E. A. Miller - Executive Summary |
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The accidental release prevention and emergency response policies at the plant consist of all regulations that are regulated by OSHA and the PSM program at the facility. All refrigeration maintenance personnel go through training on all the SOP's from the PSM program. These procedures are reviewed yearly to help insure that all problems are corrected. All refrigeration maintenance personnel are currently scheduled to go through ammonia refrigeration school to teach them the operations and safety. The school is located in Logan, Utah and is part of the local trade tech school. The preventative maintenance program is periodically reviewed and updated as the monitoring and repair on equipment is performed. This process has been of great benefit to the plant in finding problems in a timely manner. The E.A. Miller plant in Hyrum, Utah, is a beef slaughter and processing facility. The plant is defined by the EPA as a "Complex Slaughter" facility. Final products produced include: mea t products, edible tallow, inedible tallow, dried blood, meat and bone meal, and unfinished hides. The regulated substance used at this facility that meets threshold quantities is anhydrous ammonia. Ammonia is used as a manufacturing aid in the refrigeration process. Refrigeration is used in processing and storing of the meat and meat products. The worse case scenario for this facility is a rupture in the high pressure receiver resulting in a loss of the entire contents of 24,663 pounds of ammonia. This loss will occur within 10 minutes and the spilled liquid will vaporize at room temperature releasing gas to the building envelope and to the atmosphere. The American Industrial Hygiene Association (AIHA) has determined that the maximum airborne concentration below which it is believed that nearly all individuals can be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability t o take protective action for anhydrous ammonia is 200 parts per million (ppm). Under the worst-case weather conditions with dispersion into an urban area, the toxic cloud formed by the evaporating ammonia would reach offsite end points and nearby public receptors. A release of this type is very unlikely because of the safety measures and PSM programs in place at the facilty. The more likely release scenario or alternate case is the release of 2,000 pounds of ammonia within a 60 minute period of time. This release would be the result of a relief valve rupture and cause ammonia to be released a distance of 0.11 miles (to the property line). It would not affect any offsite public receptors. The E.A. Miller facility is in compliance with all OSHA PSM rules and this RMP rule requirements. The procedural and managerial steps that are in place are a preventative measure to accidental release prevention as well as maintenance and training programs that are in place. There have been no releases at this facility in the past five years that have resulted in death, injuries, or property damage on site or in death, injuries, evacuations, sheltering in place, property damage, or environmental damage offsite. The E.A. Miller facility has an emergency response plan on file with the local emergency planning committee (LEPC). The policies for reporting spills and releases is documented in the "Policies and Procedures" manual updated by the Corporate Environmental Operations office. The ammonia compressor rooms of this facility are protected by monitoring systems at this time. The facility will continue training between plant personnel and the local fire department as a deterrent to toxic release danger. |