Fresh Express - Executive Summary |
RISK MANAGEMENT SUBMISSION STATEMENT Fresh Express 1361 Southern Road Morrow, GA 30260 This is to inform all interested persons, including employees that Fresh Express, Morrow, GA is complying with OSHAs Process Safety Management Standard (called Process Safety Management or PSM), Title 29 Code of Federal Regulations (CFR) 1910.119, and EPAs Risk Management Program regulations (called RM Program), Title 40 CFR Part 68, to deal with the risks involved with the storage, handling, and processing of hazardous chemicals. In this way we promote overall plant, worker, and public safety. These programs enable our facility to prevent the occurrence, and minimize the consequences, of significant releases of toxic substances as well as fires, explosions, and other types of catastrophic accidents. Overall, these programs prevent accidental fatalities, injuries and illnesses and avoid physical property damage. Our safety programs are applied to any activity involving hazardous chemicals including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. Any group of vessels which are interconnected and separate vessels which are located such that a hazardous chemical could be involved in a potential release shall be considered a single process. Our safety programs prevent accidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment. These rules are detailed and improved as necessary. They are also communicated to and accepted by all employees at the facility. DESCRIPTION OF PROCESS The Fresh Express Facility is a Food Processing facility. The facility uses ammonia in an industrial refrigeration system to maintain temperatures in production rooms, coolers, and process water chillers. Ammonia refrigeration is the only process subject to the Risk Management Legislation. In addition there is a computer c ontrol system that monitors temperatures, pressures, and the atmosphere for leaks. Any irregular condition will result in the activation of an automated paging system to contact refrigeration personnel. WORST CASE SCENARIO Failure of the high pressure receiver containing 11,100 lbs. of ammonia with the receiver quantity limited to 80 % of the vessel capacity by facility procedures resulting in a ten minute release. Under worst-case weather conditions, ammonia could travel 1.2 miles before dispersing enough to no longer pose a hazard to the public. This scenario is unlikely for the following reasons: worst- case weather conditions are uncommon; the vessel is enclosed in a building that would withstand and help to contain such a release; industry standards for the manufacture and quality control of pressure vessels; ammonia is not corrosive in this service; pressure safety valves limit operating pressure in this vessel; the accident prevention program in place at the f acility including the mechanical integrity program for regular maintenance, inspection and testing, and replacement of equipment, if necessary; installed ammonia sensors in the system to warn of leaks; alarms and the auto-dialing system in place to warn operating personnel of process upsets; and the emergency response plan and equipment in place at the facility. ALTERNATIVE RELEASE SCENARIOS Failure of a weld in the condenser drain line returning liquid ammonia from the condensers would result in a release of 8,745 pounds. Under common weather conditions, ammonia could travel .2 miles before dispersing enough to no longer pose a hazard to the public. This particular line was chosen as an alternative scenario because it is in an area of the plant where it could be struck and result in a release. This scenario is unlikely for the following reasons: the location of the line is in an area where forklift use is typically for the aid of refrigeration maintenance employees; no rmal loading and unloading will not require that forklifts occupy this area; the mechanical integrity program for regular maintenance, inspection and testing, and replacement of equipment, if necessary; and the emergency response plan and equipment in place at the facility. ACCIDENT HISTORY There were no reportable accidents in the past five years. EMERGENCY RESPONSE PROGRAM This facilitys emergency response program is based on the OSHA requirements for Emergency Action Plans (29 CFR 1910.38 and 1910.119) and HAZWOPER (29 CFR 1910.120). We have trained employees for emergency response and maintain a written emergency response plan. This plan is coordinated with the Local Emergency Planning Committee (LEPC) and the local fire department. We conduct annual drills for implementation of the emergency response plan at the facility with the participation of the LEPC and the fire department. The last training for plant personnel was in the first quarter of 1999. The pla nt will be updating its emergency response program in the summer of 1999. |