Georgia Freezer Company - Executive Summary |
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Executive Summary A. Describe Accidental Release Prevention and Emergency PoliciesGeorgia 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 equipme nt and 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 HandledThis company operates a freezing and storage warehouse for the perishable food industry. This facility operates two ammonia refrigeration systems to provide cooling and freezing capabilities. The amount of anhydrous ammonia (CAS #7662-41-7) contained in each system is in excess of 10,000 pounds. The maximum combined inventory of both system is 48,000 lbs. Since ammonia releases from both systems could pose a risk of offsite public impact and both systems are regulated under the OSHA PSM standard (29 CFR 1910.119), the systems are 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 4.8 million cubic foot facility. Two refrigeration systems provide two-stage and 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 porti ons of the system include the condenser, 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 machine room areas.C. Summary of Worst-Case and Alternative Release ScenariosThe same Worst Case Release Scenario is developed for each of the two refrigeration systems. The Worst Case Release Scenario is determined to be a catastrophic release from V-1 receiver. The V-1 Receiver operates at 77!F. (ambient temperature) and approximately 131 psig.The System J#1 main ammonia receiver is 3.9 feet in diameter and 17.6 feet tall. When 50% filled, the receiver capacity is approximately 4,000 pounds of anhydrous ammonia.The System #2 main ammonia receiver is 4 feet in diameter and 18 feet tall. When 50% filled, the receiver capacity is approxima tely 4,300 pounds of anhydrous ammonia.Assumed is that the release occurs through a circular hole located at the bottom of the main receiver. Using EPA-default parameter values, the full content of the receiver is released within ten minutes through a 0.55-inch hole and a 0.58-inch hole in the System #1 and System #2 receivers, respectfully. For this Worst Case Release Scenario, the distance from source to toxic endpoint is 0.74 miles and 0.76 miles for System #1 and System #2 failures, respectfully.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 AnalysisAn 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 77!F. and 131 pounds per square inch. Using EPA-suggested meteorological parameters for alternative conditions, the distance from release point to the toxic endpoint is 0.64 miles. This scenario applies equally to by System #1 and System #2.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 co nsidered would be the Emergency Shutdown System which permits system to equalize to 50-60 psi.D. Description of the Accidental Release Prevention ProgramThe prevention program (OSHA Process Safety Management CFR 1910.119) consists of the following elements:Employee ParticipationProcess Safety InformationProcess Hazard AnalysisOperating ProceduresTrainingContractorsPre-startup Safety ReviewMechanical IntegrityHot Work PermitManagement of ChangeIncident InvestigationCompliance AuditsE. Five-Year Accident HistoryNo 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 ProgramThis 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 accou nt 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 Emergency Management for Hall County (770-536-3132). G. Planned Changes to Improve SafetyA compliance audit was conducted in May of 1999. Any recommendations resulting from this audit will be evaluated and implemented as required.Georgia Freezer CompanyGainesville, Georgia |