Gordon Food Service Springfield Distribution Cente - Executive Summary |
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EXECUTIVE SUMMARY In accordance with section 112(r) of the Clean Air Act and 40 CFR part 68, this report fulfills the requirements of the Risk Management Plan (RMP) program for Gordon Food Service. Envirologic Technologies, Inc. (Envirologic) completed this RMP, on behalf of Gordon Food Service's facility located in Springfield, Ohio. A brief summary of the RMP developed for GFS is presented below and in the attached computer file. Accidental Release Prevention and Emergency Response Policies at GFS GFS has established policies and developed emergency response teams to protect the safety of their workers and the public. Their Environmental Policy Statement describes GFS's commitment to release prevention in the following phrases: "Gordon Food Service is committed to excellence and leadership in protecting the environment. We strive to minimize adverse impact on the air, water, and land through pollution prevention and energy conservation. Gordon Food Service seeks t o demonstrate its responsible corporate citizenship by striving to adhere to all environmental regulations. We promote cooperation and coordination between industry, government, and the public toward the shared goal of preventing pollution at its source." Additionally, GFS's Corporate Safety Policy defines GFS's commitment to the safety of its workers and surrounding community in the following phrases: The protection of human life is one of our most important objectives in the course of conducting business. The safety of all those associated with GFS, including the general public, cannot be compromised. It is our goal to operate in both a safe and productive manner. The preservation of people, equipment, and merchandise will enable us to be a quality supplier. These unwanted events can be prevented through "know-how" and a willingness to do our jobs in a safe manner. These responsibilities rest with every one of us, and will be a part of our performance objectives. GFS demonstrates their commitment to preventing releases to the environment by being actively involved with the Clark County Local Emergency Planning Commission (LEPC). GFS has developed in conjunction with the Clark County LEPC a Chemical Emergency Response Plan & Standard Operating Procedures (Emergency Response Plan) for GFS's Springfield Distribution Center. The stated purpose of this Emergency Response Plan is: - To ensure the safety of Emergency Response Team Personnel during a hazardous materials emergency. - To provide adequate safety precautions in protecting Gordon Food Service employees and the public from harm caused by a chemical release. - To provide the Emergency Response Team with management direction during all operations directly related to a hazardous material emergency. GFS has established a strong relationship with the Springfield Fire Department to assist GFS personnel in implementing GFS's established policies and the procedures established in this E mergency Response Plan. Site Description and Substances Handled Gordon Food Service (GFS) distributes general grocery items to restaurants, cafeterias, and Marketplace stores throughout the Midwest. GFS utilizes refrigerated warehouses (Distribution Centers) to receive product from venders, which is then distributed to Marketplace stores and clients within a 250-mile radius. The Springfield Distribution Center for GFS is located in an industrial park south of the City of Springfield, Ohio. The structure of the Springfield Distribution Center consists of a warehouse building subdivided to house building maintenance; administration; dry, refrigerated, and frozen product inventory; and unloading and loading dock areas. Refrigerated and frozen inventory cooling at the Springfield Distribution Center is provided by an anhydrous ammonia refrigeration system located within the Distribution Center. The storage and use of the anhydrous ammonia is the only regulated substance used by GFS that is subject to the Risk Management Plan (RMP) requirements. Ammonia System Design The refrigeration system at the Distribution Center contains approximately 31,000 pounds of anhydrous ammonia. The refrigeration system consists of the following basic elements: - compressor, - controlled pressure receiver, - liquid pump, - evaporator, - condenser, and - associated piping and valves. This refrigeration system is a closed loop system. Refer to the attached process flow diagram for further design of the refrigeration system at the Springfield Distribution Center. The major components of the refrigeration system including the controlled-pressure receiver at the Springfield Distribution Center are enclosed in a concrete block room (compressor room) within the warehouse facility itself. The only exterior components of the refrigeration system is the condenser and associated piping and valves. The compressor room has only two access points. One access point is a door that opens into the warehouse itself and the second access point is a door that leads directly to the outside of the facility that remains continuously locked from the inside. The evaporators are suspended from the ceiling of the warehouse throughout the refrigerated and frozen food product areas. Worst-Case Release Scenario The Environmental Protection Agency (EPA) has defined a worst-case release as "the release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to a specified endpoint." Basically, a worst- case release is a catastrophic event that destroys the process and/or storage vessels and causes and immediate release of all stored materials. In order to determine the radius of impact to off-site receptors, an offsite consequence analysis was conducted. RMP*Comp, developed by the National Oceanic and Atmospheric Administration (NOAA) and the Environmental Protection Agency (EPA ), was the model utilized to perform the calculations for the offsite consequence analysis. The following site-specific parameters and required default parameters were utilized to conduct the offsite consequence analysis for the Springfield Distribution Center: - Quantity of ammonia liquefied under pressure: 31,780 