Dixie Cold Storage - Executive Summary
CON AGRA RISK MANAGEMENT PROGRAM DOCUMENT |
This document contains all required information in order to meet 40 CFR 68 "Risk Management Program" including an Executive Summary and RMP data elements (68.155 through 68.185).
1.0 Release Prevention and Emergency Response Policies
The Con Agra Poultry Company (CPC) facility in Shreveport, Louisiana has a good record in preventing releases of anhydrous* ammonia. The CPC facility has a thorough emergency training program for on-site emergency responders. The facility has implemented CPC's HAZWOPER plan (emergency response program) which is a plan designed for the safety of its employees', the community and the environment. This detailed emergency response program includes procedures for handling an emergency - the established action plan and appropriate personnel involved in containing a hazardous release (HAZMAT team). As part of this emergency response program, CPC emphasizes a thorough training program and medica
l surveillance of the HAZMAT team prior to and after an incident. With the potential dangers associated with a hazardous chemical release, CPC has researched and developed safe containment and disposal procedures as well as an evaluation procedure following an emergency response. All of these components make the CPC HAZWOPER plan a thorough and comprehensive plan for release prevention and emergency response.
The emergency response policies at the CPC facility ensure that there is emergency response coverage 24 hours - 7 days per week.
*From this point in the Executive Summary, anhydrous ammonia will be synonymous with ammonia.
2.0 Process Description and Regulated Substances
CPC is a warehouse for frozen food products. The NAICS code for these processes at this facility is 49312. The plant has freezers to preserve the food products.
CPC has one regulated substance under 40 CFR 68: ammonia. Ammonia is used as a refrigerant in the freezing of products in the various areas of t
The ammonia threshold for triggering applicability to 40 CFR 68 is 10,000 pounds. The quantity of ammonia stored on-site is approximately 16,830 pounds. Thus, 40 CFR 68 is applicable to the Con Agra Poultry Company (CPC) plant in Shreveport, Louisiana.
3.0 Worst-case and Alternative Release Scenarios
Worst-Case Scenario Description
The largest potential release of ammonia could occur with a puncture in the liquid portion of the high pressure receiver located outside of the plant. Taking the specific definition of the worst-case from 40 CFR 68.25, the largest quantity of ammonia that can be stored in a vessel is in the high pressure receiver during a pumpout operating procedures. The total quantity of ammonia that can be stored in the high pressure receiver is 12,960 pounds without administrative controls. Since the facility is located in a populated area, the release would reach offsite endpoints and nearby public receptors.
Alternative Release Scenario Descript
The alternative release scenario that meets both selection criteria is an ammonia release from a >? drain valve that is left open when plant personnel draining an HPR are overcome with ammonia and leave the area before closing the valve. The drain valve is located about one foot above ground level. Administrative controls are not applicable to this scenario. Active mitigation of the release is human intervention (system shutdown at 10 minutes from the start of the release). Since the facility is located in a populated area, the release would reach offsite endpoints and nearby public receptors.
4.0 General Accidental Release Prevention Program and Chemical-Specific Prevention Steps
Con Agra Poultry Company (CPC) has developed an OSHA PSM program for their ammonia refrigeration systems. At CPC, ammonia falls under the RMP Program 3 prevention program which is identical to the OSHA PSM program. EPA has said that if the process is in compliance with OSHA PSM, then it i
s compliance with RMP Program 3. Thus, CPC's ammonia PSM has been reviewed and determined to be complete for the RMP document.
There are several aspects of the ammonia prevention program that are key:
1. The ammonia PSM program at CPC includes provisions for employee involvement, procedures for working with contractors, pre-startup safety reviews and managing change within the system. The different sections of the PSM document detail employee participation (hazard analysis team), process safety information, process hazard analysis (PHA - what-if/checklist), operating procedures, training, mechanical integrity, hot work permits, management of change, incident investigation, compliance audits and emergency planning and response (HAZWOPER plan). The plant, therefore, maintains good training, certification, and employee awareness of operating procedures.
2. CPC has researched information pertaining to the properties and hazards of ammonia and sought professional assistance from exp
erts in the ammonia refrigeration industry. Block flow diagrams and P&ID's have been developed and are updated as the ammonia refrigeration system audits are completed.
3. CPC has established a hazards analysis team (comprising of plant employees) responsible for updating existing operating procedures for the refrigeration system and also verifying and documenting the mechanical integrity of the system.
4. In the event of a catastrophic release or an incident which could have resulted in a catastrophe, investigations will be undertaken (this is a policy of the PSM document). Necessary preventative measures will be taken to reduce the risk of incident reoccurrence.
5.0 Five-year Accident History
The review of CPC's accident history includes the following range of dates: June 22, 1994 - June 21, 1999. According to 40 CFR Part 68.42(a), there have been no accidental releases at this facility.
6.0 Emergency Response Program
As mentioned previously, the CPC facility has developed a
n OSHA hazardous substance emergency response program called HAZWOPER. The HAZWOPER document contain detailed procedures for: 1) pre-emergency planning and coordination; 2) personnel roles and lines of authority; 3) training; 4) communication; 5) emergency recognition and prevention; 6) safe distances and places of refuge; 7) site security and control; 8) emergency alerting and response; 9) ammonia decontamination; 10) emergency medical treatment and first aid; 11) critique of response and follow-up; 12) personal protective and emergency equipment; and 13) medical surveillance.
CPC's emergency response plan (HAZWOPER) is a detailed document which discusses the role of employees and management in an emergency situation. All emergency response personnel undergo training and records of this training are maintained and updated on site. The plan outlines specific procedures for evacuations, incident alarms and alerting. Depending upon a given situation, the Fire Department will be calle
d to provide back-up emergency responders and equipment. The Fire Department will be called for all fire related emergencies. The incident commander has ultimate control of implementation of the emergency response plan.
7.0 Planned Changes to Improve Safety
Based on the completed Process Hazard Analysis (PHA) for ammonia, a list of action items were developed and their status monitored to ensure that implementation was accomplished.