Gol Pak Holdings - Executive Summary

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Executive Summary 
Monterey Tennessee 
Description of the facility and the regulated substance: 
Perdue Farms Incorporated, founded in 1920, is the largest poultry producer in the Northeast and the third largest in the United States.  Headquartered in Salisbury, Maryland, the family owned, privately held company has operations in 14 states.  Twenty processing facilities produce about 50 million pounds of poultry products each week.  Perdue Farms also has grain storage and merchandising operations and is ranked among the top 20 largest U.S. grain companies.  Perdue also manufactures edible oils, specialty feeds, livestock feed ingredients and premium pet food ingredients.  
The Perdue Farms Monterey facility is located in Putnam County, Tennessee, East of the town of Monterey.  The facility is a poultry processing plant which employs approximately 1600 associates to receive chicken fronts, tenders, and other cut-up parts or de-boned product and properly sizes it for its Breading and Coo 
ked lines for shipment to market.  The facility normally operates 24 hours per day, 6 days per week.    
The regulated substance at the Monterey facility, covered by 40 CFR Part 68, is anhydrous ammonia (R-717). The facility utilizes anhydrous ammonia as an integral part of its refrigeration system. The refrigeration system consists of several storage vessels, compressors, condensers, piping and air handling units throughout the facility in order to maintain proper food safety temperatures.  The total quantity of anhydrous ammonia on-site is 160000 pounds distributed throughout the refrigeration components. 
Accidental release prevention and emergency response policies: 
As a concerned member of the community, the company takes the role as a responsible corporate citizen very seriously.  All Perdue facilities are operated to protect employees, contractors and the public from injury and illness, and to minimize environmental impact.  A company-wide safety and wellness program stress 
es safe work conditions and safe work practices.  Perdue's policy is to inspect, maintain and operate equipment and facilities to prevent accidents, including the release of hazardous materials; and to train employees in prevention, as well as to prepare them to respond rapidly and effectively should an accident occur.     
Perdue Farms has developed and implemented a Spill Prevention Control and Countermeasures plan (SPCC) and a Process Safety Management plan (PSM) as part of an overall chemical management program.  The program involves local managers and a wide range of senior management personnel, including the Director of Environmental Services and the Director of Safety and Security.  Additionally, Perdue conducts regular safety meetings and provides a wide variety of environmental, health and safety training to its staff.   
General accidental release prevention program: 
The Perdue Farms Monterey facility maintains a Process Safety Management Plan in accordance with the Occupati 
onal Safety and Health Administration (OSHA) regulation 29 CFR 1910.119.  The Maintenance personnel at the facility utilizes a preventative maintenance program for all the system components.  As part of the program, trained refrigeration personnel routinely inspect the refrigeration system operating parameters and conduct routine maintenance, as needed.    
Worst case release scenario: 
The predicted worst-case scenario for the refrigeration system is the catastrophic failure of the High Pressure Receiver located inside the engine room at the rear of the plant.  The vessel has a maximum storage capacity of 37,348 pounds of anhydrous ammonia.  Using equations presented in the EPA Risk Management Program Guidance for Ammonia Refrigeration (EPA 550-B-98-014) for inside releases, it has been estimated that approximately 5,229 pounds of this anhydrous ammonia would be released in 10 minutes into the atmosphere through the ventilation system of the building.  Using RMP*Comp modeling software 
, the calculated distance to the toxic endpoint is 1.3 miles affecting  residents and businesses.  The estimated population within the 1.3 mile radius is 264, based on the results of LANDVIEW III software. 
Alternative release scenarios: 
Several alternative release scenarios were considered.  A total of four release scenarios were chosen for further examination.  The five refrigeration system components that were deemed to cause a probable alternative release scenario were: 
1.) Delivery truck line rupture 
2.) Compressor PRV release 
3.) High pressure liquid (HPL) line leak on the roof 
4.) High pressure liquid (HPL) line leak in the engine room 
Alternatives #1 (delivery truck line rupture), and #4 (HPL line leak in the engine room), have similar operating pressures (150 psig), release heights (ground-level), and release rates (1,186 - 1,388 lb/min).  Resulting toxic endpoint distances were determined to be 0.83 miles and 0.87 miles for alternatives #1 and #4, respectively.  Population 
impacts for alternatives #1 and #4 were therefore 50. Alternative scenario #3 (HPL line leak on the roof) had a reduced release rate (110.8 lb/min), that resulted in a toxic endpoint distance of 0.61 miles and a population impact of 27.  Alternative scenario #2 (compressor PRV release) resulted in a relatively insignificant release rate of 12.9 lb/min, and did not result in an offsite consequence.  Toxic endpoint distances for all alternative scenarios were obtained using dispersion modeling software.  Population estimates were based on LANDVIEW III results. 
Five-year accident history: 
The Monterey facility has been operated by Fast Food Merchandisers since 1984 to 1998 and was purchased by Perdue Farms in Oct 1998 and has not had a series accident involving anhydrous ammonia that caused death, associate injuries and property or environmental damage.     
Emergency response program: 
In the event of an emergency involving our refrigeration system, the facility has a well defined  
incident command system.  The written Emergency Response program includes procedures to safely evacuate the facility, minimize and/or contain the release and notify the appropriate local fire department and LEPC officials.  We continue to train our associates on hazardous responses and awareness.  We conduct mock drills routinely.  We have discussed our response program with our local LEPC and fire department representatives.   
As part of our Risk Management Plan (RMP), Perdue Farms has developed a RMP Communications Plan.  The goals of the plan are to:  
1> Educate the public on the potential risks of regulated substances used by Perdue 
2> Respond to any concerns that RMP disclosures may cause with honest fact-based communications 
3> Be fully prepared to effectively respond to any accidental release scenario 
Proactive materials about disclosure information, how the company is prepared to deal with an incident, how the community should respond and a process for announcing that an i 
ncident has occurred are being prepared.  In addition, training and information materials for Perdue managers and employees, community officials, civic groups, media, environmental groups, emergency response personnel and the public in general will be available.         
Planned changes to improve safety:  
As part of Perdue's continual improvement philosophy, all Perdue facilities continue to identify system components and techniques that are updated.
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