pounds (present in the largest single vessel - controlled-pressure receiver (site-specific value) - Height of Release: ground level (default value) - Release Duration: 10 minutes (default value) - Mitigation Measures: Release in enclosed space in direct contact with outside air due to the presence of two doors one of which leads outside (default value) - Topography: Urban Surroundings (site-specific value) - Wind Speed: 1.5 meters/second (default value) - Stability Class: F (default value) - Air Temperature: 77 degrees Fahrenheit (default value) - Compressor Room volume: 59,616 ft3 (site-specific value) Since the controlled pressure receiver is located within the wa rehouse, a calculation was performed to assess if the building would fail as a result of the release. The following equation was utilized to determine the building strength as recommended by the EPA: Compressor Room Volume/Quantity of ammonia 59,616 ft3/31,780 pounds = 1.88 ft3/pounds Since the answer is greater than 0.1ft3/pound, the building will be able to sustain and contain an ammonia release. Therefore, the default values for a Mitigated Release will be able to be utilized for calculating the estimated distance to the Toxic Endpoint. Next, site specific values and default values were input into the RMP*Comp model to calculate the Toxic Endpoint and Estimated Distance to the Toxic Endpoint. The calculated results are 0.14 mg/l and 1.5 miles, respectively. In order for a release of this magnitude to occur, all automated and engineered fail-safe mechanisms would have to have been destroyed. Basically, a catastrophic event like a tornado, earthquake, or explosion would have to destroy the Controlled Pressure Receiver located inside the warehouse instantaneously to meet the assumptions required by a worst case scenario. Since the Controlled Pressure Receiver is located in the Compressor Room that has limited access and has no vehicle traffic it is highly unlikely that a catastrophe of this magnitude would occur damaging this vessel. Additionally, the compressor room has only one door that leads to the outside of the facility and it is locked from the inside. This door is only used for emergency purposes. Therefore, there are no direct outlets present for a release of anhydrous ammonia to impact outdoor air. Alternate Release Scenario GFS has reviewed their ammonia refrigeration system to determine a more likely release scenario. The Process Hazard Analysis conducted in accordance with OSHA's Process Safety Management Standard 29 CFR 1910.119 indicated that a release caused by a hole in piping caused by corrosion or a leakin g valve along the piping run located on the roof of the warehouse is a more plausible release scenario. Under normal operating conditions, the roof-top piping runs are under pressures that fluctuates between 100 to 130 psig. The fluctuations in the piping run pressure are due to the change in ambient air temperature. The absolute maximum pressure possible for this system is 150 psi. The alternate release scenario was calculated assuming the rooftop piping run was damaged creating a 2-inch hole (diameter of the pipe) and the system reaches a maximum possible pressure of 150 psi. The release rate was calculated utilizing the Bernoulli Equation: QR = HA x (203)(Pg)1/2 Where: QR = Release rate (pounds/minute) HA = Hole area (square inches) Pg = Gauge pressure (psig) Using this equation, the release rate was calculated to be 4972 pounds of anhydrous ammonia per minute. Inputting the calculated release rate of 4,972 pounds/minute and the default release duration of 60 minu tes into the RMP*Comp model, an estimated distance to the Toxic Endpoint was calculated to be 0.5 miles. This radius of impact is significantly smaller than the worst case scenario however; it could still impact the surrounding public. The alternate release scenario model assumes that all of the engineered fail safe measures present in the ammonia refrigeration system at GFS fail. The fail safe measures that would have to fail include automatic and manual alarms and shutoff mechanisms including manual shut down of the system following GFS's standard operating procedures by refrigeration personnel. Therefore, the odds of the alternate release scenario described above occurring are still very low. GFS does feel that this scenario has a greater chance of occurring than the worst case scenario previously described. Accidental Release Prevention Program and Chemical-Specific Prevention Steps To prevent the accident release scenarios described above and others outlined in GF S's Process Hazard Analysis at the Springfield Distribution Center, GFS has implemented an aggressive prevention program since the refrigeration system went on line in 1998. GFS has made a commitment to understand the environmental aspects and safety aspects of the refrigeration system operations. In response to this increased knowledge and awareness, GFS has devoted much time and effort to insuring the refrigeration system at the Distribution Center is working efficiently, effectively, and safely for not only on-site employees but also the residents and public areas surrounding the Distribution Center. GFS is subject to the OSHA Process Safety management (PSM) requirements. Therefore, the PSM program GFS has instituted is in compliance with these standards, at minimum. GFS's prevention program includes the following: - Daily manual and automated pressure checks of temperature and pressures in engine room. - Weekly inspection of exterior insulation, valve stations, and piping runs. - Bi-weekly leak checks of all valves and valve stations. - Preventative maintenance program based on recommended engineering practices and observations from inspections. - Inspections of Preventative Maintenance Work Orders and daily/weekly inspections to ensure they are completed properly and in a timely fashion. - Utilization of a software system (Maximo) to assist GFS in monitoring the preventative maintenance program for both Distribution Centers. - Systematically upgrading refrigeration system equipment and components. - Installation of Industrial Refrigeration thermal Insulation as a vapor barrier system to all refrigeration vessels, valves, piping, and