Bryan Foods, Inc. - Executive Summary |
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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), Bryan Foods, Inc. (Bryan) submits this Risk Management Plan (RMP) for operations at their West Point, Mississippi, facility. Bryans operations include the manufacturing of pork and beef food products for public consumption packaged under the familiar brand name Bryan. Bryan has been in operation at this facility for over 63 years providing quality meat products and over 2,100 jobs to the local community. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICY Bryan is committed to protecting the health of its employees, the surrounding community, and the environment; therefore it is Bryans policy to manage a safe and healthy workplace, protect the environment and maintain compliance with safety, health and environmental regulations: 40 CFR 68 as well as Occupational Safety and Health Administration (OSHA) Process Saf ety Management (PSM) regulations promulgated as Title 29 of the Code of Federal Regulations, Chapter 1910, Section 119 (29 CFR 1910.119), and OSHAs Hazardous Operations and Emergency Response regulations (29 CFR 1910.120). STATIONARY SOURCES AND REGULATED SUBSTANCES Bryan is required to maintain low temperatures in the food processing areas of the plant that are within standards required by the United States Department of Agriculture (USDA) to ensure quality in the final products. Bryan uses anhydrous ammonia (a 112(r) regulated substance) as a refrigerant to maintain the facility within the required range of operating temperatures. Anhydrous ammonia is an industry-standard refrigerant for meat processing plants. Bryans refrigeration system, consisting of receivers, compressors, evaporators, condensers, and piping, can contain a maximum amount of 400,000 pounds of anhydrous ammonia. Chlorine and sulfur dioxide are utilized in the wastewater treatment plant (WWTP) for disinfectio n and dechlorination, respectively. These treatments are performed to ensure that wastewater discharges meet environmental and health standards. The chlorine system can contain a maximum of 9,800 pounds while the sulfur dioxide system can contain a maximum of 6,000 pounds. WORST CASE RELEASE SCENARIO As required by 40 CFR 68 Subpart B, Bryan has evaluated a worst-case release scenario for anhydrous ammonia, chlorine and sulfur dioxide using the parameters specified by the EPA. The worst-case release scenarios were developed following EPA regulations and are not considered to be likely release scenarios. Ammonia Bryans worst case release scenario for ammonia is the rupture of the upper 25# accumulator (61,326 pounds when filled to 100% capacity) over a 10-minute period. Using the International Institute of Ammonia Refrigeration (IIAR) interim final draft document, Risk Management Program Guidance (40 CFR Part 68) for Ammonia Refrigeration, 1998 (Refrigeration Guidance), the m aximum distance to the toxic endpoint extends offsite. During normal operations, Bryan maintains the receiver at no more than 50% capacity. Only during emergency or failure does the receiver have the potential to be filled to 100% of capacity. Chlorine Bryans worst case release scenario for chlorine is the rupture of one cylinder (2,000 pounds maximum capacity) over a 10-minute period. Using EPAs Risk Management Program Guidance for Wastewater Treatment Plants, 1998 (WWTP Guidance), the maximum distance to the toxic endpoint extends offsite. Sulfur Dioxide Bryans worst case release scenario for sulfur dioxide is the rupture of one cylinder (2,000 pounds maximum capacity) over a 10-minute period. Using EPAs WWTP Guidance, the maximum distance to the toxic endpoint extends offsite. ALTERNATIVE RELEASE SCENARIO Ammonia A more realistic release scenario (alternative release) was developed by Bryan taking into consideration operational history and the hazards identified in the process hazard analyses (PHAs) conducted to ensure that Bryans hazards are identified and minimized. These analyses were conducted under the 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). A likely release scenario identified by Bryan would be a release caused by a damaged 1/4 fitting on a dump trap line. This release could occur as a result of torque or other pressure applied to a weakened fitting. In developing the release parameters of this alternative scenario, Bryan considered other possible scenarios and the average response time of the facilitys Hazmat team. Using the Refrigeration Guidance documents procedures for estimating release values, the maximum distance to the toxic endpoint extends offsite. Chlorine A more realistic release scenario (alternative release) was developed by Bryan taking into consideration operat ional history and the hazards identified in the process hazard analyses (PHAs) conducted to ensure that Bryans hazards are identified and minimized. These analyses were conducted under the OSHA Process Safety Management (PSM) regulations. A likely release scenario identified by Bryan would be a release caused by a damaged 3/4 valve or fitting on a cylinder. This release could occur as a result of a handling accident with physical impact to the regulator valve or fitting. In developing the release parameters of this alternative scenario, Bryan considered other possible scenarios and the average response time of the facilitys Hazmat team. Using the WWTP Guidance documents procedures for estimating release values, the maximum distance to the toxic endpoint extends offsite. Sulfur Dioxide A more realistic release scenario (alternative release) was developed by Bryan taking into consideration operational history and the hazards identified in the process hazard analyses (PHAs) condu cted to ensure that Bryans hazards are identified and minimized. These analyses were conducted under OSHAs Process Safety Management (PSM) regulations. A likely release scenario identified by Bryan would be a release caused by a damaged 3/4 valve or fitting on a cylinder. This release could occur as a result of a handling accident with physical impact to the regulator valve or fitting. In developing the release parameters of this alternative scenario, Bryan considered other possible scenarios and the average response time of the facilitys Hazmat team. Using the WWTP Guidance documents procedures for estimating release values, the maximum distance to the toxic endpoint extends offsite. ACCIDENTAL RELEASE PREVENTION PROGRAM Ammonia To prevent and mitigate accidental releases of anhydrous ammonia, Bryan has implemented several precautionary measures, such as process/equipment controls, standard operating procedures, preventative maintenance programs, employee training and audit