Greensboro Distribution - Perishable Foods - Executive Summary |
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EXECUTIVE SUMMARY Background Data In accordance with Title 40 of the Code of Federal Regulations Chapter 68 (40 CFR 68) promulgated by the Environmental Protection Agency (EPA), Harris Teeter, Inc. Perishable Foods Distribution submits this Risk Management Plan (RMP) for operations at their Greensboro, North Carolina facility. Harris Teeter's operations include the warehousing of grocery products for public consumption. Harris Teeter has been in operation at this facility for 1 year providing quality grocery products and over 92 jobs to the local community. Accidental Release Prevention and Emergency Response Policy Harris Teeter is committed to protecting the health of its associates, the surrounding community, and the environment; therefore it is Harris Teeter's policy to maintain compliance with 40 CFR 68 as well as Occupational Safety and Health Organization (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Federal Regulations Chapter 19 10, Section 119 (29 CFR 1910.119), and OSHA's Hazardous Operations and Emergency Response regulations (29 CFR 1910.120). Stationary Sources and Regulated Substances Harris Teeter is subject to section 112(r) of the Clean Air Act because ammonia, a regulated substance, is present at the facility in amounts greater than 10,000 pounds. Harris Teeter is required to maintain low temperatures in the food warehousing areas of the facility that are within standards required by the United States Department of Agriculture (USDA) to ensure quality in the delivered products. Harris Teeter uses anhydrous ammonia (the 112(r) regulated substance) as a refrigerant to maintain 173,000 ft2 within the required range of operating temperatures. Anhydrous ammonia is a typical refrigerant for food warehousing. Harris Teeter's refrigeration system consisting of receivers, a thermosyphon, compressors, evaporators, condensers, and piping can contain a maximum amount of 12,410 pounds of anhydrous ammonia. Worst Case Release Scenario As required by 40 CFR 68 Subpart B, Harris Teeter has evaluated a worst-case release scenario for anhydrous ammonia using the parameters specified by the EPA. Harris Teeter's worst-case release scenario is the rupture of the largest single receiver (1,283 gallons) when filled to 75% capacity (maximum fill capacity allowed by engineering controls) over a 10-minute period. Using the EPA's RMP*Comp program, the maximum distance to the toxic endpoint is 0.8 miles. The worst-case release scenario was developed following EPA regulations and is not considered to be a likely release scenario. During normal operations, Harris Teeter maintains the receivers at 40% capacity and a high alarm sounds at 60% capacity. Only during pump-down or by-pass operations do the receivers have the potential to be filled to 75% of capacity. The receivers are operated in pump-down or by-pass mode less than 1% of the time during the year. Alternative Release Scenario A more realistic release scenario (alternative release) was developed by Harris Teeter taking into consideration the 14-year history of a similar existing Harris Teeter facility and the hazards identified in the process hazard analyses (PHAs) conducted under the Occupational Safety and Health Organization (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Federal Regulations Chapter 1910, Section 119 (29 CFR 1910.119). The most likely release scenario identified by Harris Teeter would be a release caused by a >-inch flange gasket failure in an ammonia vapor line. In developing the release parameters of this alternative scenario, Harris Teeter considered the most common gasket size and the average response time of the community's Hazmat team. Using EPA's RMP*Comp program, the maximum distance to the toxic endpoint is 0.10 miles. Accidental Release Prevention Program The ammonia refrigeration system is designed and constructed in accordance with ANSI/II AR 2-1992 Standard for Equipment, Design, And Installation of Ammonia Mechanical Refrigerating Systems. To prevent and mitigate accidental releases of anhydrous ammonia, Harris Teeter has implemented several precautionary measures. Harris Teeter has developed and implemented a PSM program pursuant OSHA regulations and as such, has evaluated the system for the potential of anhydrous ammonia releases. Some of the controls installed to prevent catastrophic releases of ammonia are process equipment (vents, pressure relief valves, check valves, excess flow device, and manual shutoffs) and automated controls (automatic shut-offs, ammonia leak detection system,interlocks, emergency power and air, and electrical distribution system grounding). In addition, Harris Teeter has spent time with the local Hazmat team who would respond to potential ammonia releases and the Hazmat team has toured the facility to become familiar with