Dixie Packers, Inc. - Executive Summary
DIXIE PACKERS, INC.- MADISON, FLORIDA FACILITY |
RISK MANAGEMENT PLAN
1. Corporate Prevention and Emergency Response Approach
The Dixie Packers, Inc. Facility (Dixie Packers) is a manufacturing facility owned by Winn-Dixie Stores, Inc.(Winn-Dixie) located at Madison, Florida. 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-Dixie's 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
Dixie Packers is located on State Road 53 South in the southeast corner of the city of Madison, Madison County, Florida. The facility consists of areas for manufacturing and packaging of luncheon meats, hot dogs, smoked meats, and freezer an
d cooler storage of these perishable items for distribution to the Winn-Dixie Supermarkets.
Dixie Packers has one ammonia refrigeration system that exceeds the 10,000 lb. RMP threshold quantity. The ammonia refrigeration system's equipment is located in two compressor rooms in the southwest and northeast corners of the building. All of the equipment for the southwest system is located inside the building . The high pressure receivers (HPRs) are the largest capacity vessels in the ammonia refrigeration system capable of holding approximately 5,600 lbs. of ammonia each. The Northeast HPR was used for the worst-case scenario analysis. The northeast HPR is located directly outside of the northeast machine room.
The Dixie Packers 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 30,000 gallons. Propane is used as a backup fuel on site for the facility's boil
ers and ovens. The propane storage tank is located along the southwest property border near the railroad tracks and is delivered by truck to the facility.
3. Description of the Worst Case and Alternative Release Scenarios
The Worst Case release scenario for ammonia is the rupture of the Northeast HPR, releasing 5,600 lbs. of ammonia gas over a ten minute period. Under worst case weather conditions, the ammonia gas could travel 1.4 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 leak rate of 490.5 lb./min. from the HPR liquid supply line due to pipe connection failure from worker/human error or corrosion of the pipe. Under normally expected weather conditions, the ammonia gas could travel 0.40 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration les
s than .14 mg/L), using the Ammonia Guidance.
The Worst Case release scenario 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 0.40 (2006 feet) miles using the OCA Guidance.
The Alternative-Case release scenario for propane is an accident during truck filling of the propane storage tank. Failure of the process pipe connected to the transfer hose happens due to truck driver error. The contents of the pipe is released. The resulting unconfined vapor travels to the lower flammability limit. The distance to the endpoint for the lower flammability limit for the alternative scenario is less than 0.1 miles (528 feet), using the OCA Guidance. This release has the poss
ibility of extending beyond the facility boundary since the storage tank is next to the property boundary's 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 Dixie Packers facility's refrigeration process in the Program 3 level and the propane process in Program 2 level. Dixie Packers 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.
The Dixie Packers facility has a program in place to comply with the OSHA Process Safety Management Sta
ndard, 29 CFR 1910.119. The PSM Program was reengineered in 1998 for 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, Dixie Packers 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 that all refrigeration operators and mechanics are
properly trained. Existing safe work practices such as Lockout/Tagout and Hot Work Permit, were reviewed and updated to ensure that all non-routine work can be performed safely. Other components of the prevention 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 Dixie Packers refrigeration staff has the skills necessary to identify unsafe conditions, Process Hazard Analysis (PHA) training was conducted. The staff also performed a PHA of this process. Other PSM procedures, including Management of Change, Pre-Startup Safety Review, Compliance Audits, and Incident Investigation are also part of the program to ensure continued safe operation and prompt correcti
on of deficiencies. The PSM Program receives full support of plant management and involvement of employees at all levels.
5. Accident History
The Dixie Packers facility has had no accidental releases of ammonia or propane in the past five years.
6. Emergency Response Program
The Dixie Packers 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 Madison County Fire Department and Hazardous Materials Response Team, and the Regional Local Emergency Planning Committee. Notification is made locally by dialing 911, and by notifying Florida State Warning Point at (800) 320-0519 or (850) 413-9911.