Deep South Products, Inc./Margarine and Cheese - Executive Summary |
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1. Corporate Prevention and Emergency Response Approach The Deep South Products, Inc./Margarine and Cheese Plant (Deep South) is a manufacturing facility owned by Winn-Dixie Stores, Inc.(Winn-Dixie) located at Gainesville, Georgia. Winn-Dixie requires each facility to develop and maintain accident prevention programs and an emergency response plan appropriate to the site. Each site is also responsible for regulatory compliance issues that apply to the site. Winn-Dixies corporate and division environmental and safety personnel provide assistance in training for site employees and in budgeting and procurement of safety and training services. 2. Description of Stationary Source Deep South is located at 2255 White Sulpher Road, Gainesville, Georgia. The facility consists of areas for manufacturing and packaging of cheese and margarine products. On site freezer and cooler storage is provided for perishable items prior to distribution to the Winn-Dixie Warehouses. Deep South has one ammonia refrigeration system that exceeds the 10,000 lb. RMP threshold quantity. The compressors and some ammonia refrigeration vessels are located in the compressor room located at the South side of the building. All the refrigeration equipment including the high pressure receiver (HPR) is located inside the building, except some piping and the condensers. The high pressure receiver (HPR) is the largest capacity vessel in the ammonia refrigeration system. This vessel is capable of holding approximately 4,800 lbs. of ammonia. This is the vessel used for the worst-case scenario analysis. The Deep South facility also has propane on site which exceeds the flammables 10,000 lb. RMP threshold quantity. The propane is kept in an above ground storage tank that has a capacity of 29,846 gallons or 110,000 pounds. Propane is used as a backup fuel on site for the facilitys boiler. The propane storage tank is located along the east end of the northern property boundary. 3. Descript ion of the Worst Case and Alternative Release Scenarios The Worst Case release scenario for ammonia is the rupture of the HPR, releasing 4,800 lbs. of ammonia gas over a ten minute period. Under worst case weather conditions, considering passive mitigation credit, the ammonia gas could travel 0.6 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .14 mg/L), using the Ammonia Guidance. The alternative-case release scenario was characterized by a mitigated leak rate of 42.4 lbs/min. from the HPR receiver liquid line outlet connection failure caused by worker/human error or corrosion of the pipe. Under normally expected weather conditions, taking into consideration the passive mitigation credit, the ammonia gas could travel 0.10 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .14 mg/L), using the Ammonia Guidance. The Worst Case release sc enario for propane is the failure of the storage tank when filled to the greatest amount which would release 110,000 lbs. of propane. It is assumed that the entire contents are released as vapor which finds an ignition source, 10% of the released quantity is assumed to participate in the resulting explosion. The distance to the endpoint of 1 psi for the worst case analysis is 0.4 (2,006 feet) miles using the OCA Guidance. The Alternative-Case release scenario for propane is an accident during delivery truck filling of the propane storage tank. Failure of the process pipe attached to the storage tank happens due to truck driver error at time of delivery. The contents of the pipe is released over ten minutes until the excess flow valve stops the flow. The resulting unconfined vapor disperses until its concentration reaches the lower flammability limit. The distance to the endpoint for the lower flammability limit for the alternative scenario is less than 0.10 miles (528 feet). This release has the possibility of extending beyond the facility boundary since the storage tank is next to the property boundarys fence line. 4. Prevention Program This facility exceeds the ammonia threshold quantity in the ammonia refrigeration system for the OSHA Process Safety Management (PSM) Standard, 1910.119, and is therefore subject to the PSM requirements. The facility also exceeds the flammables threshold quantity for its propane system and is therefore subject to the RMP requirements. For RMP compliance purposes, this places the Deep South facilitys refrigeration process in the Program 3 level and the propane process in Program 2 level. Deep South will use its PSM program as the required Program 3 Prevention Program for ammonia. The facility will address the required Program 2 Prevention Program for the propane process by expanding its PSM program for the applicable seven elements. Program 3 Prevention Progam The Deep South facility has a program in place to compl y with the OSHA Process Safety Management Standard, 29 CFR 1910.119. The PSM Program was re-engineered in 1998 and covers the ammonia process. The PSM Program includes a preventative maintenance plan which requires all ammonia refrigeration equipment to be periodically inspected and serviced. This will ensure that the equipment remains in good operating condition and will minimize the probability of accidents due to faulty equipment. In developing the PSM Program, Deep South also developed written operating procedures for the refrigeration processes. These procedures cover all phases of operation and include information on safety devices. These procedures will be used to train all operators and mechanics who work on the ammonia refrigeration processes to ensure consistency of operation and minimize human error. In addition, all refrigeration mechanics receive training through the Refrigeration Engineers and Technicians Association (RETA) training course. These measures ensure t hat all refrigeration operators and mechanics are properly trained. Existing safe work practices such as Confined Spaces, Lockout/Tagout, Hot Work Permitting, Line Breaking, and Access Control were reviewed and updated to ensure that all non-routine work can be performed safely. Other components of the PSM program include collection and review of all equipment information, the development of updated Piping & Instrumentation Diagrams (P&IDs), and the correction of any equipment design deficiencies found. These actions will ensure that the equipment meets all refrigeration industry standards and that accurate equipment information will be available when needed. To ensure that the Deep South refrigeration staff has the skills necessary to identify unsafe conditions, Process Hazard Analysis (PHA) training was conducted. The staff then participated in a PHA of this process. Other PSM procedures, including Employee Participation, Contractors Program, Management of Change, Pre-Startup S afety Review, Compliance Audits, and Incident Investigation are also part of the program to ensure continued safe operation and prompt correction of deficiencies. The PSM Program receives full support of plant management and involvement of employees at all levels. Program 2 Prevention Program The Program 2 Prevention Program will be completed before the end of 1999 and will include Equipment Information, a Hazard Review, Operating Procedures, a Training Program, Maintenance Procedures, Compliance Auditing Procedures, and an Incident Investigation Procedure. The procedures developed for the PSM program; for example, Training, Compliance Auditing, and Incident Investigations will be modified to address propane. There will also be a mechanism to ensure that information, procedures, and training are updated when there are changes made to the propane process. 5. Accident History The Deep South facility has had no accidental releases of ammonia or propane in the past five years. 6. E mergency Response Program The Deep South facility has an Emergency Response Program in place. The program complies with 29 CFR 1910.38. The site also has some internal emergency response capability and is developing a program to comply with paragraph (q) of 29 CFR 1910.120. The current plan has been coordinated with the local Fire Department. Notification is made locally by dialing 911. |