Flav-O-Rich Greensboro, NC - Executive Summary |
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RISK MANAGEMENT SUBMISSION STATEMENT Flav-O-Rich Dairy 3939 W. Market Street Greensboro, NC 27407 This is to inform all interested persons, including employees that Flav-O-Rich Dairy, Greensboro, NC is complying with OSHA's Process Safety Management Standard (called Process Safety Management or PSM), Title 29 Code of Federal Regulations (CFR) 1910.119, and EPA's Risk Management Program regulations (called RM Program), Title 40 CFR Part 68, to deal with the risks involved with the storage, handling, and processing of hazardous chemicals. In this way we promote overall plant, worker, and public safety. These programs enable our facility 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. Our safety programs are applied to any activity in volving hazardous chemicals including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. Any group of vessels which are interconnected and separate vessels which are located such that a hazardous chemical could be involved in a potential release shall be considered a single process. Our safety programs prevent accidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment. These rules are detailed and improved as necessary. They are also communicated to and accepted by all employees at the facility. DESCRIPTION OF PROCESS The Greensboro Facility is an ice cream processing, freezing, and storage facility. The facility uses ammonia in an industrial refrigeration system to maintain temperatures in milk tanks, coolers, glycol chillers, ice builder, and freezers. The refrigeration system is also used to freeze ice cream. Ammonia refrigeration is the only process subject to the Risk Management Legislation. WORST CASE SCENARIO Failure of the high pressure receiver containing 17500 lbs. of ammonia with the receiver quantity limited to 80 % of the vessel capacity by facility procedures resulting in a ten minute release. Under worst-case weather conditions, ammonia could travel 1.7 miles before dispersing enough to no longer pose a hazard to the public. This scenario is unlikely for the following reasons: worst- case weather conditions are uncommon; the vessel is enclosed in a building that would withstand and help to contain such a release; industry standards for the manufacture and quality control of pressure vessels; ammonia is not corrosive in this service; pressure safety valves limit operating pressure in this vessel; the accident prevention program in place at the facility including the mechanical integrity program for regular maintenance, inspection and testing, and replacement of equipme nt, if necessary; installed ammonia sensors in the system to warn of leaks; alarms and the auto-dialing system in place to warn operating personnel of process upsets; and the emergency response plan and equipment in place at the facility. ALTERNATIVE RELEASE SCENARIOS Rupture of a 1/2" line in the engine room would result in a release of 150 lbs. of ammonia over a time period of ten minutes. Under common weather conditions, ammonia could travel .1 miles before dispersing enough to no longer pose a hazard to the public. This particular scenario was chosen as an alternative because it is in an area of the plant where it could be struck and result in a release. This scenario is unlikely for the following reasons: all forklift drivers are made aware of the dangers of ammonia and are properly trained; the accident prevention program in place at the facility including operating procedures to have personnel present at all times during any forklift use, and the mechanical int egrity program for regular maintenance, inspection and testing, and replacement of equipment, if necessary; and the emergency response plan and equipment in place at the facility. ACCIDENT HISTORY There have been two reportable accidents at the facility in the past five years. The first incident involved the release of ammonia into the sewer system. Water which had been used to purge ammonia vapor was accidentally disposed of into the storm sewer. The quantity released was approximately 48 lbs. and there were no injuries or evacuations as a result of the incident. Since this incident, there has been substantial training on the hazards of ammonia. The second incident at the facility happened on January 2, 1997. A liquid feed line vibrated loose in the production area. The facility estimated that it lost 100 pounds of ammonia. The fire department was called and they limited access to the plant as a precautionary measure. The leak was fixed in two hours, and the a mmonia never reached off the premises. As a result of this incident, the emergency training has been updated and operating procedures have been changed. EMERGENCY RESPONSE PROGRAM This facility's emergency response program is based on the OSHA requirements for Emergency Action Plans (29 CFR 1910.38 and 1910.119) and HAZWOPER (29 CFR 1910.120). We have trained employees for emergency response and maintain a written emergency response plan. This plan is coordinated with the Local Emergency Planning Committee (LEPC) and the local fire department. We conduct annual drills for implementation of the emergency response plan at the facility with the participation of the LEPC and the fire department. The facility is equipped with a siren to warn the community of an emergency. The last training at the plant was on August 14, 1998. |