Gordon Food Service Grand Rapids Distribution Cent - Executive Summary |
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EXECUTIVE SUMMARY In accordance with section 112(r) of the Clean Air Act and 40 CFR part 68, this Executive Summary fulfills the requirements of the Risk Management Plan (RMP) program for Gordon Food Service, Grand Rapids, Michigan. Envirologic Technologies, Inc. (Envirologic) completed this RMP, on behalf of Gordon Food Service, Grand Rapids, Michigan. A brief summary of the RMP developed by GFS is presented below and in the attached computer file. Accidental Release Prevention and Emergency Response Policies at GFS GFS has established policies and developed emergency response teams to protect the safety of their workers and the public. Their Environmental Policy Statement describes GFS's commitment to release prevention in the following phrases: "Gordon Food Service is committed to excellence and leadership in protecting the environment. We strive to minimize adverse impact on the air, water, and land through pollution prevention and energy conservation. Gordon Fo od Service seeks to demonstrate its responsible corporate citizenship by striving to adhere to all environmental regulations. We promote cooperation and coordination between industry, government, and the public toward the shared goal of preventing pollution at its source." Additionally, GFS's Corporate Safety Policy defines GFS's commitment to the safety of its workers and surrounding community in the following phrases. The protection of human life is one of our most important objectives in the course of conducting business. The safety of all those associated with GFS, including the general public, cannot be compromised. It is our goal to operate in both a safe and productive manner. The preservation of people, equipment, and merchandise will enable us to be a quality supplier. These unwanted events can be prevented through "know-how" and a willingness to do our jobs in a safe manner. These responsibilities rest with every one of us, and will be a part of our perfo rmance objectives. GFS demonstrates their commitment to safety and preventing releases to the environment by being actively involved with the Kent County Local Emergency Planning Commission (LEPC). GFS has developed in conjunction with the Kent County LEPC a Chemical Emergency Response Plan & Standard Operating Procedures (Emergency Response Plan) for GFS's Grand Rapids Campus. The stated purpose of this Emergency Response Plan is: - To ensure the safety of Emergency Response Team Personnel during a hazardous materials emergency. - To provide adequate safety precautions in protecting Gordon Food Service employees and the public from harm caused by a chemical release. - To provide the Emergency Response Team with management direction during all operations directly related to a hazardous material emergency. GFS has developed and trained a HAZMAT team, in accordance with applicable OSHA regulations; to implement their established policies and the procedures established in thi s Emergency Response Plan. The HAZMAT team is supported and sufficient resources have been provided to this HAZMAT team by GFS's upper management. Site Description and Regulated Substances Handled Gordon Food Service (GFS) distributes general grocery items to restaurants, cafeterias, and Marketplace stores throughout the Midwest. GFS utilizes refrigerated warehouses (Distribution Centers) to receive product from venders, which is then distributed to Marketplace stores and clients within a 250-mile radius. GFS's Grand Rapids facility consists of Corporate Offices, a Fleet Maintenance Building, and two Distribution Centers and is collectively called the GFS Grand Rapids Campus. The two Distribution Centers will be identified throughout the RMP as 50th Street Distribution Center and Clay Avenue Distribution Center. Since the 50th Street Distribution Center and Clay Avenue Distribution Center are located on contiguous property, have the same industrial group and are both owned by GFS, only one RMP is required for this facility. The structure of both Distribution Centers consists of a warehouse building subdivided to house building maintenance; administration; dry, refrigerated, and frozen product inventory; and unloading and loading dock areas. Refrigerated and frozen inventory cooling at both Distribution Centers is provided by two separate anhydrous ammonia refrigeration systems located within each Distribution Center. The storage and use of the anhydrous ammonia is the only substance used by GFS that is subject to the Risk Management Plan (RMP) requirements. The ammonia refrigeration systems at the distribution facilities contain the following: - 50th Street Distribution Center: 10,080 pounds of anhydrous ammonia, and - Clay Avenue Distribution Center: 23,000 pounds of anhydrous ammonia. Both refrigeration systems consist of the following basic elements: - compressors, - high pressure receiver, - liquid chiller, - heat exchanger, - condensers, and - associated piping and valves. Refer to the attached process flow diagram for further design of the refrigeration systems at both Distribution Centers. The refrigeration systems for both Distribution Centers are closed loop systems. Ammonia System Design - 50th Street Distribution Center All components of the refrigeration system at the 50th Street Distribution