SouthEastern Freezer, Inc. / King's Delight #4 - Executive Summary |
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RISK MANAGEMENT SUBMISSION STATEMENT Southeastern Freezer, Inc. / King's Delight #4 1155 Candler Road Gainesville, GA 30504 This is to inform all interested persons, including employees that Southeastern Freezer, Inc. / King's Delight #4 is complying with OSHA's Process Safety Management Standard (called Process Safety Management or PSM), Title 29 Code of Federal Regulations (CFR) 1910.119, and EPA's 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 Southeastern Freezer, King's Delight #4 facility is a poultry processing, freezing, and storage facility. The facility uses ammonia in an industrial refrigeration system to maintain temperatures in three cold storage freezers. The refrigeration system is also used to freeze poultry in 16 blast cells. In addition to the cold storage the facility houses a poultry-processing facility. The ammonia refrigeration system is used to maintain temperatures in the processing areas. Ammonia refrigeration is the only process subject to the Risk Management Legislation. The facility contains 59,000 pounds of the chemical in four systems. The facility maintains a full time refrigeration maintenance staff that conducts multiple service inspections on a daily basis. In addition there is a computer control 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 18,000 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 condi tions, ammonia could travel 2.6 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; 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 facility 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 The release of ammonia through a safety relief valve on the intercooler in the engine room #3 system would result in a release of 250 pounds of ammoni a to the atmosphere. A release of this type would last no longer than 10 minutes before maintenance employees could stop the leak from occurring. Under common weather conditions, ammonia could travel .1 miles before dispersing enough to no longer pose a hazard to the public. This particular scenario was chosen as an alternative because safety relief valves are subject designed to relieve pressure from the system if an overpressure condition exists. This scenario is unlikely for the following reasons: under normal conditions the pressure of this vessel is approximately 25 psig and the relief valve is set to relieve at 150 psig; the relief valves in the plant are replaced directly after a release or every five years as a part of the mechanical integrity program; the control system has automatic responses to high pressure conditions that will turn equipment on or off as necessary to maintain safe conditions; and the emergency response plan and equipment in place at the facility is c onstantly reviewed and updated. ACCIDENT HISTORY There have been three reportable releases in the past five years. All of the releases were handled by plant personnel and none of the releases reached any off-site receptors. The first release occurred on August 29, 1995. The leak was located in a freezer storage room. Personnel responded to the event immediately and isolated the air unit tube that was the source of the problem. As a result of the incident, approximately 90 pounds of ammonia gas was released into the freezer. Personnel used ventilation to remove the ammonia vapor from the room. As a result of the incident, the unit was replaced and there have been no further problems. As a precaution, the facility destroyed 30,000 pounds of poultry which could have become contaminated. That was less than 10% of the total amount of poultry contained in the freezer. The second and third releases were on July 1 and 7 of 1996. Both involved the same 3/8 inch line in blast cell n umber 1. The amount of ammonia lost was ten pounds of gas on the July 1, 1996 and 20 pounds on July 7, 1996. In both cases, the leaks were handled by personnel of Southeastern Freezer, Inc. The leak was repaired and the remaining vapor was removed from the area using exhaust fans. Neither of the leaks reached any off-site receptors. Since July 7, 1996 the plant has not had any substantial leaks. The facility renovated the entire refrigeration system in 1998. Included in this upgrade was the addition of a central control system to monitor any irregular pressures or temperatures as well as the presence of ammonia in any rooms. EMERGENCY RESPONSE PROGRAM This facility's 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 Com mittee (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 update of the facility's emergency response plan was on May 7,1999. |