Greenwood Packing Plant - Executive Summary
Executive Summary |
Risk Management Plan Submission
Grenwood Packing Company, Inc., as specified in 40 CFR 68.155, is the operator and owner of a meat packing facility in Greenwood, South Carolina and has determined that it is covered under the provision 112 r of the 1990 Clean Air Act Amendments. Greenwood Packing sets forth this executive summary within its Risk Management Plan. The Risk Management Plan has been incorporated within the Company's Comprehensive Environmental Management Program and will be dealt with under the management procedures set forth in that plan.
I. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES:
In this meat manufacturing and distribution facility, the Company handles ammonia (anhydrous) which is considered hazardous by EPA. Many of the same chemical parameters and properties that makes ammonia valuable as a r
efrigerant also make it necessary to observe certain safety precautions in handling ammonia to prevent unnecessary human and environmental exposure, to reduce the threat to Company employees personal health and safety as well and contractors, customers and co-workers, and to reduce the threat to nearby members of the community. It is the Company's policy to adhere to all applicable Federal Regulations and state rules, regulations and policy. Safety depends upon the manner in which we handle ammonia. With safety devices inherent in the design of this facility combined with the safe handling procedures that we use and the training of our personnel, we believe we have minimized the threat of a toxic release to the environment.
Greenwood Packing has developed accident release policies in accordance with OSHA and industry standards regarding the release of toxic chemicals within and without the plant. Appropriate employees are trained in hazardous operations and the facility's maintan
ence staff understands the designs and workings of the ammonia refrigeration system. The Company has incorporated an employee participation plan and an employee training program along with contractor procedures associated with the ammonia based refrigeration system and process.
Our emergency response system and program is based upon the Company's Risk Assessment, Process Management Program and the code under ASRAE (15-1992) for mechanical refrigeration processes. The emergency response plan includes procedures for notification of the local fire department and notification of any potentially affected neighbors.
II. THE STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED
The primary purpose of this meat processing facility is to slaughter, process, store and distribute food products to retail and wholesale customers. Ammonia is used in the refrigeration process to maintain sanitary conditions within the plant per federal regulations and to freeze and store product for distribution
and sale. Ammonia is received by truck and used solely to charge the refrigeration system. This facility has equipment and knowledgeable personnel for these tasks in addtion to access to consultants and information if needed.
The regulated substance handled at this facility is ammonia (anhydrous). The maximum amount of ammonia on site at any one time is approximately 70,000 lbs.
III. THE WORST CASE RELEASE SCENARIO AND THE ALTERNATE RELEASE SCENARIO, INCLUDING ADMINISTRATIVE CONTROLS AND MITIGATION MEASURES TO LIMIT THE DISTANCES FOR EACH REPORTED SCENARIO.
Worst case scenario. - The facility's largest vessel is located in a large engine room with limited openings to the outside environment. The largest vessel can potentially contain 18,790 lbs of ammonia. It is the policy and operational guidance to limit this vessel's actual stoarge to a maximum of 80% of full and the Company operates this tank at 60% of full capacity as a matter of procedure. For this calculation, 80%
was used. The engine room size is in excess of 33,000 cubic feet taking into libral consideration all equipment within. Approximately 3066 lbs of ammonia would be released in to the environment in a worst case release considering the mitigating effects of the building (engine room). The released quantity is assumed to all move with the prevailing wind and the release is assumed to occure in 10 minute period. The release rate is 306.6 lbs per minute.
The distance to the toxic endpoint as modeled by EPA for the worst case scenario is .7 miles.
Alternative Scenario. - The alternative scenario uses the faciliy's second largest vessel which is located outside the engine room. There are no associated mitigating effects of an interior position. The vessel could possibly contain 15,860 lbs of ammonia. It is the policy and operational guidance that this vessel shall never be filed to more than 75% of capacity. Approximately 11,895 lbs of ammonia would be released in this scenario
and it is assumed this release would take 10 minutes. The release rate would be 1189 lbs per minute.
The distance to the toxic endpoint as modeled through EPA's mathematical forumla for the alternative scenario is .22 miles.
IV. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE SPECIFIC PREVENTION STEPS.
This meat packing facility is under the OSHA Process Chemical Safety Management (29 CFR 1910.119) program and has in place programs set forth under those regulations. Further, the faciltiy has placed shut off and release control valves in case of piping leaks inside the facility in addition to sprinkler systems. The facility has in place programs for training maintenance and other appropriate employees and the refrigeration system was desigend, and is operated according to ASHREA standards and other insurance and industry guidelines. All of the Company's maintenance and refrigeration personnel have been thoroughly trained using the applicable programs and training.
V. FIVE YEAR ACCIDENT HISTORY.
The facility had a release in April of 1994 and another two in 1995 and a small release in 1998. All releases were to the interior of the plant and the April release likely resulted in no escape of vapor ammonia as it was all frozen within water. The cause of the April release was a piping failure. The cause of the 1995 releases was equipement failure. No injuries were reported and it is unknown whether any of the released ammonia traveled outside of the confines of the facility or the boundaries of the plant property.
VI. THE EMERGENCY RESPONSE PROGRAM.
This facility's emergency response program is based upon the Chemical Process Safety Plan, and the Company's Comprehensive Environmental Management Plan. The Company has a hazard contingency plan with the local LEPC and local fire and police departments have access to all pertinent information.
VII. PLANNED CHANGES TO IMPROVE SAFETY.
This facility was constructed prior to the 1960s and has
been modified and extended since that time. The buidling is in compliance with all applicable codes and regulations. The Company undertook a major maintenance and safety upgrade in 1995 and 1996 with regard to the ammonia refrigeration system and associated programs. The Company plans to continue to minimize the use of ammonia and maximize safety and environmental precuations in the future but no specific changes are planned at this time.