programs. Bryan has developed and implemented a PSM program pursuant to 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 (vents, pressure relief valves, backup pumps, and manual shutoffs) and automated controls (automatic shut-offs and electrical distribution system grounding). Chlorine The chlorine disinfection system is designed and constructed in consideration of applicable ANSI and ASTM requirements. To prevent and mitigate accidental releases of chlorine, Bryan has implemented several precautionary measures, such as process/equipment controls, standard operating procedures, preventative maintenance programs, employee training and audit programs. Bryan has developed and implemented a PSM program pursuant to OSHA regulations and as such, has evaluated the system for the potential of chlorine releases. Some of the controls i nstalled to prevent catastrophic releases of chlorine are automated controls (fail-close valves, chlorine leak detection system, and electrical distribution system grounding). Sulfur Dioxide The sulfur dioxide dechlorination system is designed and constructed in consideration of applicable ANSI and ASTM requirements. To prevent and mitigate accidental releases of sulfur dioxide, Bryan has implemented several precautionary measures, such as process/equipment controls, standard operating procedures, preventative maintenance programs, employee training and audit programs. Bryan has developed and implemented a PSM program pursuant to OSHA regulations and as such, has evaluated the system for the potential of sulfur dioxide releases. Some of the controls installed to prevent catastrophic releases of sulfur dioxide are automated controls (fail-close valves, sulfur dioxide leak detection system, and electrical distribution system grounding). In addition, Bryan has trained approxima tely 16 personnel to respond to potential ammonia, chlorine and sulfur dioxide releases (Hazmat team). Bryan has developed standard operating procedures for all employees and contractors that have contact with the refrigeration, disinfection and dechlorination systems that incorporate safety measures into the procedures. These safety procedures were developed by system operators and are reviewed at a frequency sufficient to assure that they reflect current operating practice, including changes that result from changes in the technology, the equipment and the facility. Bryan encourages employee participation in development of the control measures used at the plant by means of company newsletters and training sessions. Pursuant to written management of change procedures established by Bryan, any changes to the operating procedures are communicated to affected employees. Bryan understands that maintaining the refrigeration, disinfection and dechlorination systems in good working ord er is essential to preventing accidental releases; therefore Bryan has implemented preventative maintenance programs. Each preventative maintenance program is scheduled, documented and managed using log sheets to ensure that regular maintenance occurs on the system. These log sheets are maintained in the Engineering Department for three years. Also, to ensure the mechanical integrity of critical system components, equipment tests are performed. Specifically, the equipment is tested to detect corrosion. Refrigeration equipment consists of pressure vessels, headers, and piping. Chlorination and sulfur dioxide equipment includes headers and piping. Chlorine and sulfur dioxide cylinders are tested by the industrial gas supplier. Bryan monitors and records inspection and testing data on each cylinder received. To ensure that Bryans control measures are effective in maintaining the safe operation of the plant, regularly scheduled audits are performed on the refrigeration system. the chlorine disinfection system and sulfur dioxide dechlorination system: 7 In accordance with the PSM program, Bryan conducts detailed PSM compliance audits at least every three years, typically annually. Each audit 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, Bryan is audited by the local fire department on an annual basis. 7 Bryan is audited by the USDA on an continual basis. The USDA maintains a team of personnel at the Bryan facility. 7 Bryans insurance carrier also conducts independent audits on an variable annual to biennial basis. FIVE YEAR ACCIDENT HISTORY Ammonia Within the five years prior to the submittal of the RMP plan, there have been no acci dental releases of anhydrous ammonia that resulted in deaths, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. Chlorine Within the five years prior to the submittal of the RMP plan, there have been no accidental releases of chlorine that resulted in deaths, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. Sulfur Dioxide Within the five years prior to the submittal of the RMP plan, there have been no accidental releases of ammonia that resulted in deaths, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. EMERGENCY RESPONSE PROGRAM Bryan has developed a comprehensive emergency response program designed to protect both employees and the community in the event of a release. This program is fully described in a document entitled Emergency Response Action Plan (ERAP) in order to facilitate response efforts in the event of an off-site hazardous substance release. Included in the ERAP are measures to be taken internally by Bryan as well as measures to be taken by off-site response agencies. Bryan has trained approximately 16 on-site personnel to respond to accidental hazardous substance releases. These personnel are trained in accordance with 29 CFR 1910.120, OSHAs Hazardous Waste Operations and Emergency Response regulations according to their duties and function. These personnel receive initial training and annual update training thereafter. To assure that the local governmental response agencies are familiar with Bryans emergency response procedures, Bryan will provide copies of the ERAP and future major revisions for review by the Clay County Emergency Planning Committee (EPC) To plan for a hazardous substance release with of f-site effects, Bryans ERAP includes procedures/equipment to mitigate the release, procedures to inform local response agencies, evacuation procedures, and procedures for public communication. In addition to the Clay County EPC, Bryan has arranged emergency response assistance with a local clean-up contractor: Ferguson-Harbour, Inc. In the event of a hazardous substance release with off-site effects, the general public will be warned using one or more of the following methods: 7 Facility alarm whistle or klaxon 7 Police and fire vehicles equipped with public address systems, and 7 Public notification of residents. |