Jimmy Dean Foods - Executive Summary |
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1.0 EXECUTIVE SUMMARY 1.1 Corporate Commitment Sara Lee Corporation's basic commitment to responsible stewardship of the environment, protection of the community, protection of employee health, and assurance of product safety extends to the processes covered by the new EPA Risk Management Plan (RMP) requirements. The Florence, Alabama facility of Jimmy Dean Foods of Sara Lee has developed management systems in compliance with various applicable regulations to prevent the release of regulated substances, especially in locations which may cause detrimental effects to employees, the community, or the environment. This is accomplished through a systematic evaluation of process design, process technology, operational procedures, maintenance activities, non-routine procedures, emergency preparedness, training, and several other factors. Jimmy Dean Foods has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident pre vention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release. Jimmy Dean Foods plans to meet or surpass all regulatory requirements. In the attempt to accomplish this goal, management systems at the Florence facility have been developed in such a way that the hazards are identified, understood, and controlled to prevent accidents. 1.2 Background Data The Florence facility of Jimmy Dean foods manufactures pork sausage and a variety of other meat products marketed under familiar brand names such as Jimmy Dean, Bryan and State Fair. Raw pork is received from an offsite slaughter house, cooked and packaged in both bulk and consumer quantities. Total plant production is about two million pounds of product per week. The site is located on about seventeen acres within the Florence City limits. There are about 300,000 square feet under roof. This facility has been in operation for over 50 years and currently provides more than 900 jobs to the local community. In accordance with Title 40 of the Code of Federal Regulations Chapter 68 (40 CFR 68) promulgated by the Environmental Protection Agency (EPA), Jimmy Dean Foods (JDF) submits this Risk Management Plan (RMP) for operations at their Florence, Alabama facility. 1.3 Accidental Release Prevention and Emergency Response Policy JDF is committed to protecting the health of its employees, the surrounding community, and the environment. Therefore, it is JDF's policy to maintain compliance with 40 CFR 68 as well as Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Federal Regulations, Chapter 1910, Section 119 (29 CFR 1910.119), and OSHA's Hazardous Wast e Operations and Emergency Response regulations (29 CFR 1910.120). 1.4 Stationary Sources and Regulated Substances The Florence facility operates one process that has more than a threshold quantity of a regulated substance. That process is the plant-wide ammonia refrigeration process. Low temperatures are required in the food processing areas of the plant within standards required by the United States Department of Agriculture (USDA). These low temperatures ensure quality in the final products. Anhydrous ammonia, an industry-standard refrigerant for meat processing plants, is utilized as refrigerant to maintain the food processing areas of the facility within the required range of operating temperatures. Anhydrous ammonia is the RMP regulated chemical. The refrigeration system, consisting of receivers, compressors, evaporators, condensers, recirculators, and piping, can contain quantities over the 10,000 pound threshold. This process is a Program 3 process as defined by the ri sk management program rule (40 CFR Part 68). 1.5 Worst-case Release Scenario In accordance with 40 CFR 68 Subpart B, JDF evaluated a worst-case release scenario for anhydrous ammonia using the parameters specified by the EPA. This worst-case release scenario for a toxic substance at the Florence facility of Jimmy Dean Foods is a hypothetical release of the entire contents of a +20 F ammonia recirculator vessel, which is located near the center of the facility. In accordance with RMP regulations, the entire vessel capacity of 15,800 pounds of anhydrous ammonia was assumed to be released as a gas cloud in ten minutes. Jimmy Dean Foods believes such an event to have an extremely small probability of occurrence and, thus, not of practical interest in terms of risk management and emergency response planning. Therefore, such a scenario is included in this Risk Management Plan for administrative completeness only. The Model Risk Management Program and Plan for Ammonia Refrigeration, d eveloped by Science Applications International Corporation of Houston, Texas in cooperation EPA, was used to estimate the downwind concentrations under the EPA-mandated weather conditions of 1.5 meters per second windspeed and F stability. No passive mitigation measures were considered for this hypothetical release. The model RMP predicted a maximum distance of 1.5 miles to ammonia's toxic endpoint of 0.14 mg/L. This distance assumes that the wind blows at the mandated worst-case conditions. The probability of these conditions occurring is low. More probable meteorological conditions in North Alabama, according to National Oceanic and Atmospheric Administration (NOAA) data, are a wind speed of 3.0 meters per second and D stability. Furthermore, the receivers are maintaniined at about 40% capacity during normal operations. Only during pump-down operations do the receivers have the potential to be filled to 100% of capacity. The receivers are operated in pump-down mode less th an 5% of the time during the year. When these more likely conditions are applied to the worst-case scenario, the distance to toxic endpoint is only 0.3 miles. This change represents a 96% decrease in impacted area and a 99% decrease in impacted population from the mandated conditions. 