C&S WHOLESALE GROCERS INC. WEST - Executive Summary |
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C & S Wholesale Grocers, Inc. Facility Maintenance / Engineering Department EPA Risk Management Program Executive Summary Westfield Facility Summit Locks Road Westfield, Ma. Accidental Release Prevention and Emergency Policies C& S Wholesale Grocers, Inc. is the third largest grocery wholesaler in the United States. We have facilities located in six states in the greater New England region, massing over 5million square feet of distribution warehouses. C&S Wholesale Grocers management team understands the responsibility in protecting its employees, and surrounding environmental receptors. The continued safety of all persons within the property boundaries and adjacent receptors will continue to be a priority of our maintenance and engineering team. This facility incorporates a proactive and reactive emergency response program encompassing both systems to mitigate accidental releases, and preventative measures. This program is designed and maintained in accordance with Osier s existing Process Safety Management of highly hazardous chemicals, 29CFR1910.119 and new EPAs Risk Management Program regulation under, 40CPRPart 68. The V.P. of Maintenance and Engineering is responsible for the management of the prevention and emergency response programs. The design and management of our programs has been facilitated by both in-house and outsourced professionals. Its purpose is to prevent and plan for the occurrence of a significant release. The programs intent and application is to effectively minimize the consequences of a significant release of hazardous and potentially toxic substances. Facility Overview and Regulated Substances Handled The facility located at the above-mentioned address, is subject to Program 3 of the EPAs RM Program. The facility encompasses approximately 345,000 square feet of ammonia refrigerated warehouse. This facility contains a maximum inventory of 56000lbs of anhydrous ammonia. (CAS # 7662-41-7). Since the possibility of a catastrophic release could affect offsite receptors, the systems are subject to the Program # requirements of the RM program. The system is used to control various temperatures of food products located within the facility. The system is controlled by a central computer command center and monitored at all times for specified points. The system can be controlled both at the central computer, and remotely via modem ports. The use of ammonia sensors within the engine rooms and immediate area are connected to a alarm system and corresponding alert system. All responsible parties are notified via telecommunication systems, beepers and pagers from a central monitoring station. Summary of Worst-Case and Alternate Case Scenarios The information contained within the scenarios provided has been used for its probability and potential of an actual occurrence. After developing several potential scenarios for each area, the worst case model of each required scenario was used for this filing. The commitment of C&S is to take the, high road in regards to its safety programs and implementations of OSHA and EPA guidelines. It is believed that the safest approach is not only best but required. The modeling software utilized for this submission is, RMP COMP. Worst Case Scenario The worst case scenario for this facility involves the release of 27,800 lbs. of anhydrous ammonia, under a release rate of 1530 lbs/min. within an enclosed space, in direct contact with outside air due to a failure within the high pressure receiver. The modeling software utilized for this scenario, RMP COMP, has used a release duration of 10min, liquefied under pressure, with a with speed of 3.4 MPH, a stability class of F with an air temperature of 77 degrees F. The resulting ammonia could travel 2.2 miles in a described rural area before dispersing enough to no longer pose a hazard to the public. (Toxic endpoint @ 0.14 mg/l :basis ERPG-2) The Worst-case release scenario is unlikely for the following reasons: -The worst-case weather conditions which were used for this scenario are uncommon; -Industry standards were followed for the manufacture and quality control of the vessels and IIAR guidelines followed for installation: -Ammonia is not corrosive in this service and the vessels are relatively new. -Pressure safety valves limit operating pressures in these vessels -Corporate commitment for five- year change-out of pressure safety valves; -The facility has preventative maintenance program in place to maintain the on-going integrity of the vessels; -The facility has a training program designed to ensure that the system is operated by qualified personnel: -Areas are designated authorized personnel only and kept locked; -The facility emergency response procedures which enable trained personnel to respond quickly to isolate any potential release. AlternateCase Scenario The alt ernative release scenario at the facility involves the release of 56000 pounds of anhydrous ammonia, under a release rate of 1320 lbs/min. over a 40 minute period, due to a fracture in a = liquid bypass line. Under alternative release weather conditions in a described rural area, wind speed 6.7 MPH, stability class D, resulting ammonia could travel 0.5 miles before dispersing enough to no longer pose a hazard to the public. (Toxic endpoint @ 0.14 mg/l :basis ERPG-2) -The Alternative release scenario is unlikely for the following reasons: -Industry standards were