KPR Hlodings, LP d.b.a. Columbia Foods - Executive Summary |
|
EXECUTIVE SUMMARY Accident Release Prevention Program and Emergency Response Policy It is the policy of the KPR Holdings, LP d.b.a. Columbia Foods (KPR) Columbia, South Carolina, facility management to implement the requirements of this Risk Management Program (RMP) in accordance with the USEPA regulations under 40 CFR Part 68 and with the corresponding regulations under OSHA's Process Safety Management (PSM) program. The objective is to minimize the risk of a release of a hazardous material and if a release occurs, to minimize the potential impact to KRP employees, the public and the environment. This objective will be accomplished by utilizing general good operating procedures, providing appropriate training to all employees, and coordinating response activities, as necessary, with the local emergency response providers. KPR management is committed to providing the resources necessary to implement this policy. Facility Description KPR operates a fresh meat processing facility at this location. Fresh meats are trucked to the facility, ground, mixed with spices, cooked, frozen, packaged, and shipped to restaurants for use in consumer food products. Support operations include cold storage, boilers, an analytical laboratory, and administrative offices. Figure 1-1 shows the location of the facility. One chemical is utilized at the facility in sufficient quantities to be subject to the requirements of 40 CFR Part 68. This chemical is ammonia and is used as a refrigerant throughout the facility. Worst-Case and Alternative-Release Scenarios RMP regulations require that each facility identify worst-case and alternative case release scenarios. EPA has defined a worst-case release as the release of the entire contents of the largest vessel that contains a regulated substance in a 10-minute period. This release rate is then evaluated using modeling techniques and/or reference tables to define the distance to a specified endpoint (concentration or overpressure). The distan ce to the endpoint is affected by several factors including molecular weight, volatility, heat of combustion, and physical setting (urban or rural). The alternative-release scenario must be one that is more likely to occur than the worst-case scenario and that reaches an endpoint off site, unless no such scenario exists. The alternative-release scenario is also evaluated to define the distance to the specified endpoint. Under 40 CFR 68 Subpart B '68.22(e), the RMP rule identifies surface roughness as a parameter to be used in the hazard assessment to determine the physical setting of the site, urban or rural. "Urban means there are many obstacles in the immediate area; obstacles include buildings or trees. Rural means there are no buildings in the immediate area and the terrain is generally flat and unobstructed." Due to the presence of trees, hills, and other structures in the immediate vicinity of the Columbia, South Carolina, facility, an urban dispersion environment was assumed. Ammonia The data provided in the document "Model Risk Management Program and Plan for Ammonia Refrigeration" (May 1996) was used to estimate the toxic endpoint distance for the worst-case and alternative ammonia release scenarios. The EPA's "RMP Off-Site Consequence Analysis Guidance" (May 1996) was not used to determine the toxic endpoint since it classifies ammonia as a neutrally buoyant gas. Since the worst-case ammonia release would involve liquid and would come from a pressurized system containing liquid, the released gas should be classified as a dense gas (a result of evaporative cooling). The ammonia refrigeration document provides calculated endpoint distances for typical meteorological conditions. The worst-case release scenario for an anhydrous ammonia release included a release of all the contents of the recirculator in the 26oF system in a 10-minute period (per EPA guidelines). This release translates to a release of 19,382 pounds [WDW1]of ammonia in 10 minutes or 1,93 8 lbs/min. Other assumptions included in the worst-case assessment are: * The ammonia is a liquefied gas * The recirculator is not diked * The release does not take place indoors * The nearfield dispersion environment is characterized as urban * A 10-minute averaging period * The wind speed is 1.5 meters/sec * The atmospheric stability is classified as F (stable) The results of the worst-case assessment for ammonia show that the plume must travel 2.27 miles (3.65 kilometers) before dispersing to the endpoint concentration of 201 ppm. Figure 1-2 shows the worst-case release scenario. The selected alternative-release scenario for the ammonia systems is a liquid release from one of the 250 gallons per minute (gpm) pumps, located outside the building, due to the failure of mechanical seals in the pump. The leak potential of such a seal failure is approximately five gpm. KPR personnel have indicated that such a leak would first be detected in the engine room and an alarm sounded. KPR perso nnel have also indicated that, subsequent to the alarm and within five minutes of the initial leak, personnel would respond to and stop the leak by taking the pump out of service. The release rate of five gpm of liquid ammonia for five minutes results in an evaporating pool of 25 gallons (approximately 142 pounds) of liquid ammonia. Assuming total evaporation of the pool in five minutes results in a dense vapor release rate of 28.4 lb/min. The ammonia refrigeration document provides calculated endpoint distances for typical meteorological conditions (3 m/s wind speed, D atmospheric stability, 50% relative humidity). Based on the above release rate, the results of the alternative-release scenario indicates that the endpoint concentration of 201 ppm is reached at 0.042 miles (67.7 meters) from the release point. Assumptions include that no active or passive mitigation measures are currently in place and an urban dispersion environment in the nearfield. Figure 1-3 shows the alternative ca se release scenario. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The Columbia, South Carolina, facility is governed by a set of OSHA and USEPA regulations that require planning and facility activities intended to prevent a release of hazardous material. In the event that such a release inadvertently occurs, these rules are established to minimize the consequences of a release to the employees of the facility, the public and to the environment. These regulations include: * 40 CFR Part 68, Accidental Release Prevention * 40 CFR Part 112, Spill Prevention, Control and Countermeasure * 29 CFR Part 119, Process Safety Management * 40 CFR Part 302, Emergency Planning and Community Right-to-Know Act (EPCRA) The key concepts in KPR's release prevention program are employee participation, appropriate design and maintenance of equipment, and appropriate training of all employees. Employee participation in the release prevention program is encouraged and supported by KPR management. Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the ammonia systems. KPR employees are also members of the facility emergency response team. KPR policy is to construct all new equipment, systems, and facilities to ensure the appropriate safety and release prevention systems are included from the beginning of each project. KPR maintains a computerized program of maintenance activities to ensure that key systems are maintained appropriately to minimize the risk of a release. KPR is committed to providing appropriate training to all employees regarding safety procedures. Each new employee is provided comprehensive safety training during their initial orientation for the facility. In addition, KPR conducts regularly scheduled safety training for all employees each year. Additional training is provided to maintenance personnel for the systems they are responsible for. Members of KPR's em ergency response team participate in annual training drills to ensure that response actions are promptly and safely completed. Five Year Accident History KPR has not had a release of ammonia from the Columbia, South Carolina, facility that has affected the employees, public or the environment. Emergency Response Program KPR has personnel trained in emergency response at the facility 24 hours per day, seven days per week. These personnel participate in annual training drills on emergency procedures and response techniques. Planned Changes to Improve Safety KPR completes a thorough review of the ammonia systems each time a design change is implemented. KPR is committed to using these methods to identify and implement ways to improve the safety of these systems. [WDW1]Originally the recirculator was said to normally hold 9,601 lb of ammonia. Later we discussed the possibility that the recirculator could be used to store 15,000+ lb. What is the correct worst case amount? 19,382 lb during transfer. (12/16/98 telecon w/Bryson Downing) |