Hunter Farms - High Point Division - Executive Summary |
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EXECUTIVE SUMMARY Background Data In accordance with Title 40 of the Code of Federal Regulations Chapter 68 (40 CFR 68) promulgated by the Environmental Protection Agency (EPA), Hunter Farms Dairy (Hunter Farms) submits this Risk Management Plan (RMP) for operations at their High Point, North Carolina facility. Hunter Farms operations include the processing of dairy products for public consumption. Hunter Farms has been in operation since 1917 and has been at this facility for over 8 years providing quality dairy products and over 130 jobs to the local community. Dairy production has occurred at this facility for over 50 years. Accidental Release Prevention and Emergency Response Policy Hunter Farms is committed to protecting the health of its associates, the surrounding community, and the environment; therefore it is Hunter Farms' policy to maintain compliance with 40 CFR 68 as well as Occupational Safety and Health Organization (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 Operations and Emergency Response regulations (29 CFR 1910.120). Stationary Sources and Regulated Substances Hunter Farms is subject to section 112(r) of the Clean Air Act because ammonia, a regulated substance, is present at the facility in amounts greater than 10,000 pounds. Hunter Farms is required to maintain low temperatures in the dairy processing areas of the facility that are within standards required by the Federal Drug Administration (FDA) to ensure quality in the delivered products. Hunter Farms uses anhydrous ammonia (the 112(r) regulated substance) as a refrigerant to maintain 75,900 ft2 within the required range of operating temperatures. Anhydrous ammonia is a typical refrigerant for dairy processing. Hunter Farms' refrigeration system consisting of receivers, accumulators, compressors, evaporators, condensers, and piping can contain an oper ating capacity of 32,100 pounds of anhydrous ammonia. Worst Case Release Scenario As required by 40 CFR 68 Subpart B, Hunter Farms has evaluated a worst-case release scenario for anhydrous ammonia using the parameters specified by the EPA. Hunter Farms' worst-case release scenario is the rupture of the largest single receiver (2,200 gallons) when filled to 100% capacity (there are no engineering controls on the receivers) over a 10-minute period. Using the EPA's RMP*Comp program, the maximum distance to the toxic endpoint is 1.2 miles. The worst-case release scenario was developed following EPA regulations and is not considered to be a likely release scenario. During normal operations, Hunter Farms maintains the receivers at 20-30% capacity. 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 than 1% of the time during the year. Alternative Release Scenario A more realistic r elease scenario (alternative release) was developed by Hunter Farms taking into consideration the 9-year history of operation's experience and the hazards identified in the process hazard analyses (PHAs) conducted under the Occupational Safety and Health Organization (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Federal Regulations Chapter 1910, Section 119 (29 CFR 1910.119). The most likely release scenario identified by Hunter Farms would be a release caused by a >-inch flange gasket failure in an ammonia vapor line. In developing the release parameters of this alternative scenario, Hunter Farms considered the most common gasket size and the average response time of the community's Hazmat team. Using EPA's RMP*Comp program, the maximum distance to the toxic endpoint is 0.10 miles. Accidental Release Prevention Program The ammonia refrigeration system is designed and constructed in accordance with ANSI/IIAR 2-1992 Standard for Equipment, Design, And Installation of Ammonia Mechanical Refrigerating Systems. To prevent and mitigate accidental releases of anhydrous ammonia, Hunter Farms has implemented several precautionary measures. Hunter Farms has developed and implemented a PSM program pursuant OSHA regulations and as such, has evaluated the system for the potential of anhydrous ammonia releases. Some of the controls installed to prevent catastrophic releases of ammonia are process equipment (pressure relief valves, rupture disks, purge system, backup pumps, and manual shutoffs) and automated controls (automatic shut-offs, interlocks and ammonia leak detection system). In addition, Hunter Farms has spent time with the local Fire Department who would respond to potential ammonia releases and the Fire Department has toured the facility to become familiar with the location of the system equipment, valves and emergency shut-offs. Hunter Farms has developed standard operating procedures (SOPs), that incorporate saf ety measures into the procedures. for all associates and contractors that have contact with the ammonia refrigeration system. These safety procedures were developed by refrigeration system operators and are reviewed on an as-needed basis. Process