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Roger Wood Foods, Inc.

Parent Companies:
EPA Facility ID:
100000173206
Other ID:
Facility DUNS:
3307345

Location:

Address:
7 Alfred Street
Savannah, GA 31408
County:
CHATHAM
Lat / Long:
32.090, -81.147 (Get map)
Method:
GPS Carrier Phase Kinematic Relative Positioning Technique
Description:
Process Unit
Horizonal accuracy:
11.7 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
David Solana
Phone:
(912) 964-6335
Address:
7 Alfred Street
Savannah, GA 31408
Foreign Address:

Person responsible for RMP implementation:

Name:
Jonathan Hauser
Title:
Plant Manager

Emergency contact:

Name:
Adel Bushnaq
Title:
Maintenance Manager
Phone:
(912) 652-9600
24-hour phone:
(912) 210-6449
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Chatham County LEPC
Full-Time Equivalent Employees:
230
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Sept. 23, 2013
Inspecting Agency:
Fire Department
Using Predictive Filing:
No

Processes:

Ammonia Refrigeration
RMP ID:
1000050744
CBI claimed:
No
Program Level:
3
NAICS:
Meat Processed from Carcasses (311612)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
17,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Process Compliance Partners, Inc
Address:
617 Falcon Fork Way
Saint Johns, FL 32259
Foreign Address:

Phone:
(904) 315-6331

Latest RMP Submission:

Date:
April 25, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000041250

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Ammonia Refrigeration)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Enclosures
not considered:
  • Dikes
  • Berms
  • Drains
  • Sumps

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Ammonia Refrigeration)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

June 21, 2010 at 08:25
ID:
1000033284
NAICS:
Meat Processed from Carcasses (311612)
Duration:
35 minutes
Chemicals involved:
  • Ammonia (anhydrous)
Release events:
Gas release
Weather conditions at time of event
Wind speed:
None
Temperature:
None ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
Yes
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
2
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$500
Known off-site impacts
Deaths:
0
Hospitalizations:
1
Medicals treatments:
1
Evacuated:
200
Sheltered-in-place:
0
Property damage:
$500
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
Off-site responders notified:
Savannah Fire Department
Changes introduced as a result of the accident:
  • Revised emergency response plan

7. Prevention: Program level 3

Ammonia Refrigeration, Meat Processed from Carcasses (311612)
Prevention Program ID:
1000043181
Safety Review Date
Dec. 7, 2012
PHA Update Date
Aug. 24, 2009
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Earthquake
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • None
Mitigation Systems
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
Procedure Review Date
Feb. 25, 2014
Training Review Date
Feb. 25, 2014
Maintenance Review Date
Sept. 14, 2013
Maintenance Inspection Date
April 14, 2014
Equipment Tested
Yes
Management of Change Most Recent Date
Sept. 14, 2013
Management of Change Review Date
Sept. 14, 2013
Pre-startup Review Date
Feb. 25, 2014
Compliance Audit Date
Dec. 7, 2012
Compliance Audit Change Completion Date
June 30, 2015
Incident Investigation Date
May 5, 2013
Incident Invest. Change Completion Date
May 6, 2013
Participation Plan Review Date
Sept. 16, 2013
Hot Work Review Date
Sept. 16, 2013
Contractor Safety Review Date
Sept. 16, 2013
Contractor Safety Eval. Date
April 15, 2014

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
No
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
July 24, 2013
Local Response Agency:
Local Response Agency Phone:
(912) 651-6758
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

EXECUTIVE SUMMARY



Roger Wood Foods, Inc. in Savannah, GA has developed a Risk Management Program in compliance with the Environmental Protection Agency's final Rule 40 CFR Part 68. The regulated substance is anhydrous ammonia with a total inventory charge over the threshold quantity of 10,000 lbs. Since the facility is also subject to the Occupational Safety and Health Administration's PSM Standard 29 CFR 1910.119, Program 3 is required.



ACCIDENTAL RELEASE PREVENTION POLICY



The top priority of Roger Wood Foods, Inc. is to provide a healthy and safe work environment for its employees and the surrounding community. In this effort, Roger Wood Foods, Inc. has developed strict policies and procedures to reduce the risk of an accidental hazardous chemical release. The Process Safety Management (PSM) program acts as a gatekeeper of these policies and procedures.



The requirements of the Occupational Safety and Health Administration (OSHA) PSM Standard CFR 1910.119 mirrors that of Risk Management Prevention Program 3 and therefore has been integrated. Of the 14 PSM elements, 13 focus on accidental release prevention and one on emergency planning and response. It is the commitment of management and employees to follow the established procedures and seek new ways for improvement.



EMERGENCY RESPONSE POLICY



The facility has developed an Emergency Response Plan with the intent to take control of an incident until the Savannah Fire Department arrives on the scene. Once the Fire Department arrives they will assume the lead role. Roger Wood Foods, Inc. has designated and trained employees that will assist in the emergency response. This strategic approach combines the expertise and the response team of the Charlotte Fire Department with the facility and process knowledge of the Roger Wood Foods, Inc. staff. Roger Wood Foods, Inc. provides annual refresher training and schedules periodic meetings and drills with the Savannah Fire Department.



