Richfood Chester - Executive Summary |
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The Richfood Company policy is to comply with the requirements of EPA's Risk Management Program (RMP) regulation, Title 40 Code of Federal Regulations (CFR) part 68; and with OSHA's Process Safety Management Standard (PSM), Title 29 CFR 1910.119. The Richfood, Inc. Chester PSM/RM Program, along with other company safety and training programs, deal with the risks involved in the storage, handling, and processes utilizing hazardous chemicals. In this way Richfood promotes overall plant, worker, and public safety. These programs enable our facility to prevent the occurrence, and minimize the consequences, of significant releases of toxic substances as well as fires, explosions, and other types of catastrophic accidents. Overall, these programs prevent accidental fatalities, injuries and illnesses, and avoid physical property and environmental damage. The Richfood safety programs are applied to any activity involving hazardous chemicals including any use, storage, handling, or the on- site movement of such chemicals, or combination of these activities. Any group of vessels which are interconnected and separate vessels which are located such that a hazardous chemical could be involved in a potential release is considered a single process. The Richfood safety programs prevent accidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment. These rules are detailed and improved as necessary. They are also communicated to and accepted by all employees at the facility. The process covered by the Richfood, Chester, VA PSM/RM Program is the ammonia refrigeration system. The ammonia refrigeration system provides cooling for the refrigerated storage of perishable food products. The refrigeration process involves a typical vapor compression refrigeration cycle with compressors, condenser and evaporators. The system is closed and is designed to completely contain the ammonia refrigerant withi n vessels, equipment and piping specifically constructed for ammonia refrigeration. Liquid ammonia is circulated from the vessels in the refrigeration equipment room to the evaporator coils which cool the refrigerated spaces by boiling off some of the ammonia liquid to vapor. The ammonia then returns to the equipment room where the ammonia vapor enters the compressors and is discharged at higher pressure to the condenser. The vapor is cooled in the condenser causing the vapor to condense to liquid which is drained to the receiver vessel to repeat the refrigeration cycle. The Richfood, Chester refrigeration system contains 33,100 pounds of anhydrous ammonia which is a regulated toxic substance. The worst case scenario involves failure of the high pressure receiver containing 20,700 pounds of ammonia, released over a period of ten minutes. Under the worst-case weather conditions, ammonia could travel 1.9 miles before dispersing enough to no longer pose a hazard to the public. This scenario is unlikely for the following reasons: worst case weather conditions are uncommon; industry standards for the manufacture and quality control of pressure vessels; ammonia is not corrosive in this service; pressure safety valves limit operating pressure in this vessel; the accident prevention program in place at the facility including the mechanical integrity program for regular maintenance, inspection and testing, and replacement of equipment, if necessary; installed ammonia sensors in the system to warn of leaks; alarms in place to warn operating personnel of process upsets; and the emergency response plan and equipment in place at the facility. The alternative release scenario for the Richfood, Chester refrigeration system involves a leak from a rooftop pipe or tank resulting in a release of 10,800 pounds of ammonia over a time period of 20 minutes. Under common weather conditions, ammonia could travel 0.2 miles before dispersing enough to no longer pose a hazard to the p ublic. This scenario was chosen because there is a significant amount of piping and equipment on the roof of the facility. This scenario is unlikely for the following reasons: industry standards for the manufacture and quality control of equipment and piping; the mechanical integrity program in place at the facility including operating precedures, regular maintenance, inspection and testing, and replacement of equipment, if necessary; and the emergency response plan and equipment in place at the facility. In addition to the implementation of safety programs for compliance with the OSHA PSM Standard and the EPA RM Program regulations the Richfood, Inc. Chester, VA ammonia refrigeration system has been designed and constructed in accordance with applicable codes and standards including ANSI/B-9 1972 Standard for Equipment, Design and Installation of Ammonia Mechanical Refrigerating Systems. Standard operating procedures and training programs have been developed for the facility perso nnel to specifically address the characteristics of the Richfood Chester refrigeration system. There have been no accidental releases of ammonia at the Richfood Chester facility in the past five years. The Richfood Chester facility's emergency response program is based on the OSHA requirements for Emergency Action Plans (29 CFR 1910.38 and 1910.119) and HAZWOPWER (29 CFR 1910.120). Employees are trained for emergency response and a written emergency response plan is maintained for the facility. This plan is coordinated with the Local Emergency Planning Committee (LEPC) and the local fire department. Annual drills are conducted for implementation of the emergency response plan at the facility with the participation of the LEPC and the fire department. The Richfood Chester facility has a management system in place which has been developed to assure that the PSM/RM Program is implemented, documented and updated to assure its effectiveness. |