Lucky Stores, Inc. - San Leandro - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

Lucky Stores, Inc. ("Lucky") is a diversified retailer of grocery products. Lucky is a wholly owned operating unit of American Stores Company (ASC, Salt Lake City, UT). Lucky operates many retail grocery stores throughout California that are supplied through a number of distribution and transportation complexes, one of which is located in San Leandro, California.  The San Leandro distribution operation employs over 200 people.  Warehouses storing frozen foods, meat, produce, and delicatessen products are cooled by two separate ammonia refrigeration systems, one system for refrigeration of frozen foods that contains 17,500 pounds of anhydrous ammonia, and one system for refrigeration of perishable products in storage that contains 24,000 pounds of anhydrous ammonia. Anhydrous ammonia is subject to EPA regulation under 40 CFR 68, Accidental Release Risk Management of Highly Hazardous Chemicals. 
 
Pursuant to the Risk Management Plan (RMP) regulations (40 CFR 68) and the Process Safety Man 
agement (PSM) standard (29 CFR 1910.119), Lucky has developed a comprehensive PSM written program to protect employees and the surrounding community from exposure to ammonia.  The facility completed a process hazards analysis (PHA) for ammonia using the industry standard What-If? Analysis developed through the International Institute for Ammonia Refrigeration. The PHA was completed using technical and operations staff from the Lucky facility as well as experienced facilitators from Dames & Moore, an outside engineering firm. 
 
Lucky is committed to minimizing accidental releases of ammonia from the refrigeration process at the San Leandro distribution center. Lucky's implementation of the revised PSM program includes employee education in the hazards of ammonia and measures that can be used to reduce employee and community exposure to accidental releases of ammonia. The plans include preventive maintenance programs (mechanical integrity) for the ammonia system, and a program for both pr 
e-startup safety reviews and management of changes (MOC) to this system. The program also includes specific requirements for safe work practices (such as safe approaches to welding and similar hot work) and safety requirements for contractors who may be hired to work on the system. 
 
Lastly, the PSM written program incorporates the Lucky distribution center's emergency response plan and places special emphasis on handling accidental releases of hazardous chemicals and coordination of emergency response with local fire departments and other emergency response organizations. 
 
The Lucky distribution center has never experienced a release of ammonia involving consequences that affected residents or the environment. However, as part of the RMP requirements, Lucky undertook a review of the potential offsite consequences of the accidental releases of the largest vessels in the system.  Although such a release is highly unlikely, the regulation requires this review.  
 
The worst case scenario wa 
s assumed to be the release of the entire contents of the 20,230-pound recirculator for the perishable products warehouse. The analysis of this release indicates that a potential exposure of an area approximately 1.72 miles in diameter (distance to endpoint of 0.86 miles) would result. The total population within the potential exposure area is estimated to be 9,923.  Within this area there are schools, residences, parks, and commercial/industrial areas. 
 
In determining the alternate case scenario for ammonia, Lucky analyzed incidents occurring at other refrigeration facilities and the results of the internal process hazards analysis (PHA).  Owing to the fact that there are two refrigeration processes, one at the meat/deli warehouse and one at the frozen food warehouse, Lucky analyzed alternate cases for both and reports both results here.  The scenario chosen for both ammonia systems assumes a =" hole in a liquid return pipe from the outside condensers. Such a release would affect an a 
rea of 0.34 miles (0.17 miles to the toxic endpoint) and create the potential to affect approximately 192 persons (from the perishable good warehouse) and 170 persons (from the frozen foods warehouse).  Local businesses and residences are located within these areas.
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