Center are located within the warehouse facility itself except for the high-pressure receiver, condensers, and associated piping and valves. The high-pressure receiver, condensers and associated piping and valves are located on the roof of the warehouse building. The remaining components of the system except for the chillers are housed in a concrete block room (compressor room) within the warehouse. The compressor room has only two access points that open into the warehouse itself. The chillers are suspended from the ceiling of the warehouse throughout the refrigerated and frozen food product areas. Ammonia System Design - Clay Avenue Distribution Center The major components of the refrigeration system including the high-pressure receiver at the Clay Avenue Distribution Center are enclosed in a concrete block room (compressor room) within the warehouse facility itself. The only exterior components of the refrigeration system are the condensers and associated piping and valves. The compressor room has only two access points. One access point is a door that opens into the warehouse itself and the second access point is a door that leads directly to the outside of the facility that remains continuously locked from the inside. The limited access to the compressor room essentially contains the refrigeration system and acts as containment in the event of a release. The chillers are suspended from the ceiling of the warehouse throughout the refrigerated and frozen food product areas. Worst-Case Release Scenario The Environmental Protection Agency (EPA) has d efined a worst-case release as "the release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to a specified endpoint." Basically, a worst- case release is a catastrophic event that destroys the process and/or storage vessels and immediately releases all stored materials. In order to determine the impact of a worst case accidental release of ammonia to off-site receptors (public), an off-site consequence analysis was conducted. RMP*Comp, developed by the National Oceanic and Atmospheric Administration (NOAA) and the Environmental Protection Agency (EPA), was the model utilized to determine the potential area of impact a worst case accidental release of ammonia could cause. GFS modeled both Distribution Centers to assess which refrigeration system created the greatest area of impact. The greatest quantity of ammonia is stored in the High Pressure Receiver at both Distribution Centers, therefore; the quantity of ammonia stored in this vessel was the quantity utilized to model the worst case scenario. The scenario developed for the 50th Street Distribution Center (a rupture in the High Pressure Receiver located on the rooftop of the warehouse building) generated the largest area of impact and was therefore utilized for the Worst-Case Release Scenario. The following site-specific parameters and required default parameters were utilized to conduct the off-site consequence analysis for the 50th Street Distribution Center: - Quantity of ammonia liquefied under pressure: 10,080 pounds (present in the high- pressure receiver located on the rooftop of the 50th Street Distribution Center (site- specific value) - Height of Release: ground level (default value) - Release Duration: 10 minutes (default value) - Mitigation Measures: None (default value) - Topography: Urban Surroundings (site-specific value) - Wind Speed: 1.5 meters/second (default value) - Stability Class: F (default value) - Air Temperature: 77 degrees Fahrenheit (default value) These site specific values and default values were input into the RMP*Comp model to calculate the Toxic Endpoint and Estimated Distance to the Toxic Endpoint. The calculated results are 0.14 mg/L and 1.2 miles, respectively. In order for a release of this magnitude to occur, all automated and engineered fail-safe mechanisms would have to have been destroyed also. Basically, a catastrophic event like a tornado or earthquake would have to destroy the High Pressure Receiver instantaneously to meet the assumptions required by a worst case scenario. With respect to GFS, the immediate release would be in liquid form ultimately evaporating to the atmosphere over time. This model also assumes that the release occurs at ground level which is not an accurate representation of the site. The High Pressure Receiver at the 50th Street Distribution Center is located on the roof approximately 45 feet above the ground. In actuality, the ammonia vapor cloud that would form when a release occurred would dissipate in the direction of the wind predominantly west southwest. This would significantly reduce the ammonia concentration (0.14 mg/l as calculated by RMP*COMP) of the vapor cloud and radius of impact (only affecting the public located immediately downwind of the release). Alternate Release Scenario GFS has reviewed their ammonia refrigeration system to determine a more likely release scenario. The Process Hazard Analysis conducted in accordance with OSHA's Process Safety Management Standard 29 CFR 1910.119 indicated that a release caused by a hole in piping caused by corrosion or a leaking valve along the piping run located on the roof of the warehouse is a more plausible release scenario. Under normal operating conditions, the rooftop piping and associated valves are operating under 175 psig. The alternate release scenario was calculated assuming a