followed for the manufacture and quality control of the lines and IIAR guidelines followed for installation; -Ammonia is not corrosive in this service and the vessels are relatively new; -The facility has preventative maintenance program in place to maintain the on-going integrity of the lines; -The facility has a training program designed to ensure that the system is operated by qualified personnel: -Areas are designated authorized personnel only and kept locked; -The facility emergency response procedures which enable trained personnel to respond quickly to isolate any potential release. Description of the Accidental Release Prevention Program ? Employee Participation This program involves the employees in establishing and implementing the program. Employees are also in involved when a process hazard analysis is conducted, and audited. The program also ensures that all employees have complete access to the program. ? Process Safety Information Collected information is provided which enables the employees to identify and understand the potential hazards of the system. The written information includes the ammonia MSDS and a description of the design of the ammonia refrigeration system. ? Process Hazard Analysis Written formal studies conducted utilizing the, What-if / Checklist protocol have been completed to identify all feasible poten tial hazards. ? Operating Procedures Written procedures have been generated to detail and describe safe and practical standard procedures to safely operate and maintain the ammonia refrigeration system and its integral components. ? Training An in-depth, comprehensive training program has been developed to meet and exceed training guidelines as issued by OSHA, and the IIAR. This training encompasses both classroom instruction, and practical exams and observations. Annual refresher training exercises are conducted to maintain and certify our refrigeration technicians and level A hazmat team. ? Contractors All outsourced contractors must pass a safety orientation and required provide criteria, regardless of their interaction with the ammonia refrigeration system. Additionally contractors are periodically reviewed for their compliance with company protocol. All outsourced contractors are coordinated by the maintenance and engineering department for inclusion in this requisite. ? Pre-startup Safety Review A pre-startup safety review is completed for all new ammonia projects to verify that all implemented safety programs are in place. All projects completed for the ammonia refrigeration system are reviewed for their respective scope of work, completeness and compliance with design standards. ? Mechanical Integrity This program has been developed to maintain the system and its components, using preventative maintenance measures as dictated by manufactures and IIAR recommendations. Annual inspections performed by a Factory Mutual representative of the boiler and machinery division, are completed to add to the completeness of our program. ? Hot Work Permit The development and use of these permits is mandatory for all employees and contractors. The permits are issued by the maintenance and engineering department and are reviewed by Factory Mutual representative. No cutting, welding or burning shall commence without the issuance of a hot work permit. ? Mana gement of Change All changes to the ammonia refrigeration system are documented as dictated by OSHA under the PSM. Written documentation is generated and filed per company directives. ? Incident Investigation An incident investigation team has been assembled comprised of ammonia refrigeration technicians, refrigeration manager and the V.P. of Maintenance and Engineering. This team reviews all incidents and near incidents, and generates documentation for the occurrence. ? Compliance Audits Current OSHA PSM programs are audited per established guidelines to ensure completeness and accuracy. Audits have been completed in preparation for this submission. Five-Year Accident History No-ammonia-related incidents have been identified for the facility in the previous five years resulting in on-site or off-site consequences. No releases of substantial amounts ie. > 10 lbs. have been experienced. Emergency Response Program A corporate wide emergency response program has bee n implemented at all refrigerated warehouse facilities. This program includes procedures describing the response efforts necessary for an ammonia incident, and other emergencies. This program is coordinated with local fire departments. The corporate wide commitment to employee and community safety has been demonstrated by the purchase, installation and maintenance of a fully equipped Level A HazMat Trailer on site. An (30)member hazmat team has been collected, and trained to effectively mitigate an ammonia incident detected by alarm and alert systems. ? Organizational plan and responsibilities legend ? Communication procedures and requisites ? Detailed action plans and contingency efforts ? Fire aid procedures ? Emergency responders are located at each facility ? EMT procedures ? Evacuation plans ? Description of outside assistance available ? Site re-entry procedures and requisites ? Training programs and drills Facility Design Criteria The design specifications for the faci lity incorporate several measures to aid in the initial prevention and preventative maintenance of the ammonia refrigeration system. The construction of an interior catwalk aids in the protection of evaporators and lines. |