DOT Foods, Inc. (Vidalia) - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The DOT Foods facility has an emergency response plan in effect. The Emergency Response Plan (Plan) is detailed in the Emergency Planning and Response section of this PSM/RMP document. This Plan was designed to meet the following objectives: 1.) To save lives. 2.) To minimize and avoid injuries. 3.) To protect the environment. 4.) To minimize property damage. DOT Foods maintains a safety committee whose members are the designated emergency coordinators for the facility who will respond to minor leaks. The Plan provides the response organization and notification procedures, evacuation routes, ammonia health hazards, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility. This Plan is reviewed and updated at least once per year. This Plan was reviewed and updated to ensure compliance with the PSM and RMP regulations, as well as to incorporate fa cility changes. STATIONARY SOURCE AND REGULATED SUBSTANCE The DOT Foods ammonia refrigeration system was built in 1990. The ammonia refrigeration process was designed and constructed in accordance with all applicable federal, state, and local regulations. The facility is located at 1120 W. North St., Vidalia, Georgia 30474. The ammonia refrigeration system uses 16,000 pounds of ammonia for dock operations, cold storage, and freezer storage. The majority of the system is located in the machine room including vessels and compressors. The condensers and the Thermosyphon Receiver are mounted on the roof above the machine room. Evaporators are located in their respective cold storage rooms/areas. HAZARD ASSESSMENT SUMMARY Worst Case Release Result Summary Scenario Description: Release of the maximum quantity of chlorine that can be stored in a vessel - 13,100 pounds in 10 minutes. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed, and F stabil ity. The reference table, Exhibit 4-4, from the EPA's Risk Management Program Guidance for Ammonia Refrigeration for rural topography was used to determine the distance to the toxic endpoint of 200 ppm. This release reaches offsite and may affect public receptors. No environmental receptors were affected by this potential release. Alternative Release Result Summary Scenario Description: A release of ammonia gas from a 1/4 inch diameter leak. The release rate of ammonia due to the pressure of the tank is 100 pounds per minute. The meteorological conditions used were 3 meters per second wind speed, and D stability.The reference table, Exhibit 4-5, from the EPA's Risk Management Program Guidance for Ammonia Refrigeration for rural topography was used to determine the distance to the toxic endpoint of 200 ppm. This release reaches offsite and may affect public receptors. No environmental receptors were affected by this potential release. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS The DOT Foods facility was designed and constructed in accordance with the Uniform Mechanical Code which specifically outlines requirements for the safe operation of ammonia refrigeration systems. These safety features include ammonia sensors in the machine room as well as sensors in selected cold storage areas, and automatic shut down systems. In addition, the majority of the ammonia is maintained inside the machine room or outside on the roof above the machine room (condensers and Thermosyphon Receiver). In addition to the Uniform Mechanical Code, the facility will operate in accordance with the International Institute of Ammonia Refrigeration (IIAR) guidelines. In particular, the IIAR Bulletin 110, "Startup, Inspection, and Maintenance of Ammonia Refrigeration Systems." There are ammonia and temperature sensors placed in strategic locations in the freezer, cooler, and dock areas. In the event of ammonia detection, a facility alarm sounds and a visible alarm is triggered. Ammonia sensors are located throughout the facility in the Machine Room, Dock Area, Cooler Areas, and Freezer Area. These sensors are tied to a central computer that alarms and calls an outside alarm company. The alarm will activate at one set concentration level. FIVE YEAR ACCIDENT HISTORY There is no accident history at this facility which commenced operation in 1990. EMERGENCY RESPONSE PROGRAM The DOT Foods has an emergency response plan in effect at the facility. Two operators at the facility are trained to use SCBAs and will respond to minor leaks by shutting down the system and ventilating the machine room. DOT Foods, Vidalia will also call 911 in order for reach the Fire Department who will also respond to the release. DOT Foods emergency plan provides the response organization and notification procedures, evacuation routes, ammonia health hazards, and mitigation procedures which will be implemented to respond effectively to emergency sit uations that may arise at the facility. This Plan is reviewed and updated at least once per year. This Plan was reviewed and updated to ensure compliance with the PSM and RMP regulations, as well as to incorporate facility changes due to the renovation of the facility. PLANNED CHANGES TO IMPROVE SAFETY The Process Hazard Analysis conducted on 11/9/98 provided recommendations to improve safety at the DOT Foods facility located at 1120 W. North St., Vidalia, Georgia. The latest recommendation