ANSI/IIAR 1984 Equipment Design, and Installation of Ammonia Mechanical Refrigeration Systems or the existing 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 substance 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 mitagation 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 receiving vessel during a ten-minute period. Administrative controls to mitigate a release such as emergency shut down procedure s 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 area would find an endpoint at 1.60 miles. The alternate release scenario is based on a more realistic release from a pipe leak in the compressor room. This release 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 area would find an endpoint at 0.20 miles. 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, check valves, manual shutoffs, automatic shutoffs, interlocks, alarms and procedures, emergency power, and backup compressorhave been designed and installed to lessen the probability and severity of a release. Mitigation systems such as enclosure 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 personnel 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. A reportable quantity release occured on July 3, 1996. A pipe fracture occured in an ammonia line located on the roof of the building. Approximately 125 pounds was released during a six-hour period. The pipe run that failed was replaced with a loop system so that no ammonia remains stationary in the pipe run. This design change removed the possibility of a release resulting from similar circumstances. 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 pesonnel 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 Harris County Local Emergency Planning Committee, through the 911 emergency service, and the National Response Center (1-800-424-8802) should the release have off-site impact, a reportable quantity (RQ) is released (100 pounds), or additional assistance is otherwise required. An on-site health clinic is staffed during all production hours to attend to minor employee injuries and illnesses. Any affected employees would be seen by this clinic or transported to an emergency room should the situation warrant it. G) Planned changes to improve safety. None are planned at this time. |