Fry's Food & Drug Stores - Executive Summary |
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1.0 EXECUTIVE SUMMARY 1.10 Accidental Release Prevention And Emergency Response Policies The Fry's Food & Drug Store's refrigeration system uses pure anhydrous ammonia (a commonly used refrigerant for industrial systems) as the refrigerant. Given the quantity handled, anhydrous ammonia is considered a hazardous substance by EPA. Many of the properties that make ammonia valuable as a refrigerant also requires that precautions and procedures be in place to protect employee and public health and safety during a chemical emergency. It is the policy of Fry's Food & Drug Store to be in compliance with all applicable federal and state rules and regulations. Safety at our facility is inherent on the manner in which anhydrous ammonia is handled. While the design of the facility incorporates a multitude of safety devices, safe handling procedures combined with appropriate training of our personnel are key aspects to maintaining safety at our facility. We have a written Process Safet y Management (PSM) plan that complies with the regulations stipulated by 29 CFR 1919.119. A crucial component of this plan is the Emergency Response Plan, developed in compliance with the Emergency Response provisions of 29 CFR 1910.120. The Emergency Response Plan includes pre-emergency planning and coordinating with outside parties. This enables those who deal with emergencies to have a course of action to effectively deal with unplanned events. 1.20 Facility Description And Substances Handled 7 The Fry's Food & Drug Store stores and distributes refrigerated and non-refrigerated foods. Storage requires the use of a refrigeration system to preserve the integrity of processed foods. This refrigeration process uses ammonia as a refrigerant. Access to the facility is restricted to authorized employees, management personnel, and contractors. 7 The regulated substance handled at this facility is anhydrous ammonia. 7 At this facility, two separate refrigeration systems are currentl y in use. The Produce Warehouse system has a total anhydrous ammonia inventory of 13,000 pounds. The Frozen Warehouse refrigeration system contains 9,100 pounds of ammonia. Although process piping does not interconnect these systems, they are housed in a single structure, separated by a common wall. Given the relatively close proximity of storage vessels for both systems, a catastrophic event involving one system, such as a major fire, explosion, or natural disaster, could theoretically impact the other. Therefore, both systems are considered a single process for purposes of this RMP. The combined total inventory of anhydrous ammonia is 22,100 pounds. There is no standby make-up inventory kept on-site. 1.30 The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario Release scenarios were modeled using RMP*Comp (Version 1.06), a software program develope d by the National Oceanic and Atmospheric Administration (NOAA) and EPA. Offsite receptors were defined using the LandView III (Version 1.0) system. This system estimates residential population within the circle defined by the endpoint of the worst-case and alternative release scenarios. In addition, it lists whether certain types of public receptors and environmental receptors are within the circles. Populations and distances to offsite receptors such as schools, hospitals, and residences are based on 1990 Census data contained in LandView III. 7 Worst-Case Scenario. Catastrophic failure of the Freezer Warehouse Recirculation vessel located in the compressor room when filled to the greatest amount would release 9,100 pounds of liquid ammonia. This scenario presumes that the entire contents are released. This distance to the toxic endpoint for the worst-case scenario is 1.3 miles from the point of release. This distance extends beyond the facility fence line, and would encom pass a population of 20 with the closest residence about 200 feet away, inside of this release zone. A school and hospital are about 1.5 miles, located outside of this release zone. No other public or environmental receptors are located within this zone. This worst-case scenario would not likely occur unless an act of nature (e.g., earthquake) physically compromised the tank. The structural integrity of the tank is safeguarded by periodic inspection for mechanical integrity to prevent a rupture due to tank degradation. The tank is also safeguarded from rupture from over-pressurization. It is a rated pressure vessel hydro-tested to 375 psi and equipped with 250 psi pressure relief valves. Relief venting is directed through piping to a water filled diffusion tank, preventing atmospheric release of ammonia gas during over-pressurization events. The design specification of the tank only allows a maximum capacity of 80% to 90% at 800F, limiting the total amount of ammonia in the system. During high demand, the High Pressure Receiver may only be filled to a fraction (~30%) of capacity. 