Armour Swift-Eckrich - Executive Summary |
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EXECUTIVE SUMMARY 1.0 RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Armour Swift-Eckrich facility in St. James, Minnesota has a good record in preventing releases of anhydrous* ammonia. As part of their release prevention program, the plant uses a Computerized Maintenance Management System (CMMS) to control scheduling and to accomplish preventative maintenance on all components of the refrigeration system. 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 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. All of these components make the Emergency Action Plan a thorough and comprehensive plan for release prevention and emer gency 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 The Armour Swift-Eckrich St. James plant produces processed meats including lunch meats. The NAICS code for the processes at this facility is 311613. 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 29,521 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 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 accompanied with a high ignition temperature. Although ammonia is not p oisonous, 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 St. James plant. The two high pressure receivers plus interconnecting pipework were used to determine the worst-case release quantity. The worst-case release quantity was calculated to 15, 917 pounds. The worst-case scenario considers a 11/4 inch diameter puncture in the liquid portion of one of the high pressure receivers. The release assumes that both vessels lose their entire contents in 10 minutes. Administrative and passiv e controls are not applicable to this scenario. 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. Since this facility is located in a populated area, the worst-case release scenario distance-to-endpoint will reach off-site public receptors. 3.2 Alternative Release Scenario Description The alternative release scenario is an ammonia release from piping on the roof. The release scenario considers a forklift truck backing into an evaporator breaking the attached pipe on the roof enough to crack it. The opening in the damaged pipe is assumed to have a diameter of 1/2 inch, and is located eight feet above ground level. Administrative and passive contro ls are not applicable to this scenario. Active mitigation of the release is human intervention. Since this facility is located in a populated area, the alternative release scenario distance-to-endpoint will reach off-site public receptors. 4.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Armour Swift-Eckrich has developed an OSHA (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 ammonia 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 to accomplish preventative m aintenance 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. Results of PM and T/I procedures are documented on the individual work order. The work order is signed off by both the operator/mechanic and their supervisor. 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. 6.0 EMERGENCY RESPONSE PROGRAM As mentioned previously, the Armour Swift-Eckrich facility has developed an emergency response program called Emergency Action Plan (EAP) to ensure the safety of its employees, the community, and the environment. Armour Swift-Eckrich's EAP is a detailed document which discusses the role of employees and management in an emergency situation. All emergency response personnel (HAZMAT Team) undergo emergency response training. The plan outlines specific procedures for evacuations and notification by means of a public address system. For all emergencies, the plan activates the Emergency Command Team which consists of the Incident Commnader and two Team Leaders. This team is responsible for implementing the EAP and controlling all aspects of the plan and personnel. This document contains specific procedures for: 1) emer gency notification procedures, evacuation instructions and maps, personnel accounting procedures as well as notification of offsite response groups; 2) emergency medical treatment; 3) HAZMAT-chemical spills and releases (includes roles and lines of authority, emergency recognition and prevention, safe distances and places of refuge, site security and control, medical/first-aid, decontamination, personal protective equipment, and emergency equipment); 4) critique of response and follow up; and 5) procedures for communication with outside news media. This document also contains an Emergency Ammonia Shutdown Procedure which gives very detailed information for shutting down the ammonia system. 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 the status monitored to ensure that implementation was accomplished. An example of safety improvements made at the plant is discus sed below: Currently, the plant has several ongoing projects to improve the safety of the refrigeration system. These steps include installation of an ammonia detection system and emergency shutdown system. Additionally, the relief valve manifold will be replaced with an increased size. |