valve was damaged crea ting a 2 inch hole (diameter of the valve). The release rate was calculated utilizing the Bernoulli Equation: QR = HA x (203)(Pg)1/2 Where: QR = Release rate (pounds/minute) HA = Hole area (square inches) Pg = Gauge pressure (psig) Using this equation, the release rate was calculated to be 4,792 pounds of anhydrous ammonia per minute. Inputting the calculated release rate of 4,792 pounds/minute and the default release duration of 60 minutes into the RMP*Comp model, an estimated distance to the Toxic Endpoint was calculated to be 0.5 miles. This radius of impact is significantly smaller than the worst case scenario, however; it could still impact the surrounding public. The alternate release scenario model assumes that all of the engineered fail safe measures present in the ammonia refrigeration system at GFS fail. The fail safe measures that would have to fail include automatic and manual alarms and shutoff mechanisms including manual shut down of the system follow ing GFS's standard operating procedures by HAZMAT responders. Therefore, the odds of the alternate release scenario described above occurring are still very low. GFS does feel that this scenario has a greater chance of occurring than the worst case scenario previously described. Accidental Release Prevention Program and Chemical-Specific Prevention Steps To prevent the accident release scenarios described above and others outlined in GFS's Process Hazard Analysis at both 50th Street and Clay Avenue Distribution Centers, GFS has implemented an aggressive prevention program within the last four years. GFS has made a commitment to understand the environmental aspects and safety aspects of the refrigeration system operations. In response to this increased knowledge and awareness, GFS has devoted much time and effort to insuring the refrigeration systems at each Distribution Center are working efficiently, effectively, and safely for not only on-site employees but also the res idents and public areas surrounding the Distribution Centers. GFS is subject to the OSHA Process Safety management (PSM) requirements. Therefore, the PSM program GFS has instituted is in compliance with these standards, at minimum. GFS's prevention program includes the following: - Daily manual and automated pressure checks of temperature and pressures in engine room. - Weekly inspection of exterior insulation, valve stations, and piping runs. - Bi-weekly leak checks of all valves and valve stations. - Preventative maintenance program based on recommended engineering practices and observations from inspections. - Inspections of Preventative Maintenance Work Orders and daily/weekly inspections to ensure they are completed properly and in a timely fashion. - Utilization of a software system (Maximo) to assist GFS in monitoring the preventative maintenance program for both Distribution Centers. - Systematically upgrading refrigeration system equipment and components. - Installat ion of Industrial Refrigeration Thermal Insulation as a vapor barrier system to all refrigeration vessels, valves, piping, and fittings including hot gas lines to the defrost/condensing temperature system. - Equipping each refrigeration system with alarms, and automated activation of relief valves and automated shutdown once the system reaches dangerously high levels of pressure. - Development of a HAZMAT team and an Emergency Action Plan to effectively respond to any potential accidents and leaks specifically relating to the refrigeration system in accordance with OSHA Standard 29 CFR 1910.120 and 29 CFR 1910.38(a), respectively. - Emergency response training for all HAZMAT team members. - Constructed and equipped a HAZMAT Command Post Trailer with all necessary communication equipment and personal protective equipment to respond to an anhydrous ammonia release. In addition to these measures, GFS has implemented an Employee Training Program for Refrigeration Technicians. The Training Program includes both on-site and off-site training seminars through the University of Wisconsin, the Manufacturer (Vilter and Frick) and training modules and competency tests developed and supplied by the International Institute of Ammonia Refrigeration (IIAR). Training is completed by each Refrigeration Technician on an annual basis. Five-Year Accident History Only the 50th Street Distribution Center has had a release of anhydrous ammonia from the refrigeration system. On August 24, 1996 approximately 287.1 pounds of anhydrous ammonia gas accidentally released into the air over an approximate 90 minute time span from a roof mounted distribution pipe, a component of GFS's refrigeration system for the 50th Street Distribution Center. The Wyoming Fire Department responded to the release at approximately 8:30 P.M. along with GFS personnel. Once aware of the release, GFS maintenance employees immediately began closing valves to eliminate further anhydrous ammonia releases from the distribution pipe. However, anhydrous ammonia vapors from the release did migrate off-site. The Wyoming Fire Department and Police Department conducted emergency notification of all persons within two blocks of the release. The source of the leak was determined to be from external corrosion of the pipe. Subsequently, GFS has instituted an aggressive and predictive preventative maintenance program which includes inspection, repair and replacement