the location of the system equipment, valves and emergency shu t-offs. Harris Teeter has developed standard operating procedures (SOP) for all associates and contractors that have contact with the ammonia refrigeration system, that incorporate safety measures into the procedures. These safety procedures were developed by refrigeration system operators and are reviewed on an as-needed basis. Process safety information for the refrigeration system is reviewed anytime there is a change in the process or SOP. Harris Teeter requires associate participation in development of overall safety measures used at the plant by means of company newsletters, total quality management teams and training sessions. Pursuant to written management of change procedures established by Harris Teeter, any changes to the operating procedures are to be communicated to affected employees. Harris Teeter understands that maintaining the refrigeration system in good working order is essential to preventing accidental releases; therefore Harris Teeter has implemented a preve ntative maintenance program. The preventative maintenance program is scheduled, documented and managed by the Ammonia Refigeration Technician to ensure that regular maintenance occurs on the system. Also, to ensure the mechanical integrity of critical refrigeration system components, x-ray corrosion testing is conducted every five years. To ensure that Harris Teeter's control measures are effective in maintaining the safe operation of the plant, regularly scheduled audits are performed on the ammonia refrigeration system: 7 In accordance with the PSM program, Harris Teeter conducts detailed PSM compliance audits every three years that incorporates review of process safety information, process hazard analysis, operating procedures, training programs, system mechanical integrity, management of change, pre-start up review procedures, compliance audit procedures, incident investigation procedures, employee participation programs, hot work permit procedures, and contractor safety proced ures. 7 In addition, Harris Teeter is audited by the parent company's (Ruddick Corporation) Corporate Environmental Manager and Corporate Safety Manager on an annual basis. 7 Harris Teeter's insurance carrier also conducts independent audits on an annual basis. 7 The State of North Carolina Department of Labor, Boiler Safety Bureau conducts an assessment on the pressure vessels every two years. 7 The USDA audits the facility on an annual basis. Five-Year Accident History Over the last five years, Harris Teeter has not experienced an accidental off-site release of anhydrous ammonia from the ammonia refrigeration system. Emergency Response Program Harris Teeter has documented emergency response procedures in three documents entitled Special Situation Manual, Emergency Evacuation Program and Emergency Response Plan in order to facilitate response efforts in the event of an on-site or off-site anhydrous ammonia release. Included in the documents are measures to be taken internally by Harris Teeter as well as measures to be taken by off-site response agencies. Harris Teeter has no on-site personnel to respond to accidental ammonia releases. Personnel that work on the ammonia system receive initial training and update training every 3 years or as needed reviewing safe work practices. These associates are also trained in the proper use of respirators and receive an annual fit test. To assure that the local governmental response agencies are familiar with Harris Teeter's emergency response procedures, Harris Teeter has met with the local fire department and Hazmat team. To plan for an ammonia release with off-site effects, Harris Teeter includes procedures/equipment to passively mitigate the release, procedures to inform local response agencies, transportation maps for response agencies, evacuation route maps, and procedures for public communication. In addition to the local response agencies, Harris Teeter has arranged emergency resp onse assistance with a local clean-up contractor. In the event of an anhydrous ammonia release with off-site effects, the general public will be warned using the following methods: 7 Broadcast message via the Guilford County Central Dispatch 7 Police and fire vehicles equipped with public address systems, and 7 Door-to-door notification of residents (if time permits). Planned Changes to Improve Safety As a result of Harris Teeter's initial process hazard analyses, several changes are planned at the facility to improve safety and prevent anhydrous ammonia releases. These changes are scheduled to be implemented by September 2000 and include improvements to operating procedures, and preventative maintenance program relocation of emergency shut down equipment to safer locations, increased protection of ammonia equipment (e.g., guarding), increased ammonia safety training, improvements to security and formalizing inspections. |