Copies of
the Roger Wood Foods, Inc. Emergency Response Plan has been submitted to the Savannah Fire Department and the Chatham County Local Emergency Planning Committee.



STATIONARY SOURCE AND REGULATED SUBSTANCES



Roger Wood Foods, Inc. is a food processing and distribution facility located in Savannah, Georgia. The process includes refrigerated spaces that utilize anhydrous ammonia as the refrigerant. Anhydrous ammonia is a regulated substance under the Chemical Accident Prevention Provisions, 40 CFR 68.



GENERAL ACCIDENT RELEASE PREVENTION PROGRAM

CHEMICAL-SPECIFIC PREVENTION STEPS



EPA's Risk Management Prevention Program 3, 40 CFR Part 68(D) and OSHA's Process Safety Management Standard 29 CFR 1910.119 outline the facilities accidental release prevention program. Included are 13 Chemical Specific Prevention steps implemented by Roger Wood Foods, Inc. and are summarized below.



Employee Participation - Employees are given shared responsibility with management in the continued evolution of the program.

Process Safety Information - Chemical, equipment, and system information has been compiled to ensure the safe design and operation.

Process Hazard Analysis - Hazardous Operability Study (HAZOP) completed to identify potential hazards and minimize their impact.

Operating Procedures - Standard Operating Procedures developed to ensure the safe operation of the process.

Training - Training program established and operators trained to ensure the safe operation of the process.

Contractors - Contractor program established to ensure only qualified and trained contractor work on or near the process.

Pre-Startup Safety Review - Procedures and check lists developed to ensure all safety requirements are completed before startup of new or modified process.

Mechanical Integrity - Program developed to ensure equipment and systems installed per design specifications and maintained per manufacturer recommendations and good engineering practices.

Hot Work Permit - Per
mit program established to prevent the potential of fire/explosion resulting from hot work near hazardous chemicals.

Management of Change - Procedures established to manage process changes to ensure the integrity of the PSM program is maintained.

Incident Investigations - Procedures established to investigate releases that resulted in or could have resulted in a catastrophic release of a hazardous chemical and to prevent recurrence.

Compliance Audits - Procedures established to periodically review program implementation and to correct as necessary.

Trade Secrets - Policy implemented to provide all necessary information regardless of trade secrets to ensure employee safety.



ACCIDENT HISTORY - LAST FIVE YEARS



Despite Roger Wood Foods, Inc. extensive release prevention program, the facility has experienced one accident in its Five Year Accident History.



On June 21, 2010 an Ammonia alarm was received and when personnel went to investigate the cause, it was found that there was Ammonia leaking from a faulty nipple valve in the engine room. Two employees were treated by medical responders for ammonia inhalation and chemical burns. The estimated Ammonia quantity released was 390 pounds.



EMERGENCY RESPONSE PROGRAM



Roger Wood Foods, Inc. Emergency Response Program calls for evacuation of the facility in the event of a hazardous chemical emergency. With the assistance of the Savannah Fire Department, the facility will respond in performing rescue, control and containment, and clean-up operations. The facility maintains a written Emergency Response Plan to document specific procedures to be implemented in the event of various emergencies, including hazardous chemical releases. The Emergency Response Plan includes procedures for facility evacuation, as well as for notification to the local emergency response agencies, which are responsible for notifying the public. The plan is promptly updated to reflect any pertinent changes taking place within the facili
ty that would require modified procedures.



Roger Wood Foods, Inc. has devised a comprehensive emergency response program, designed to protect both employees and the community in the event of a release. This program is fully described in the facilities Emergency Response Plan in order to facilitate response efforts in the event of a hazardous chemical release. Included in the plan are measures to be taken internally by Roger Wood Foods, Inc. as well as measures to be taken by off-site response agencies.



Roger Wood Foods, Inc. has trained on-site personnel to respond to accidental hazardous chemical releases. These personnel are trained in accordance with 29 CFR 1910.120, Hazardous Operations and Emergency Response regulations according to their duties and function. These personnel also receive initial training and annual update training thereafter.



To assure that the local governmental response agencies are familiar with the Roger Wood Foods, Inc. emergency response procedures, Roger Wood Foods, Inc. has provided copies of the Emergency Response Plan for review and approval by the local agencies.



To plan for an ammonia release with off-site impact, Roger Wood Foods, Inc. includes procedures/equipment to mitigate the release, procedures to inform local response agencies, evacuation route maps, and procedures for public communication.



PLANNED CHANGES TO IMPROVE SAFETY



Roger Wood Foods, Inc. employees are encouraged to identify and communicate areas where safety can be improved. At the time of this RMP submission, there are no planned changes to improve safety.