of piping. Additionally, GFS has made a significant commitment to responding to and preventing releases to the environment in the future by being actively involved with the Kent County LEPC and developing, training, and equipping a HAZMAT team and a mobile command center for the Grand Rapids Distribution Centers. Emergency Response Program GFS has developed an extensive Emergency Response Program to respond to a chemical release from the anhydrous ammonia refrigeration systems at the 50th Street a nd Clay Avenue Distribution Centers. GFS has developed in conjunction with the Kent County LEPC an Emergency Response Plan for GFS's Grand Rapids Campus. The Emergency Response Plan details: - pre-emergency planning procedures, - GFS's Emergency Response Team organizational structure, - training requirements, - emergency recognition and prevention procedures, - emergency alerting procedures, - evacuation procedures, - emergency medical services, - emergency response procedures, - medical surveillance procedures, and - post emergency response critique procedures. Emergency response personnel are available to respond to a release 24 hours per day seven days per week. GFS has provided not only employee training but all necessary resources needed to adequately, quickly, and safely respond to and mitigate a release of anhydrous ammonia. An Emergency Response Trailer has been created and equipped with personal protective equipment, first aid equipment, and two-way radios . The Equipment in this trailer is maintained in "ready" condition at all times. Additionally, GFS has coordinated with the Wyoming Fire Department and the Kent County LEPC whose master plan includes coordinating with the Wyoming Police Department, area hospitals and local emergency response companies to ensure all parties are aware of their roles and responsibilities in the event a release does occur. GFS has established protocol to bring in the local authorities and inform the surrounding public when an accidental release of anhydrous ammonia exceeds 100 pounds. By the direction of the Kent County LEPC, off-site notification comes from the Local Fire Department. Upon their contact they assume the leadership role for emergency response and make all off-site evacuation and sheltering communications to the community. GFS employees required to do work in and around the anhydrous ammonia refrigeration systems, are trained and annually updated in accordance with the MIOSHA Hazardous Waste Operations and Emergency Response Standard, Michigan Administrative Code R325.52101et seq. These training programs include: - First Responders at the Awareness Levels, - Hazardous Materials Technicians, and - On Scene Incident Commander. To ensure response procedures and employee training is complete and up to date, GFS conducts mock emergency response scenarios on a quarterly basis. After completing each mock emergency response scenario the HAZMAT Team reviews the methods and procedures followed to coordinate the response effort and mitigate a release to assess their effectiveness and to determine if changes to response procedures are necessary. In any event, GFS is fully prepared to respond to an accidental release of anhydrous ammonia and more importantly protect GFS employees, and people living and working around the 50th Street and Clay Avenue Distribution Centers. Planned Changes to Improve Safety In the last four years, GFS has made many improv ements in employee training, operations and procedures that involve the refrigeration systems at both Distribution Centers. These changes have increased the safety for all on-site employees and significantly reduced the risk of a release of anhydrous ammonia from not only occurring but also from migrating off-site and impacting the surrounding residences and businesses. GFS is committed to continually improve the operations of the refrigeration system to continue to reduce the threat of a release occurring from these two systems. The changes proposed for the immediate future include but are not limited to: - Developing a Hot Work Program for refrigeration contractors, - Further enhancing the Compliance Audits Program by developing an Internal Auditing Program and peer review from personnel at other Distribution Centers, - Continually enhancing the Employee Training Program to allow GFS to obtain the best available information and technology for improving refrigeration syste m efficiency and safety, - Developing procedures for selecting and assessing contractors to ensure, at minimum, they meet OSHA's safety requirements, and - Expanding the management system developed to address anhydrous ammonia as required by the OSHA Process Safety Management Standard and the RMP to include all chemicals that pose a risk by developing an Integrated Contingency Plan. GFS is considering adopting the principles and management characteristics of an ISO 14000 Environmental Management System to manage environmental, health and safety compliance issues consistently throughout GFS's diversified organization. An Environmental Management System is a proactive voluntary initiative that a company commits itself to going beyond compliance. This system will allow Gordon Food Service to seek additional improvements in their effort to manage, control and potentially eliminate the risks associated with GFS's daily operational tasks. Pw/auditing/grdfs/80131grex |