safety information for the refrigeration system is reviewed anytime there is a change in the process or SOP. Hunter Farms requires associate participation in development of overall safety measures used at the plant by means of company newsletters, total quality management teams and training sessions. Pursuant to written management of change procedures established by Hunter Farms, any changes to the operating procedures are to be communicated to affected employees. Hunter Farms understands that maintaining the refrigeration system in good working order is essential to preventing accidental releases; therefore Hunter Farms has implemented a preventative maintenance program. The preventative maintenance program is scheduled, documented and ma naged by the Chief Engineer and the Maintenance Manager to ensure that regular maintenance occurs on the system. Also, to ensure the mechanical integrity of critical refrigeration system components, x-ray corrosion testing is conducted every five years. To ensure that Hunter Farms' control measures are effective in maintaining the safe operation of the plant, regularly scheduled audits are performed on the ammonia refrigeration system: 7 In accordance with the PSM program, Hunter Farms conducts detailed PSM compliance audits every three years that incorporates review of process safety information, process hazard analysis, operating procedures, training programs, system mechanical integrity, management of change, pre-start up review procedures, compliance audit procedures, incident investigation procedures, employee participation programs, hot work permit procedures, and contractor safety procedures. 7 In addition, Hunter Farms is audited by the parent company's (Harris Teeter) hol ding company's (Ruddick Corporation) Corporate Environmental Manager and Corporate Safety Manager on an annual basis. 7 Hunter Farms' insurance carrier also conducts independent audits on an annual basis. 7 The NCDA audits the facility on an annual basis. 7 The FDA audits the facility on a random basis. Five-Year Accident History Over the last five years, Hunter Farms has experienced an accidental off-site release of anhydrous ammonia from the ammonia refrigeration system. On Monday, October 16, 1995 at approximately 12:30 am the High Point Fire Department responded to a report of an ammonia leak. Upon arrival at the facility the fire department evacuated three blocks of residential area and moved 71 individuals to a local church. Three or four of the residents elected to go to the hospital. The release seemed to have been caused by the disengagement of the main switchgear breaker which caused the condensers to shutdown and cause a high pressure situation. The hig h pressure relief valve vented ammonia to the atmosphere to stabilize the system. The problem with the breaker has been resolved by installing safety control devices within the system. Emergency Response Program Hunter Farms has documented emergency response procedures in two documents entitled Special Situation Manual and Emergency Evacuation Program in order to facilitate response efforts in the event of an on-site or off-site anhydrous ammonia release. Included in the documents are measures to be taken internally by Hunter Farms as well as measures to be taken by off-site response agencies. Hunter Farms has no on-site personnel to respond to accidental ammonia releases. Personnel that work on the ammonia system receive initial training and annual update training every three years or as needed reviewing safe work practices. These associates are also trained in the proper use of respirators and receive an annual fit test. To assure that the local governmenta l response agencies are familiar with Hunter Farms' emergency response procedures, Hunter Farms has met with the local fire department. To plan for an ammonia release with off-site effects, Hunter Farms includes procedures/equipment to passively mitigate the release, procedures to inform local response agencies, transportation maps for response agencies, evacuation route maps, and procedures for public communication. In addition to the local response agencies, Hunter Farms has arranged emergency response assistance with a local clean-up contractor. In the event of an anhydrous ammonia release with off-site effects, the general public will be warned using the following methods: 7 Broadcast message via the Guilford County Central Dispatch 7 Police and fire vehicles equipped with public address systems, and 7 Door-to-door notification of residents (if time permits). Planned Changes to Improve Safety As a result of Hunter Farms initial process hazard analyses, several changes are planned at the facility to improve safety and prevent anhydrous ammonia releases. These changes are scheduled to be implemented by September 2000 and include improvements to operating procedures, and preventative maintenance program, increased protection of ammonia equipment (e.g., guarding), increased ammonia safety training, improvements to security and formalizing inspections. |