Fresh Mark, Inc. - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICY |
It is the policy of Fresh Mark Inc. to conduct business in a manner that is safe to the employees, the community and the environment. The Company's officers, managers and supervisors are accountable to carry out the policies of the Company relevant to the prevention of accidental releases of hazardous materials. Fresh Mark has made a determined effort to develop a plan to prevent releases of extremely hazardous substances. Procedures to assist in the prevention of extremely hazardous material releases are set forth in EPA's Risk Management Program. In the event of a release, the Emergency Response Plan will be the guidance for responding to, containing and reporting such releases. The Response Plan includes an incident command system for decision-making authority for each stage of a release situation. The Company will coordinate with public responders and emergency services in ensuring safety of the public.
SCRIPTION AND THE REGULATED SUBSTANCES
Fresh Mark, Carriage Hill Division is a further processing facility. Meat is trucked in and processed for human consumption. To preserve the meat and prevent bacteria contamination, an extremely hazardous substances is utilized, ammonia. Ammonia is used as a refrigerant to maintain cool to freezing temperatures in the various stages of the process. The refrigeration system is a closed loop system, meaning the ammonia is continually reused.
Fresh Mark, Inc. has developed models of the release scenarios at this facility to identify the potential affected areas. A commercial computer model, Phast Professional, was used to develop the models. This is not an exact prediction of what would in the event of a release, but an estimate of the affected area and the resources needed in the event of a release.
The worst-case release of ammonia involves the sudden failure of the High Pressure Recirculator, HPR when used as a storage v
essel. The HPR can store approximately 37,000 pounds of ammonia. This model assumes the release of all the vessel contents. Depending on wind direction, residences and businesses at a distance of 2.21 miles could be affected. Approximately 5900 people live within a 2.21 mile radius of the facility. This type release is not likely to occur because of the stringent construction codes for pressure vessels and annual inspections of the pressure vessels.
The alternative release of ammonia involves the failure of a 3/4 inch line on the HSR releasing 15,000 pounds of liquid ammonia over a 147 minute period. Residences up to 0.13 mile from the release would be affected. Approximately 31 people live within a 0.13 mile radius of the facility This release was selected because appurtenances are more likely to be broken. Protective devices are put in place to protect lines from traffic and accidental breaking.
RELEASE PREVENTION PROGRAM
Fresh Mark has set forth in its policies the impor
tance of operating safely. The Company has aggressively developed programs, policies and materials requirements to minimize the possibility of releases. These programs include compliance with appropriate OSHA and EPA regulations and sound safety practices. Stringent material and contractor requirements have been developed to assure that materials and work conform to recognized standards. Training for employees is conducted to maintain a high level awareness when working with hazardous materials. A recent audit revealed inadequacies in the Mechanical Inteigrity Program. These inadequacies are being addressed and should be resolved by December 31, 2002.
FIVE YEAR ACCIDENT HISTORY
Fresh Mark, Salem facility has not had a reportable accidental release of ammonia during the last five years.
EMERGENCY RESPONSE PLAN
On-site emergency response teams are trained to respond to releases, and effectively minimize the release. Joint response training is conducted with local emergency se
rvice organizations (i.e. fire police, rescue, etc.) Drills are conducted bi-annually for on-site response teams and annually with outside organizations. Although Rick Foster, Plant Manager, is the key 24 hour contact, Pat Payne, Facility Engineer, will be the contact should Mr. Foster be unavailable. Mr. Payne's 24 hour page number is (330) 214-1417.
Future changes to improve release prevention include: improved maintenance procedures and periodicity; addition of new technology as it becomes available; and continued training of plant and response personnel.