IBP, inc. - Executive Summary |
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EXECUTIVE SUMMARY Accident Release Prevention Program and Emergency Response Policy It is the policy of the IBP, inc. (IBP) Finney County, Kansas 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 OSHAs 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 IBP 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. This plan covers all IBP owned activities at this facility. IBPs management is committed to providing the resources necessary to implement this policy. Facility Description IBP operates a cattle slaughter and processing facility and a hides tannery at this location. Cattle are trucked to the facility, slaughtered and fabricated. IBP operates rendering systems to produce gel bone, dried blood, low protein beef byproducts, and tallow. Support operations include a wastewater treatment system, truck repair facilities, cold storage, an analytical laboratory, and administrative offices. 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 th e distance to a specified endpoint (concentration or overpressure). The distance 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 offsite, 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 absence of trees, hills, and other structures in the immediate vicinity of the Fin ney County, Kansas facility, a rural dispersion environment was assumed. The Finney County, Kansas facility has three separate ammonia refrigeration systems: the Slaughter, Processing, and Trans Continental Cold Storage (TCCS) refrigeration systems. The largest ammonia system is in the Slaughter refrigeration system. The worst-case ammonia release radius for the slaughter ammonia system would contain the area impacted by the worst-case release for the processing and TCCS ammonia systems. 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 EPAs 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 contai ning 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 high side accumulator in a 10-minute period (per EPA guidelines). This release translates to a release of 36,009 pounds of ammonia in 10 minutes or 3,600.9 lbs/min. Other assumptions included in the worst-case assessment are: the ammonia is a liquefied gas; the high side accumulator is not diked; the release does not take place indoors; the nearfield dispersion environment is characterized as rural; 10-minute averaging period; the wind speed is 1.5 meters/sec and the atmospheric stability is classified as F (stable). The results of the worst-case assessment for ammonia show that the plume must travel 3.42 miles (5.51 kilometers) before dispersing to the endpoint concentration of 201 ppm. The selected alternative-release scenario for the ammonia systems is a release from a relief valve due to overpressure of a compressor unit. The largest relief valve in the system was used in this scenario. The largest relief valve has a relief rate of 469 pounds of air per minute. As a matter of convention, the specified release rate of any relief valve is always in pounds of air per minute. The release rate of 469 pounds of air per minute correlates to a release rate of 333 pounds of ammonia vapor per minute. This release rate was applied to a release from the ammonia header on top of the building. The ammonia refrigeration document provides calculated endpoint distances for typical meteorological conditions (3 m/s wind speed, D atmospheric stability, 50% relative humidity). It has been determined, through a review of IBPs operational history, that the total release would likely be 500 pounds of ammonia. Based on the release rate of 333 lbs/min, the duration for a 500-pound release is 1.5 minutes. Other assumptions include that no active or passive mitigation measures are currently in place and a rural dispersion environment in the nearfield. The results of the alternative-release scenario for an ammonia release indicates that the endpoint concentration of 201 ppm is reached at 0.49 miles (790 meters) from the release point. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The Finney County, Kansas 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, or if a release inadvertently occurs, 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 ? 40 CFR Part 264, Hazardous Waste Contingency Plan ? 29 CFR Part 119, Process Safety Management ? 40 CFR Part 302, Emergency Planning and Community Right-to-Know Act (EPCRA) The key concepts in IBPs release prevention program are employee participation, appropriate design and maintenance of equipment, and appropriate training of all employees. IBP has developed and documented these elements in their process safety management plan (PSM). The PSM plan is incorporated with this document by reference. Employee participation in the release prevention program is encouraged and supported by IBP management. Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the ammonia systems. IBP employees are also members of the facility emergency response team. IBP 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. IBP maintains a computerized program of maintena nce activities to ensure that key systems are maintained appropriately to minimize the risk of a release. IBP 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, IBP 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 IBPs emergency response team receive annual training to ensure that response actions are promptly and safely completed. Five Year Accident History Between August 1995 and July 1998, IBP has had two releases of ammonia from the Finney County, Kansas facility that resulted in two OSHA recordable injuries. None of these releases affected the public or the environment. IBP does not have records of the time or duration of the release or the release quantity for the August 1995 r elease. IBP has process alarms in the room where the release occurred. If the concentration of ammonia reaches 20 parts per million the alarm will sound. During this incident the alarms did not activate. Therefore, because the alarms did not sound, IBP believes the release quantity was small. Since, the release was small an incident investigation was not required. IBP has assumed, after reasonable inquiry, the time of the incident is 12:00 PM, lasted one minute, and released one pound of ammonia. On July 13, 1998 the liquid expansion valve packing nut on Evaporator AA-3 was found to be corroded, loose and leaking ammonia. The system was isolated (locked out/tagged out following IBPs policy and procedures) and pumped down to remove the liquid ammonia from the system. The valve bonnet was loosed and removed. However, some liquid ammonia was still in the system and was released to the atmosphere that injured one employee. The incident investigation found the system had not been pumped down properly. The pump down SOPs were reviewed and discussed. IBP has not had an OSHA recordable incident related to the ammonia system since 1998. Emergency Response Program IBP has personnel trained in emergency response at the facility 24 hours per day, seven days per week. These personnel receive annual training on emergency procedures and response techniques. Planned Changes to Improve Safety IBP completes a thorough review of the ammonia system each time a design change is implemented. IBP is committed to using these methods to identify and implement ways to improve the safety of these systems. |