7 Alternative Scenario. Several alternative scenarios can generate the equivalent of a 1" opening in a high pressure liquid line. Alternative scenarios could include an opening created by a valve sheared off, a large gasket leak, or a pressure relief valve release. These scenarios presume a release duration of 10 minutes resulting in a loss of 13,000pounds of liquid ammonia, the total inventory of the Produce Warehouse refrigeration system. This scenario was selected because a release of this type would occur outdoors resulting in the highest potential exposure to offsite receptors. This distance to the toxic endpoint for the alternative scenario is 0.7 miles from the point of release. This distance extends beyond the facility fence line, and would encompass a population of 6 with the closest residence about 200 feet away, inside of this release zone. A school and hospital are about 1.5 miles, located outside of this release zone. The severity of release from this scenario would likely be less since safety system provisions are in place to limit the release duration to less than ten minutes through the use of appropriately placed isolation valves. Relief venting is directed through piping to a water filled diffusion tank, preventing atmospheric release of ammonia gas during over-pressurization events. 1.40 General Accidental Release Prevention Program And Chemical-Specific Prevention Steps Fry's Food & Drug Store complies with EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations. The design and construction of this facility was in accordance with published standards, tests or recommended methods of trade, industry or governmental organizations. Fry's Food & Drug Store's written PSM plan incorporates many policies and procedures to ensure safe operation and maintenance of this facility. Plan e lements essential to safe operation of the refrigeration system include employee participation, process hazard information, process hazard analysis, operating procedures, training, contractor safety, pre-startup safety review, mechanical integrity, management of change, hot-work permits, incident investigation, emergency response and planning, and compliance audits. This plan will be reviewed annually and updated as necessary by the Fry's Food & Drug Store Refrigeration Supervisor. Training is provided to ensure that each employee involved in operating a process has been trained in an overview of the process, the operating procedures, and safety considerations. This training uses guidelines developed by the International Institute of Ammonia Refrigeration (IIAR) and Refrigeration Engineers Technology Association (RETA). Only qualified maintenance personnel operate and interact with the refrigeration system. This minimizes the chances of inadvertent error in operation that could l ead to a release of ammonia. Startup, shutdown, and any onstream adjustments are handled by these qualified persons. 1.50 Five-Year Accident History There has been no reportable release of ammonia at the Fry's Food & Drug Store in the past five years. 1.60 Emergency Response Program Fry's Food & Drug Store has a written Emergency Response Plan developed to ensure that precautions and procedures are in place to protect employee and public health and safety during a chemical emergency. It complies with the provisions of OSHA Emergency Response regulations, 29 CFR 1910.120. The Emergency Response Plan includes pre-emergency planning and coordinating with outside parties. This enables those who deal with emergencies to have a course of action to effectively deal with unplanned events. This plan has been reviewed with the Phoenix Fire Department. The approach in the development of this plan has been to identify the ammonia emergencies most likely to occur at Fry's Food & Drug St ore and establish precautions and procedures to protect life safety and health during an emergency. The refrigeration process has back-up prevention systems to keep processing malfunctions from becoming ammonia release emergencies. If an emergency does occur, the following response personnel, facilities, and equipment are in place: 7 Incident Command Center 7 Emergency Alarm and Communication System 7 Safe Rooms, Evacuation Plans, and Assembly Points 7 Personal Protective Equipment In the event of an emergency that may have an impact offsite, outside agencies are the designated responders, specifically the Phoenix Fire Department and refrigeration contractor. The role and procedures for obtaining external emergency assistance have been established with the Phoenix Fire Department, including the Maricopa County HazMat Team. The Phoenix Fire Department is responsible for notification of any potentially affected neighbors. This plan will be reviewed annually and updated as necess ary by the Fry's Food & Drug Store Refrigeration Supervisor. 1.70 Planned Changes To Improve Safety This facility started storage and distribution operations of the Produce Warehouse in 1978. The Freezer Warehouse refrigeration system began operations in April 1995. All system components meet design specifications in ANSI/IIAR, equipment, design, and installation of ammonia mechanical refrigerating systems. All pressure vessels are built according to American Society of Mechanical Engineers (ASME), ASME Boiler and Pressure Vessel Code, pressure vessels. Any upgrades or extensive maintenance work performed in the future will be in compliance with those standards applicable at that time. Process Hazard Analysis (PHA) Priority List of Recommendations complies all follow-up actions. Those recommendations with the top priority ratings will be resolved in the next 3 months. Other recommendations warranting action will be completed in 6 months. |