Longmont Foods - Executive Summary |
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EXECUTIVE SUMMARY 1.0 RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Longmont Foods facility in Longmont, Colorado has a good record in preventing releases of anhydrous* ammonia. As part of their release prevention program, the plant has a thorough preventative maintenance program. More information about the prevention program is discussed in Section 4.0 of this Executive Summary. The facility has implemented an Emergency Planning Action and Response Plan which is to ensure 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 an ammonia release - HAZMAT Team. As part of this program, there is emergency response training and medical surveillance of the HAZMAT team prior to and after an incident. All of these components make the Emergency Planning Action and Response Plan a thorough and comprehen sive plan for release prevention and emergency response. The emergency response policies at the Longmont Foods 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 Longmont Foods slaughters and debones turkeys and prepares various meats from them. The NAICS code for the processes at this facility is 311615. Many areas of the plant are refrigerated to preserve the meat products. Longmont Foods has one regulated substance under 40 CFR 68: ammonia. Ammonia is used as a refrigerant in the refrigeration of the products in the various areas of the plant. The ammonia threshold for triggering applicability to 40 CFR 68 is 10,000 pounds. The total quantity of ammonia stored in the refrigeration process is approximately 61,511 pounds. The process exceeds the threshold quantity of 10,000 pounds as set by 40 CFR 68 and thus is regulated by the Risk Management Program. 3.0 WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS The ammonia refrigeration system has associated hazards that can potentially affect on-site employees and the general public off-site if there is a release from the system. Described below are the associated hazards and the worst-case and alternative release scenario for the regulated chemical. Though there may be other scenarios possible, EPA only requires that one worst-case and one alternative scenario be reported for each regulated chemical. Ammonia is classified as a Group 2 Refrigerant per ASHRAE Standard 34-1989. The dominant characteristic of this chemical is its toxicity. It is a self-alarming chemical by its distinctive pungent odor. Due to this odor, persons exposed to ammonia vapor will not voluntarily stay in areas of even small concentrations. Ammonia will burn at a very narrow and high range of concentrations accompanied with a high ignition temperature. Although ammonia is not poisonous, it is corrosive to human tissue. Ammonia is readily absorbed into the moisture of the skin and, at high concentrations, can cause severe burns. The risks to persons in an accidental release of ammonia include: 1. Corrosive attack of skin and other tissue (including lung tissue) 2. Freezing of skin and other body tissue when contacted by liquid ammonia 3. Eye contact Below is a description of the release scenarios for ammonia and their off-site consequences: 3.1 Worst-Case Scenario Description One worst-case scenario has been developed for the Longmont plant. The largest potential release of ammonia would occur with a two and one-eighth inch diameter puncture in the liquid portion of the high pressure receiver. Taking the specific definition of the worst-case from 40 CFR 68.25, the vessel that can store the largest quantity of ammonia is the high pressure receiver. The total quantity of ammonia that can be stored in the high pressure receiver is 36,248 pounds. Administrative and passive controls are not applicable to this scenario. It is assumed that the entire 36,248 pounds is released into the atmosphere. The release rate is 3,624.8 lb./min. For the worst-case release, regulations dictate that the release height is at ground level. Under Section 68.25(c)(1), a regulated toxic substance such as ammonia that is normally a gas at ambient temperature and handled as a liquid under pressure shall be considered to be released as a gas over a 10 minute period. Thus, ammonia's physical state in the worst-case scenario is a gas. Since this facility is located in a populated area, the worst-case release scenario distance-to-endpoint will reach off-site receptors. 3.2 Alternative Release Scenario Description The alternative release scenario is an ammonia release from a gasket leak on the high pressure receiver. The orifice is assumed to have a diameter of one-eight inch, and is located eight feet above ground level. Ad ministrative and passive controls are not applicable to this scenario. Active mitigation of the release is human intervention. Since this facility is located in a populated area, the alternative release scenario distance-to-endpoint will reach off-site receptors. 4.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Longmont Foods has developed an OSHA Process Safety Management (PSM) program for their ammonia refrigeration system. At Longmont Foods, 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 is compliance with RMP Program 3. Thus, Longmont Foods' ammonia PSM system has been reviewed and the PSM system elements are being implemented for the RMP. Listed below are the key aspects of the ammonia prevention program: The plant uses a Computerized Maintenance Management System (CMMS) for control scheduling and accom plishment of preventative maintenance on components of the refrigeration system. The scope of preventative maintenance (PM) and testing/inspection (T/I) for refrigeration components is based on individual vendor recommendations and generally accepted engineering practices with regard to types of preventative maintenance and inspections and their recommended frequencies. The plant has created work tasks for each type of PM and T/I associated with the refrigeration system. These tasks are included on the individual work order generated by the CMMS. This system ensures that each operator/mechanic is aware of the pertinent safety precautions required for a PM procedure as well as the step-by-step actions required to complete the procedure. The operator/mechanic and their supervisor sign off the completed work order. Specific results of each PM and T/I procedure are recorded on the work order. In the event a PM or T/I procedure is not completed satisfactorily, the operator/mechanic n otes it on the work order, and a follow-up work order is generated to address the specific deficiency. 5.0 FIVE-YEAR ACCIDENT HISTORY The review of Longmont Foods' accident history includes the following range of dates: June 21, 1994 - June 21, 1999. According to 40 CFR Part 68.42(a), there has been one accidental release at this facility. 6.0 EMERGENCY RESPONSE PROGRAM As mentioned previously, the Longmont Foods facility has developed an emergency response program called Emergency Planning Action and Response Plan. This document was developed in accordance with 29 CFR 1910.38, 29 CFR 1910.120, and 29 CFR 1910.119. The HAZMAT Program describes procedures for the response to an ammonia release. This section contains specific procedures for: pre-emergency planning and coordination with outside parties; personnel roles and lines of authority; emergency recognition and prevention; HAZMAT communication; HAZMAT training; site security and control; air monitoring; evacuation routes and procedures; decontamination; emergency medical treatment; and personal protective clothing and emergency equipment. The Emergency Action Plan consists of all notifications and plant evacuation procedures in the event of an ammonia release. The purpose of this plan is to summarize the existing policies, procedures, and plans of action to protect the team members of this facility from dangers associated with these emergencies and provide for the notification and proper evacuation of plant personnel in event of an emergency. Furthermore, the purpose of this plan is to mitigate and prevent releases of ammonia from reaching the offsite public. 7.0 PLANNED CHANGES TO IMPROVE SAFETY Based on the completed Process Hazard Analysis (PHA) for ammonia, a list of action items to improve safety was developed and their status monitored to ensure that implementation was accomplished. An example of recommendations from the PHA are as follows: Additional safety improvements include a new ammonia detection system, pressure vessel replacement, improved engine room ventilation, upgraded relief valve vents, and automated king valves. The existing ammonia detection system is unreliable and will be replaced and configured to operate the upgraded ventilation system. The plant also plans to replace all non-rated vessels in the future with National Board registered vessels. Colorado statutes don't require NB registered vessels, but the plant plans to install registered vessels in place of those existing vessels which are not registered. Furthermore, based upon modeling assessments, the facility plans to provide an enclosure for the high pressure receiver by 12/31/99. The enclosure will provide mitigation and reduce potential impact to the community. |