1.6 Alternative Release Scenario A more realistic release scenario (alternative scenario) was developed that took into consideration the 50-year history of operation and experience of the facilty. Also considered in the alternate scenario were the hazards identified in the process hazard analysis (PHA) conducted under the OSHA PSM regulation promulgated as Title 29 of the Code of Federal Regulations Chapter 1910, Section 119 (29 CFR 1910.119). The alternate release scenario identified by JDF consisted of a release of ammonia from a 0.25-inch diameter hole in the pipeline from the high-pressure receiver. Anhydrous ammonia is unloaded from tank trucks into a high-pressure receiver, which is locat ed on the No. 1 Engine Room dock near the center of the plant. From the high-pressure receiver, ammonia is pumped into the process. It was estimated that 10 minutes elapse before the leak is detected and stopped. Under these conditions, 900 pounds of ammonia are released at the rate of 90 pounds per minute. Distance to the EPA toxic endpoint of 0.14 mg/L was estimated to be 0.1 mile. This distance was estimated utilizing the Model Risk Management Program and Plan for Ammonia Refrigeration. Science Applications International Corporation of Houston, Texas prepared this model plan in cooperation with EPA. No mitigation of the release was considered, because the risk management program rule mandates that release of gases liquefied by pressure must be treated as gases. 1.7 Accidental Release Prevention Program To prevent and mitigate accidental releases of anhydrous ammonia, JDF has implemented precautionary measures. These precautionary measures comply with OSHA's PSM regulatio ns and were evaluated and engineered for anhydrous ammonia releases. Examples of some of the controls installed to prevent catastrophic releases of ammonia are vents, pressure relief valves, backup pumps, manual and automatic shutoffs, ammonia leak detection system, and electrical distribution system grounding. In addition, JDF has trained approximately 16 employees to respond to potential ammonia releases (Process Safety Team). JDF has developed Standard Operating Procedures (SOP) for all employees and contractors that have contact with the ammonia refrigeration system. These procedures incorporate safety measures. Safety procedures were developed by refrigeration system operators and are reviewed annually by a highly qualified SOP review team. JDF encourages employee participation in development of the control measures used at the plant by means of monthly Process Safety Team meetings. Any changes to the operating procedures are communicated to affected employees following w ritten management of change procedures established by JDF. JDF understands that maintaining the refrigeration system in good working order is essential to preventing accidental releases. Therefore, JDF has implemented a preventive maintenance program. The preventive maintenance program is managed and documented to ensure that regular maintenance occurs on the system. Also, to ensure the mechanical integrity of critical refrigeration system components, ultra-sonic testing on piping, headers and vessels is conducted. To ensure that JDF's control measures are effective in maintaining the safe operation of the plant, regularly scheduled audits are performed on the ammonia refrigeration system: * In accordance with the PSM program, JDF conducts detailed PSM compliance audits every three years. Each audit incorporates review of process safety information, process hazard analysis, operating procedures, training programs, system mechanical integrity, management of change, pre-start up re view procedures, compliance audit procedures, incident investigation procedures, employee participation programs, hot work permit procedures, and contractor safety procedures. * The following audits by outside agencies are conducted: * The local fire department audits JDF on an annual basis. * The USDA on a daily basis audits JDF. * The facility's insurance carrier conducts independent audits on a semi-annual basis. 1.8 Five-year Accident History Jimmy Dean Foods has an outstanding record of accident prevention. This good record is demonstrated by the fact that over the past five years there have been no accidental releases of anhydrous ammonia that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. 1.9 Emergency Response Program Jimmy Dean Foods maintains a comprehensive written emergency response program to protect plant workers, the g eneral public and the environment. The program includes plans and procedures for responding to a wide range of events caused either naturally or accidentally that have the potential to result in a release of a regulated substance. The JDF emergency response program utilizes the Incident Command System (ICS) which parallels the National Interagency ICS. This is an "all risk" system developed for on-scene management of any emergency event. The functional design of the ICS minimizes the impact of personnel changes upon the emergency plan. The emergency response program is updated when necessary, based on modifications made to the plant processes or facilities. In addition, the plant has an emergency preparedness program that addresses maintenance; inspection and testing of response equipment as well as instructions and training that govern use of this equipment. The overall emergency response program is coordinated with the Local Emergency Planning Committee (LEPC). This coordinati on consists of periodic meetings of the committee. The committee is comprised of emergency response officials from the public sector, local government officials, and industry representatives. JDF has around-the-clock communications with the LEPC to ensure notification in event of an incident as well as facilitating a quick response. JDF's emergency response program is contained in a written plan. This plan is communicated to affected employees and to appropriate off-site agencies. JDF has trained approximately 16 employees to respond to accidental ammonia releases. These employees are trained in accordance with 29 CFR 1910.120, OSHA's Hazardous Waste Operations and Emergency Response regulations according to their duties and function. They receive initial training and annual update training thereafter. As an additional measure, JDF arranged emergency response assistance with the local Fire Department. 1.10 Planned Changes to Improve Safety Ammonia refrigeration is a mature i ndustry employing known technology. Yet, the plant remains abreast of current innovations that improve safety. To this end, the facility is an active member of International Institute of Ammonia Refrigeration (IIAR) and in Muscle Shoals Safety & Health Association. This involvement enables the facility to learn and implement the most modern safety system improvements as they emerge within the ammonia refrigeration industry. Some of the most recent improvements include strategic location of ammonia controls away from employees, ultra-sonic testing of mechanical integrity of the ammonia piping, headers and vessels, and computer based techniques for automated control systems, management systems, and training. |