Armour Swift-Eckrich, Inc. - Executive Summary |
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EXECUTIVE SUMMARY 1.0 RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Armour Swift-Eckrich facility in Kansas City, Kansas has a good record in preventing releases of anhydrous* ammonia. As part of their release prevention program, the plant has a thorough preventative maintenance program. More information about these aspects of the prevention program is discussed in Section 4.0 of this Executive Summary. The facility has implemented an Emergency Planning and Response program which is to ensure the safety of its employees', the community, and the environment. This detailed emergency response program includes procedures for handling an emergency - the established action plan and appropriate personnel involved in containing an ammonia release - HAZMAT Team. As part of this program, there is emergency response training and medical surveillance of the HAZMAT team prior to and after an incident. All of these components make the Emergency Action and Response Plan a thorough an d comprehensive plan for release prevention and emergency response. The emergency response policies at the Armour Swift-Eckrich facility ensure that there is emergency response coverage 24 hours - 7 days per week. *From this point in the Executive Summary, anhydrous ammonia will be synonymous with ammonia. 2.0 PROCESS DESCRIPTION AND REGULATED SUBSTANCES Armour Swift-Eckrich is a producer of processed meats, including prepared lunch meats and hot dogs. The NAICS code for the processes at this facility is 311612. Many areas of the plant are refrigerated to preserve the meat products. Armour Swift-Eckrich has one regulated substance under 40 CFR 68: ammonia. Ammonia is used as a refrigerant in the refrigeration of the products in the various areas of the plant. The ammonia threshold for triggering applicability to 40 CFR 68 is 10,000 pounds. The total quantity of ammonia stored in the refrigeration process is approximately 71,106 pounds. The process exceeds the threshold quant ity of 10,000 pounds as set by 40 CFR 68 and thus is regulated by the Risk Management Program. 3.0 WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS The ammonia refrigeration system has associated hazards that can potentially affect on-site employees and the general public off-site if there is a release from the system. Described below are the associated hazards and the worst-case and alternative release scenario for the regulated chemical. Though there may be other scenarios possible, EPA only requires that one worst-case and one alternative scenario be reported for each regulated chemical. Ammonia is classified as a Group 2 Refrigerant per ASHRAE Standard 34-1989. The dominant characteristic of this chemical is its toxicity. It is a self-alarming chemical by its distinctive pungent odor. Due to this odor, persons exposed to ammonia vapor will not voluntarily stay in areas of even small concentrations. Ammonia will burn at a very narrow and high range of concentrations accompanie d with a high ignition temperature. Although ammonia is not poisonous, it is corrosive to human tissue. Ammonia is readily absorbed into the moisture of the skin and, at high concentrations, can cause severe burns. The risks to persons in an accidental release of ammonia include: 1. Corrosive attack of skin and other tissue (including lung tissue) 2. Freezing of skin and other body tissue when contacted by liquid ammonia 3. Eye contact Below is a description of the release scenarios for ammonia and their off-site consequences: 3.1 Worst-Case Scenario Description One worst-case scenario has been developed for the Kansas City plant. The largest potential release of ammonia would occur with a one and one-half inch diameter puncture in the 75 pound receiver vessel in Engine Room 1. Taking the specific definition of the worst-case from 40 CFR 68.25, the vessel that can store the largest quantity of ammonia is the 75 pound receiver vessel in Engine Room 1. The total quantity of amm onia that can be stored in the 75 pound receiver vessel is 12,972 pounds. Administrative controls are not applicable to this scenario. Passive controls are applicable as the building will mitigate some of the ammonia release. It is assumed that the entire 12,972 pounds is released into the engine room and some of the released ammonia is mitigated by equipment in the room. The mitigated release rate to the atmosphere over a 10 minute period is 264.6 lb./min. Under Section 68.25(c)(1), a regulated toxic substance such as ammonia that is normally a gas at ambient temperature and handled as a liquid under pressure shall be considered to be released as a gas over a 10 minute period. Thus, ammonia's physical state in the worst-case scenario is a gas. This facility is located in a fairly unpopulated area, however the worst-case release scenario distance-to-endpoint will reach off-site receptors. 