Decker Food Company - Executive Summary

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EXECUTIVE SUMMARY 
 
1.0    RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 
 
The Decker Food Company facility in Garland, Texas has a good record in preventing releases of anhydrous* ammonia.  As part of their release prevention program, the plant has an excellent and very detailed 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 Action Plan which is to provide information to safely deal with an ammonia release.  This detailed emergency response program includes procedures for handling an emergency - the established response plan and appropriate personnel involved in containing an ammonia release - HAZMAT Team. These components make the Emergency Action Plan a thorough and comprehensive plan for release prevention and emergency response.  The emergency response policies at the Decker Food Company facility ensure that there is emergency respons 
e 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 
 
The Decker Food Company Garland Plant produces various meats including:  bacon, lunchmeats, 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. Decker Food Company 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 documented as approximately 35,000 pounds.  The process exceeds the threshold quantity 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 ammoni 
a 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 accompanied with a high ignition temperature.  Although ammonia is not poisonous, it is corrosive to human tissue.  Ammonia is readily absorbed into the moisture of t 
he 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 Garland plant.  The largest potential release of ammonia would occur with a 1 = inch diameter puncture in the liquid portion of the control pressure receiver.  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 high back accumulator.  However, the control pressure receiver would be used as the primary liquid storage vessel during pumpout conditions.  The high back accumulator would only be used to accommodate excess liquid from the control pres 
sure receiver.  The total quantity of ammonia that can be stored in the control pressure receiver is 9,305 pounds.  Therefore, the worst-case release quantity will be 9,305 pounds.  Administrative and passive controls are not applicable to this scenario.  It is assumed that the entire 9,305 pounds is released to the atmosphere in 10 minutes.  For the worst-case release, regulations dictate that the release height is at ground level.   
 
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 ammonia release from an HTRL li 
ne on the roof. The release scenario considers a forklift contacting the evaporator in the south dock, dropping the evaporator from its mounting; the fall of the evaporator damages the HTLR piping above the roof at the valve station. The opening in the damaged pipe is assumed to be equivalent to a = diameter orifice, and is located 18 feet above ground level.  Administrative and passive controls are not applicable to this scenario.  Active mitigation of the release is human intervention.     
 
Since this facility is located in an fairly unpopulated area, the alternative release scenario distance-to-endpoint will not reach off-site receptors. 
    
4.0    GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS 
 
Decker Food Company has developed an OSHA (PSM) program for their ammonia refrigeration system. At Decker Food Company, 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 i 
n compliance with OSHA PSM, then it is compliance with RMP Program 3.  Thus, Decker Food Company's ammonia PSM system has been reviewed and the PSM system elements are being implemented for the RMP.   
 
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 operator/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.   
 
5.0    FIVE-YEAR ACCIDENT HISTORY 
 
The review of Decker Food Company'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. 
 
6.0    EMERGENCY RESPONSE PROGRAM 
 
As mentioned previously, the Decker Food Company facility has developed an Emergency Action Plan. The response plan is a detailed document which discusses the role of employees in an emergency situation. The plan outlines specific procedures for evacuations for plant personnel. All emergency response personnel (HAZMAT Team) undergo emergency response training on a semi-annual basis.  Every 6 months Decker Food Company conducts a HAZMA 
T exercise in which all emergency equipment is utilized.  On an annual basis refresher training is given in conjunction with an exercise.  For all emergencies, the Incident Commander has operating authority for emergency response at the site of the release and assumes control of the incident scene beyond the first responder awareness level. 
 
This document contains specific information regarding: contact numbers; emergency communication; incident team job descriptions; evacuation zones; emergency escape procedures; notification procedures; training; practice drills; HAZMAT emergency response; personnel roles and lines of authority; emergency recognition and prevention; safe distances and places of refuge; site security and control; evacuation routes and procedures; decontamination; medical/first aid treatment; emergency alerting and response procedures; PPE and emergency equipment; and standard operating procedures in the event of an ammonia release. 
 
7.0    PLANNED CHANGES TO IMPROVE SAFE 
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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 installed an emergency shutdown system for the ammonia system.  The engine room ventilation systems have been upgraded and the plant has an ammonia detection system.  The plant has future plans, which include increased ammonia detection, addition of handrails and crossovers on the roof and replacement of some oil pots.
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