Georgia Freezer Company - Executive Summary

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Executive Summary  A.    Describe Accidental Release Prevention and Emergency Policies Georgia Freezer Company believes that our workplace should be run in a manner that reduces and/or eliminates the potential for injuries in the workplace. That the cost of injury and illness to employees and damage to Company property is unacceptable. That no job is so important and no service is so urgent that we cannot take the time to perform them safely. That all employees have an individual responsibility in the Company safety program to protect themselves, their co-workers and Company facilities. That in an attempt to minimize the personal and financial loss that can be caused by accidental injury, Management is held accountable for providing safe work conditions for all employees and applying and enforcing safe work practices. Therefore, it is the policy of Georgia Freezer Company to conduct our operations in a manner that will prevent injuries to people and damage to Company property and equipmen 
tand the will comply with all applicable  regulations for safety and health. Accidental Release Prevention and Emergency Policies are designed to comply with OSHA's Process Safety Management (PSM) standard (Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119) and EPA's Risk Management Program (RM program) regulation (Risk Management Programs for Chemical Accidental Release Prevention, 40 CFR Part 68).  The Safety Director is responsible for the management of the accidental release prevention and emergency action programs. The purpose of the accidental release prevention and emergency action programs is 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. B.    Stationary Source and Regulated Substances Handled This company operates a  
freezing and storage warehouse for the perishable food industry.  This facility operates an ammonia refrigeration system to provide cooling and freezing  capabilities.  The amount of anhydrous ammonia (CAS #7662-41-7) contained in the system is in excess of 10,000 pounds.  The maximum inventory of the system is 40,000 lbs.  Since an ammonia release from the system could pose a risk of offsite public impact and the system is regulated under the OSHA PSM standard (29 CFR 1910.119), the system is subject to the Program 3 requirements of the EPA's RM program.     The closed ammonia refrigeration system removes heat from the storage and blast freezers of the 6.3 million cubic foot facility.  The refrigeration system provides single-stage operation with screw compressors for the -35 blast and -10 freezers.  The sub-zero temperatures are provided with low pressure ammonia suction and liquid lines via pumped recirculating accumulators.  The higher pressure portions of the system include the conde 
nser, located on the roof, along with refrigerant vent lines where any leaks can dissipate to the air, joining ammonia produced by lightning where it can be consumed as it goes through a natural biodegrading process.  Normal safeties include: high pressure cut-outs, relief valves, and ventilating systems for the machine room. C.    Summary of Worst-Case and Alternative  Release Scenarios The Worst Case Release Scenario is determined to be a catastrophic release from V-3 Intercooler.  The V-3 Intercooler operates at 10F. and approximately 24 psig. The V-3 Intercooler receiver is 5 feet in diameter and 17 feet tall.  When 50% filled, the receiver capacity is approximately 6,840 pounds of anhydrous ammonia. Assumed is that the release occurs through a circular hole located at the bottom of the Intercooler.  Using EPA-default parameter values, the full content of the intercooler is released within ten minutes through a 1.05-inch hole.  For this Worst Case Release Scenario, the distance from s 
ource to toxic endpoint is 0.87 miles. The worst-case release scenario is unlikely for the following reasons: The worst-case weather conditions which were used for this scenario are uncommon; Industry standards were followed for the manufacture and quality control of these receivers and vessels; Ammonia is not corrosive in this service; Pressure safety valves limit operating pressures in these receivers and vessels and have design margins of safety of about 4 to 1. Alternative Release Scenario Analysis An Alternative Release Scenario is chosen as a pipe failure.  The potential for a pipe failure is significant given the extensive ammonia piping system extending throughout the Facility. Assumed is the failure of a four-inch pipe connected to the main receiver.  The pipe is 100 feet long with a smooth interior.  The receiver serves as an infinite source of anhydrous ammonia at 77F. and 131 pounds per square inch.  Using EPA-suggested meteorological parameters for alternative conditions t 
he distance from release point to the toxic endpoint is 0.64 miles. The Alternative Release Scenario is unlikely for the following reasons: The high pressure liquid lines are located in enclosed areas that could help to contain such a release; Industry standards were followed for the manufacture and quality control of these lines; Ammonia is not corrosive in this service. Vessel design uses a factor of approximately 4 to 1 margin for safety. Active mitigation considered would be the Emergency Shutdown System which permits system to equalize to 50-60 psi. D.    Description of the Accidental Release Prevention Program The prevention program (OSHA Process Safety Management CFR 1910.119) consists of the following elements: Employee Participation Process Safety Information Process Hazard Analysis Operating Procedures Training Contractors  Pre-startup Safety Review Mechanical Integrity Hot Work Permit Management of Change Incident Investigation Compliance Audits   E.    Five-Year Accident History  
No ammonia-related incidents were identified for the facility in the previous five years which resulted in significant on-site or off-site consequences. F.    Description of the Emergency Response Program This facility has an Emergency Action Plan.  The plan contains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures, escape routes, critical operations shutdown procedures, procedures to account for all employees, rescue and medical duties assignment, means of reporting fires and emergencies, name of responsible person, alarm system, training and fire prevention. Georgia Freezer Company is included in the community emergency response plan developed by the Jackson County Emergency Services (706) 367-5202. G.    Planned Changes to Improve Safety A compliance audit was conducted in May of 1999.  Any recommendations resulting from this audit will be evaluated and implemented as required.       Georgia Freezer Company Pender 
grass, Georgia
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