Publix Super Markets, Inc.-Lakeland Facility - Executive Summary |
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PUBLIX SUPER MARKETS, INC.- LAKELAND FACILITY RISK MANAGEMENT PLAN EXECUTIVE SUMMARY 1. Corporate Prevention and Emergency Response Approach The Publix Super Market, Inc. (Publix) Lakeland Facility is located at 3045 New Tampa Highway, Lakeland, Polk County, Florida. Publix 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. Publix 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 The Publix Lakeland Facility is located south of Interstate I-4 in the western portion of the city of Lakeland, Polk County, Florida. The facility consists of a dairy and ice cream manufacturing plant, bakery facility, produce warehouse building, and deli meats plant for dist ribution to the Publix Super Markets. The Lakeland Facility has four separate ammonia refrigeration systems which all four exceed the 10,000 lb. RMP threshold quantity. The four ammonia refrigeration systems' equipment are located in each of four machine or compressor rooms. Each system has a high pressure receiver (HPR) associated with the system. For the purposes of the worst-case analysis the largest capacity HPR vessel for the dairys ammonia refrigeration system was chosen because it was the largest high pressure vessel at the facility and is located outside. The HPR is located outside of the machine room and has a capacity of 23,314 lbs. of ammonia. Alternative-case scenarios for all four refrigeration processes were analyzed using the HPRs from the respective processes considering passive mitigation when appropriate as well as administrative limits on the contents of the vessels. The HPR at the bakerys ammonia process is the only vessel inside the machine room for which the enclosure passive mitigation was applied. The Publix Lakeland Facility uses propane as a backup fuel for the boilers at the bakery facility. The fuel system has a maximum intended inventory maintained by Publix of approximately 90,720 pounds of propane, which exceeds the RMP threshold for propane. The propane is stored in one aboveground horizontal storage tank, which is located near the southeastern property line. 3. Description of the Worst Case and Alternative Release Scenarios 3.1 Ammonia The Worst Case release scenario is the rupture of the HPR vessel located at the dairy building, releasing 23,314 lbs. of ammonia gas over a ten minute period. Under worst case weather conditions, the ammonia gas could travel 2.7 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 lookup tables. The Alternative Release Scenario for the HPR at the dairy process is characterize d by a leak rate of 1,005.9 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 0.60 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 OCA lookup tables. The Alternative Release Scenario for the HPR at the deli process is characterized by a leak rate of 948.3 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 0.60 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 OCA lookup tables. The Alternative Release Scenario for the HPR at the produce process is characterized by a leak rate of 890.7 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 0.60 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 OCA lookup tables. The Alternative Release Scenario for the HPR at the bakery process is characterized by a leak rate of 98.6 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, taking in consideration the passive mitigation of the machine room, the ammonia gas could travel 0.20 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 lookup tables. 3.2 Propane The worst-case release for propane assumes that the total quantity of 90,720 lbs. was released in to a vapor cloud and 10 percent was assumed to detonate in a vapor cloud explosion. Since the OCA Guidance requires the user to choose either urban or rural, rural land use was chosen. The endpoint distance of 0.30 miles for the worst-case release was determined using OCA Guidance Reference Table 13. For the alternative-case scenario analysis, the quantity of 6,027.9 lbs., a release rate of 602.79 lbs./min., and a duration of 10.0 minutes were used. As in the worst-case, rural land use was assumed for the alternative-case scenario. Since the calculated release rate for the alternative-case release was less than 1500 lb./min and the LFL for propane is 36, the endpoint distance for the alternative release was determined using the data presented in OCA Guidance Table 28, which gave a distance of 0.01 miles or 528 feet. 4. Prevention Program 4.1 Prevention Program 3 This facilitys four refrigeration systems exceed the ammonia threshold quantity for the OSHA Process Safety Manage ment (PSM) Standard, 1910.119, and are all therefore subject to the PSM requirements. For RMP compliance purposes, this places all four of the Lakeland Facilitys refrigeration processes in the Program 3 level. The Lakeland Facility will use its PSM program as the required Program 3 Prevention Program. The Lakeland Facility has a program in place to comply with the OSHA Process Safety Management Standard, 29 CFR 1910.119. The PSM Program was established in October 1994 for the four ammonia processes. 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, the Lakeland Facility also developed written operating procedures for the refrigeration process. These procedures cover all phases of operation and include info rmation 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. 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 Lakeland Facility refrigeration staff has the skills necessary to identify unsafe conditions, Process Hazard Analysis (PHA) tra ining 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 correction of deficiencies. The PSM Program receives full support of plant management and involvement of employees at all levels. Prevention Program 2 The propane process at the Publix Lakeland Facility satisfies the RMP rule criteria for a Program 2 process. These criteria are that the process could affect public receptors in a worst-case accidental release of propane and that the process is not subject to PSM. The requirements of the RMP rule for Program 2 processes are the same as the Program 3 requirements, except that fewer Prevention Program elements are required. Publix has a prevention program in place that satisifies the Program 2 requirements, including written operating procedures, written maintenance procedures, employee training, an incident investigation procedure, and a compliance audits procedure. Publix has also collected and verified the propane equipment information and has performed a hazard review of the process. 5. Accident History The Lakeland Facility has had no accidental releases of ammonia or propane that have resulted in offsite consequences in the past five years. 6. Emergency Response Program The Lakeland Facility has Emergency React Procedures in place. The program complies with 29 CFR 1910.38. The site also has some internal emergency response capability and has developed a program to comply with paragraph (q) of 29 CFR 1910.120. The current plan has been coordinated with the City of Lakelands Fire Department and the Polk County Hazardous Materials Response Team, and the Local Emergency Planning Committee. Notification is made locally by dialing 911, and by notifying Florida State Warning Point at (800) 320-0519 or (904) 413-9911. |