fittings including hot gas lines to the system and defrost/condensing temperature. - Equipping each refrigeration system with alarms, and automated activation of relief valves and automated shutdown once the system reaches dangerously high levels of pressure. - Development of a HAZMAT team and an Emergency Ac tion Plan to effectively respond to any potential accidents and leaks specifically relating to the refrigeration system in accordance with OSHA Standard 29 CFR 1910.120 and 29 CFR 1910.38(a), respectively. - Emergency response training for all HAZMAT team members. - All necessary communication equipment and personal protective equipment to respond to an anhydrous ammonia release are provided and maintained by GFS. In addition to these measures, GFS has implemented an Employee Training Program for Refrigeration Technicians. The Training Program includes both on-site and off-site training seminars through the University of Wisconsin, the Manufacturer (Vilter and Frick) and training modules and competency tests developed and supplied by the International Institute of Ammonia Refrigeration (IIAR). Training is completed by each Refrigeration Technician on an annual basis. Five-Year Accident History An accidental release of anhydrous ammonia has never occurred at the Spring field Distribution Center. Emergency Response Program GFS has developed an extensive Emergency Response Program to respond to a chemical release from the anhydrous ammonia refrigeration systems at the Springfield Distribution Center. GFS has developed in conjunction with the Springfield Fire Department an Emergency Response Plan for the Springfield Distribution Center. The Emergency Response Plan details: - pre-emergency planning procedures, - GFS's Emergency Response Team organizational structure, - training requirements, - emergency recognition and prevention procedures, - emergency alerting procedures, - evacuation procedures, - emergency medical services, - emergency response procedures, - medical surveillance procedures, and - post emergency response critique procedures. GFS has provided not only employee training but also all necessary resources needed to adequately, quickly, and safely respond to a release of anhydrous ammonia. GFS personnel are trained to contact the Springfield Fire Department to respond to and mitigate a release of anhydrous ammonia at GFS's Springfield Distribution Center when a resulting release approaches 100 pounds or a spill over 35 ppm of ammonia which can not be operationally isolated. GFS has coordinated with the Springfield Fire Department whose master plan includes coordinating with area hospitals and local emergency response companies to ensure all parties are aware of their roles and responsibilities in the event a release does occur. Off- site notification comes from the Springfield Fire Department according to their direction. Upon their contact they assume the leadership role for emergency response and make all off-site evacuation and sheltering communications to the community. GFS employees required to do work in and around the anhydrous ammonia refrigeration system, are trained and annually updated in identifying and initially responding to a release in accordance with the OSHA Standards . To ensure response procedures and employee training is complete and up to date, GFS in conjunction with the Springfield Fire Department conducts period emergency response inspections. After completing each period emergency response inspection the Springfield Fire Department and GFS refrigeration personnel review the methods and procedures followed to coordinate the response effort and mitigate a release to assess their effectiveness and to determine if changes to response procedures are necessary. In any event, GFS and the Springfield Fire Department are fully prepared to respond to an accidental release of anhydrous ammonia and more importantly protect GFS employees, and people living and working around the Springfield Distribution Center. Planned Changes to Improve Safety The Springfield Distribution Center is a new Distribution Center brought on line in April of 1998. GFS has been able to introduce many engineering fail-safe mechanisms into the new refrigerati on system that improve the odds of a release of anhydrous ammonia from occurring. These engineered fail-safe mechanisms have increased the safety for all on- site employees and significantly reduced the risk of a release of anhydrous ammonia from not only occurring but also from migrating off-site and impacting the surrounding residences and businesses. GFS is committed to continually improve the operations of the refrigeration system to continue to reduce the threat of a release occurring. As part of GFS's continual improvement commitment, several administrative improvements are proposed for the immediate future. These administrative improvements include but are not limited to: - Developing a Hot Work Program for refrigeration contractors, - Further enhancing the Compliance Audits Program by developing an Internal Auditing Program and peer review from personnel at other Distribution Centers, - Continually enhancing the Employee Training Program to allow GFS to obtain the best available information and technology for improving refrigeration system efficiency and safety, - Developing procedures for selecting and assessing contractors to ensure, at minimum, they meet OSHA's safety requirements, and - Expanding the management system developed to address anhydrous ammonia as required by the OSHA Process Safety Management Standard and the RMP to include all chemicals that pose a risk by developing an Integrated Contingency Plan. GFS is considering adopting the principles and management characteristics of an ISO 14000 Environmental Management System to manage environmental, health and safety compliance issues consistently throughout GFS's diversified organization. An Environmental Management System is a proactive voluntary initiative that a company commits itself to going beyond compliance. This system will allow Gordon Food Service to seek improvements in their effort to manage, control and potentially eliminate the risks associated with GFS's daily operational tasks. Pw/auditing/grdfs/80131sfex |