Cagle-Keystone Foods JV LLC - Executive Summary |
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CAGLE-KEYSTONE FOODS, JV LLC RISK MANAGEMENT PROGRAM EXECUTIVE SUMMARY 1. General accidental release and prevention policy of Cagle-Keystone Foods. In this food product manufacturing facility we handle anhydrous ammonia and chlorine in a liquid and vapor state which is considered hazardous by the EPA. Due to the hazardous properties of ammonia and chlorine it is necessary to observe certain safety precautions during their use to prevent human exposure, reduce the threat to our workers personal health, the surrounding community and the environment. It is our policy to adhere to all applicable federal and state regulations that were are governed by. Safety depends directly on our proper handling of these chemicals coupled with the safety devices, control measures and safe handling procedures that our personnel are trained in. 2. Stationary source and regulated substance handled. Cagle-Keystone Foods, 7220 Highway 19 N, Camilla, Georgia, is located approximately two miles north of Camilla, Georgia. We are responsible for the processing of frozen poultry products in various varieties. The entire facility consists of two separate processing centers. Both plants manufacture product around the clock, (7) seven days a week. There are 2600 full time employees at the entire facility, which includes hourly and salary personnel. The potentially hazardous chemicals used at the Cagle-Keystone Foods facility are anhydrous ammonia and chlorine. The dominant characteristic of ammonia vapor is it's pungent, distinct odor. Persons exposed to ammonia will not voluntarily stay in areas of even small concentrations, although these levels would not result in any health risks. Risks from accidental exposure to ammonia in a vapor state are irritations to the eyes, nose and throat. The extent of irritation depends on the exposure amount and length of exposure. Ammonia is classified non-flammable by the Department of Transportation. It will burn, but only in a very narrow, high concentration level with a constant ignition source. Chlorine gas is primarily a respiratory irritant. It is so irritating that low concentrations in the air are readily detectable. In high concentrations the irritating effect of the gas will force an individual from a contaminated space unless trapped or unconscious. Liquid chlorine will cause skin and eye burns upon contact. When liquid is exposed to atmospheric pressure and temperature the liquid will vaporize to chlorine gas. The normal operating level of ammonia that is used/stored at Cagle-Keystone Foods facility is 100,000 pounds, 50,000 at each of the Processing and Further Processing centers. The anhydrous ammonia is used as the refrigerant chemical during the manufacturing and cold storage process. The normal operating level of chlorine that is used/stored at the Cagle-Keystone Foods Processing facility is 4,000 pounds. The chlorine i s used in the facility for water treatment and sanitation. The possible hazards that could lead to an accidental release of either chemical include, but are not limited to, equipment failure, damage to piping, damage to equipment and human error. 3. Worst case release scenarios and alternate release scenarios including administrative and engineering controls to limit/prevent the release of ammonia and chlorine. Ammonia worst case release scenario criteria for Cagle-Keystone Foods Processing facility: Worst case scenario depicts continuous source leak from the High Pressure Receiver (HPR) located in the Processing facility engine room. This vessels normal operating level is 11,500 pounds of liquid ammonia, approximately 50% of it's total capacity. Although it's maximum capacity is 23,000 pounds, this exceeds engineering controls and written operating procedures that only allows an 80% level at any time. Ammonia Quantity: 11,500 pounds Rate of Release: 1,150 lbs / min. (10 min. release) LOC (Level of Concern): 200 ppm (EPA ERPG-2) Physical State: Gas Type of Area: Rural Wind Speed: 1.5 m/sec Distance to Endpoint 3.6 miles Ammonia alternate case release scenario criteria for Cagle-Keystone Foods Processing facility: Alternate release scenario is represented by the release of ammonia vapor from a safety relief valve (SRV) due to an over pressurization condition on a vertical vessel located within the Cagle- Keystone Foods engine room. The SRV would be performing exactly as it is designed to do. Actual venting would take place on the facility roof where the relief vent piping exits to the atmosphere. . Ammonia Quantity: 280 pounds Max. Rate of Release: 26 pounds/min. (44 min. release) Distance to Endpoi nt: 235 yards (.15 miles) Ammonia worst case release scenario criteria for