3.2 Alternative Release Scenario Description The alternative release scenario is an amm onia release from a pump seal leak on the T-2 high temperature pump receiver in Engine Room 2. The orifice is assumed to have a diameter of three-eighths inch, and is located two feet above ground level. Administrative and passive controls are not applicable to this scenario. Active mitigation of the release is human intervention. This facility is located in a fairly unpopulated area, however the alternative release scenario distance-to-endpoint will reach off-site receptors. 4.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Armour Swift-Eckrich has developed an OSHA Process Safety Management (PSM) program for their ammonia refrigeration system. At Armour Swift-Eckrich, ammonia falls under the RMP Program 3 Prevention Program which is identical to the OSHA PSM program. EPA has said that if the process is in compliance with OSHA PSM, then it is compliance with RMP Program 3. Thus, Armour Swift-Eckrich's PSM system has been reviewed and the PSM system elements are being implemented for the RMP document. Listed below are the key aspects of the ammonia prevention program: The plant uses a Computerized Maintenance Management System (CMMS) for control scheduling and accomplishment of preventative maintenance on components of the refrigeration system. The scope of preventative maintenance (PM) and testing/inspection (T/I) for refrigeration components is based on individual vendor recommendations and generally accepted engineering practices with regard to types of preventative maintenance and inspections and their recommended frequencies. The plant has created work tasks for each type of PM and T/I associated with the refrigeration system. These tasks are included on the individual work order generated by the CMMS. This system ensures that each operator/mechanic is aware of the pertinent safety precautions required for a PM procedure as well as the step-by-step actions required to complete the procedure. The opera tor/mechanic and their supervisor sign off the completed work order. Specific results of each PM and T/I procedure are recorded on the work order. In the event a PM or T/I procedure is not completed satisfactorily, the operator/mechanic notes it on the work order, and a follow-up work order is generated to address the specific deficiency. 5.0 FIVE-YEAR ACCIDENT HISTORY The review of Armour Swift-Eckrich's accident history includes the following range of dates: June 21, 1994 - June 21, 1999. According to 40 CFR Part 68.42(a), there have been no accidental releases at this facility. However, a non-reportable release (according to 40 CFR Part 68.42(a)) of 5,000 pounds of ammonia did occur in 1996. Armour Swift-Eckrich feels that it is important to mention this release but that it does not meet the requirements for reporting in the RMP. 6.0 EMERGENCY RESPONSE PROGRAM As mentioned previously, the Armour Swift-Eckrich facility has developed an OSHA hazardous substance emergency resp onse document called Emergency Planning and Response. The program describes procedures for the response to hazardous substances, spills and releases. The plan contains specific information about: HAZMAT emergency response; pre-emergency planning; roles and lines of authority; levels of training; HAZMAT roles; emergency recognition and prevention; emergency team job descriptions; decontamination; safe distances and places of refuge; emergency alerting and response procedures for ammonia release; critique of response and follow-up; standard operator procedures for HAZMAT response; and annual refresher training. The Emergency Planning and Response also consists of all notifications and plant evacuation procedures in the event of an ammonia release. The purpose of this plan is to summarize the existing policies, procedures, and plans of action to protect the team members of this facility from dangers associated with these emergencies and provide for the notification and proper evacuat ion of plant personnel in event of an emergency. 7.0 PLANNED CHANGES TO IMPROVE SAFETY Based on the completed Process Hazard Analysis (PHA) for ammonia, a list of action items to improve safety was developed and their status monitored to ensure that implementation was accomplished. An example of safety improvements made at the plant is discussed below: The plant has upgraded engine room ventilation, ammonia detectors in the engine room and pressure relief valve vent line and an emergency shutdown system. The engine room ventilation includes both constant and emergency fans. The emergency fan is activated either by the ammonia detection system or by manual input. The pressure relief valve vent header was recently modified to provide the required flow capacity. The emergency shutdown switch stops all ammonia equipment in the engine room. The switch also closes the main ammonia liquid supply valve to the plant. |