Mar-Jac Poultry, Inc. - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
At Mar-Jac Poultry, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including:
* A description of our facility and use of substances regulated by EPA's RMP regulation
* A summary of results from our assessment of the potential offsite consequences from accidental chemical releases
* An overview of our accidental release prevention programs
* A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule
* An overview of our emergency response program
n overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment
STATIONARY SOURCE AND REGULATED SUBSTANCES
Our facility processes poultry. Used in our warehouse refrigeration process to cool our warehouse, anhydrous ammonia has been identified by the EPA as having the potential to cause significant offsite consequences in the event of a substantial accidental release. Our facility qualifies as a Risk Management Program 3 facility because we also are covered by OSHA's Process Safety Management rule [29 CFR 1910.119].
Our facility uses propane as an auxiliary fuel (to natural gas) to heat water and buildings. Propane in excess of 67,000 pounds has been identified by EPA as having the potential to cause significant offsite consequences in the event of a substantial release. We do not store the threshold quantity of propane.
Anhydrous ammonia is a toxic ga
s regulated by EPA under the Clean Air Act section 112(r) Risk Management Program (RMP) rule. Mar-Jac Poultry has anhydrous ammonia in various interconnected vessels, piping and equipment which make up our ammonia refrigeration system. Our refrigeration system contains in excess of the 10,000-pound threshold quantity and is required to comply with 40 CFR 68 in addition to 29 CFR 1910.119.
Propane is used as an auxiliary fuel when natural gas supplies are curtailed. Natural gas and propane are used to heat water and to heat our buildings during cold weather. The maximum amount of propane stored at our facility is less than 67,000 pounds, and our single storage tank holds significantly less than 18,000 gallons. April 20, 1999, guidance from EPA proposed exempting from the Clean Air Act section 112(r) Risk Management Program (RMP) rule propane and other flammable hydrocarbon fuels in quantities less than 67,000 pounds.
Our accidental release prevention programs and o
ur contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals.
KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS
EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario:
Worst-case Release Scenario(s) - Regulated Toxic Chemicals
Our worst case toxic release scenario is the failure of our largest storage tank when filled to the greatest amount of anhydrous ammonia. This scenario would release 14,000 pounds of anhydrous ammonia in 10 minutes to form a toxic vapor cloud. Company policy (administrative control) and practices published by the International Institute of Ammonia Refrigeration (IIAR - consensus standa
rd) limit the maximum filling capacity of this tank to 80 percent at approximately 70 degrees F. According to EPA's Offsite Consequence Analysis Lookup Tables, the distance to the toxic endpoint (200 ppm) is 2 miles. There were approximately 6,000 people living within a 2-mile radius our our plant according to the 1990 U.S. Census and recorded in LandView III software obtained from the U.S. Bureau of the Census. There are several schools, a hospital, a county airport, industrial parks, a judicial diversion center, recreation area and numerous residences within this distance. We have identified no environmental receptors within this distance.
Alternative Release Scenario(s) - Regulated Toxic Chemicals
The alternative toxic release scenario for our facility is a relief valve failure resulting in a toxic gas release. We assume the 600-pound release of anhydrous ammonia would be limited by application of proper emergency shutdown operating procedures. This potential release results
in a distance to toxic endpoint (200 ppm) at 0.19 miles (1000 feet). According to the 1990 U.S. Census and recorded in LandView III software obtained from the U.S. Census Bureau, approximately 70 people were living within this distance. There are several businesses and industrial operations, a public scale, a county airport, a judicial diversion center and several residences within that distance.
Worst-case Release Scenario(s) - Regulated Flammable Chemicals
Alternative Release Scenario(s) - Regulated Flammable Chemicals
We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention
* Process safety information
* Process hazard analysis
* Operating procedures
* Mechanical integrity
* Management of change
* Pre-startup review
* Compliance audits
* Incident investigation
* Employee participation
* Hot work permit
As part of our prevention efforts, we have implemented the following chemical-specific prevention steps:
1. A process safety management program under 29 CFR 1910.199 the Process Safety Management (PSM) rule.
2. Ammonia refrigeration systems designed, installed and maintained in accordance with International Institute of Ammonia Refrigeration (IIAR) consensus standards.
3. Training, preventive maintenance, and other specific programs within the context ofthe PSM rule and IIAR recommended practice.
These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management
systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention.
FIVE-YEAR ACCIDENT HISTORY
We keep records for all significant accidental chemical releases that occur at our facility. Within the past five years, Mar-Jac Poultry has not had an accident involving ammonia which caused deaths, property, or environmental damage, evacuations or shelterings in place.
EMERGENCY RESPONSE PROGRAM
We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan.
In the event of an emergency involving the ammonia refrigeration systems, it is our policy to
notify both the Hall County Fire Department and the Gainesville Fire Department. Normally, we reach them by telephone (911). We request they respond to the emergency. We have discussed this policy with the fire departments and members of the fire departments have been invited to visit our facility.
PLANNED CHANGES TO IMPROVE SAFETY
We plan to build an emergency dump station for ammonia to help prevent and/or better respond to accidental chemical releases.