Cagle-Keystone Foods Further Processing facility: Worst case scenario depicts continuous source leak from the High Pressure Receiver (HPR) located in the Further Processing engine room. This vessels normal operating level is 16,500 pounds of liquid ammonia, approximately 50% of it's total capacity. Although it's maximum capacity is 33,000 pounds, this exceeds engineering controls and written operating procedures that only allows an 80% level at any time. Ammonia Quantity: 16,500 pounds Rate of Release: 1,650 lbs / min. (10 min. release) LOC (Level of Concern): 200 ppm (EPA ERPG-2) Physical State: Gas Type of Area: Rural Wind Speed: 1.5 m/sec Distance to Endpoint 4.2 miles Ammonia alternate case release scenario criteria for Cagle-Keystone Foods Further Processing facility: Alternate release scenario is represented by the release of ammonia vapor from a safety relief valve (SRV) due to an over pressurization condition on a vertical vessel located within the Further Processing engine room. The SRV would be performing exactly as it is designed to do. Actual venting would take place on the facility roof where the relief vent piping exits to the atmosphere. . Ammonia Quantity: 235 pounds Max. Rate of Release: 22 pounds/min. (57 min. release) Distance to Endpoint: 212 yards (.15 miles) The following administrative and engineering controls are in place at the Cagle-Keystone Foods facility to eliminate or control the release of ammonia. * Electronic ammonia detection in engine rooms, coolers and freezers. Alarms tie into a computer system to alert personnel of potential releases in the monitored areas. Detection systems also activate emergency ventilation within the engine rooms. * High and low level switches are configured to pressure vessels to alert refrigeration personnel of potential abnormal operating levels within the associated vessel or the refrigeration system. * Safety relief valves are installed on all condensers, compressor oil separators and pressure vessels to eliminate the possibility of over-pressurization conditions within the particular piece of equipment. * Emergency shut down switches are located just outside of engine room exits to allow shut down of entire system in the event of an emergency condition. * Operators make periodic rounds to monitor equipment operational status. * Periodic Maintenance Program is in place within the maintenance department to ensure all refrigeration components are kept in optimum operational and mechanical co ndition. Chlorine worst case release scenario criteria for Cagle-Keystone Foods Processing facility: Worst case scenario depicts continuous source leak from a 1 (one) ton chlorine cylinder located outside the Processing facility chlorine water treatment room. This vessels normal operating level is 1,600 pounds of liquid chlorine, approximately 80% of it's total capacity. Chlorine Quantity: 1,600 pounds Rate of Release: 160 lbs / min. (10 min. release) LOC (Level of Concern): 10 ppm Physical State: Gas Type of Area: Rural Wind Speed: 1.5 m/sec Distance to Endpoint 1.7 miles Chlorine alternate case release scenario for Cagle-Keystone Foods Processing facility: Alternate release scenario is represented by an accidental release of chlorine vapor from a control valve on the 1 (one) ton vessel located outside the water treatment room. Chlorine Quantity: 234 pounds Max. Rate of Release: 58 pounds/min. (10 min. release) Wind Speed 3.0 m/sec Distance to Endpoint: 1070 yards (.6 miles) The following administrative and engineering controls are in place at the Cagle-Keystone Foods Processing facility to eliminate, or control the release of chlorine. * Periodic Maintenance Program is in place within the maintenance department to ensure all chlorine system components are kept in optimum operational and mechanical condition. * Operators make periodic rounds to monitor equipment operational status. 4. Five-year accident history. During the last five years the Cagle-Keystone Foods facility has no significant accidental releases of ammonia or chlorine. 5. Emergency Response Program The purpose of the Cagle-Keystone Foods Emergency Response Program is to: 1. Minimize exposure to our employees and the surrounding community in the event of a hazardous material release or spill. 2. Assure the safe emergency evacuation of the plant in the instance that it is required. 3. Provide for prompt medical attention to any employees who become seriously injured or ill at work. 4. Manage an emergency response system and coordinate response of the internal and external resources required to provide efficient and effective response to any type of emergency that may occur at Cagle-Keystone Foods. This Emergency Action Plan currently meets requirements as set forth in OSHA 29 CFR 1910.38 and 29 CFR 1910.120. |