is scheduled to be complete by 8/1/99. R01 Install an emergency switch outside of the machine room to shut down the system. R02 Establish a sensor concentration level to shut down the machine room. A suggestion is to have a visual and audible alarm set at half the immediately dangerous to life or health value (150 ppm), or a level that will shut down the compressors. The ventilation fans should also respond to this concentration level. R03 Train two people to use SCBAs and respond to minor leaks by shutting down the system and ventilating the machine room. The fire department will also be used as responders to an ammonia release. R04 Include in the Mechanical Integrity program a procedure to replace or recertify relief valves every five years or sooner if one unseats. R05 Include in the maintenance program to annually check for rust, especially around fittings. R06 Make eye protection accessible and include in operator training to wear eye protection when working on the system. R07 Include in the Training program that once personnel at the facility are informed that ammonia is present and the action to take if they smell ammonia to sign a certification page showing that they have been trained. R08 Implement an evacuation plan and perform a drill once a year. Include in the Emergency Response Plan a standard assembly area and an alternate site. R09 Include a procedure to account for truck carriers and passengers and how to notify them in case of an emergency, s uch as an ammonia release or fire. DOT Foods, Vidalia would like to note that truck carriers will sign an entry form prior to entrance onto the facility. R10 Include in the Training program to have operators sign a certification page to verify that they have had training. R11 Have the operator give an office employee a definite time of finishing a task when working on the roof. DOT Foods, Vidalia would like to note that employees will also carry a portable radio when performing work on the roof. R12 Include in the Mechanical Integrity program to inspect the roof area once a week. R13 Include in the Mechanical Integrity program to verify that the king solenoid valve closes on an annual basis. R14 Include in the Mechanical Integrity program to test low level switches on an annual basis. R15 Include in the Mechanical Integrity program to annually test level switch, vessel and fitting inspection, and to paint if necessary. R16 Include in the Mechanical Integrity program to check the high and low level switches quarterly. R17 Ensure that operating procedures include an oil draining procedure and that these procedures are included in operating procedures. R18 Set up lock-out/tag-out procedures when working on the ammonia system. R19 Check manufacturer's recommendations regarding the frequency of the ammonia sensor calibration requirements and include it in the maintenance program. R20 Reduct air vent so that contaminated air is not ducted into the battery room from the machine room. R21 Include in the Mechanical Integrity program to keep fans clean. Ensure that lockout - tagout is performed during maintenance. R22 Include in the maintenance program to check safety cut-outs on compressors annually. R23 Follow the manufacturer's recommendations for maintenance on the compressors. R24 Establish lockout - tagout procedures when performing maintenance on the condenser. R25 Include in the Mechanical Integrity to check pumps & fans, and replace belts. R26 Determine the location at which the drain in the machine room empties. Ensure that the evacuation assembly area is not located near this location. R27 Install emergency shut down switches inside the battery room and outside the machine room. R28 Place two extra 10-minute escape masks in the machine room. R29 Ensure that the person responsible to notify the proper authorities has the names and phone numbers readily available. R30 Install a visible strobe light in the battery room. Tie the visual light to the ammonia detector inside the machine room. See recommendation R02. R31 Ensure that ammonia safety placards are installed on all doors to the machine room. R32 Consider installing a hoist on the machine room roof so the operator is able to transfer tools and other heavy objects to the roof. R33 Place wind socks in locations that are visible form all potential emergency exits. R34 Consider adding an automatic switch to open exhaust fans once the detector senses ammo nia instead of operator entering the machine room. See recommendation R02. R35 Establish an evacuation plan that includes notification of employees on the PA system. R36 Train the necessary employees (i.e., Dock Supervisor) in the proper response action to an ammonia alarm. R37 Consider labeling piping relief valves and other important valves (shut-off valves, etc.) within the system. R38 Print out the system's normal set points from the central computer, so that a hard copy is present. R39 Include in the Operating Procedures a written set of procedures (Start-up, Shut-down, Oil Draining, etc.) for the ammonia system. R40 Provide daily log sheets for the system's parameters (pressure, temperatures, levels, etc.) in order for operators to perform a walkthrough. R41 Verify that "911" on facility cell phones reach the fire department/police (if not, program the appropriate telephone numbers). |