Ralphs Grocery Company - Executive Summary

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The Ralphs Grocery Company Stockton Distribution Center has completed a Risk Management Plan (RMP) in accordance with 40 CFR Part 68 and California Title 19.  A summary of the following is presented herein. 
 
I.  Accidental Release Prevention and Emergency Response Policies 
 
Ralphs Grocery Company has a longstanding commitment to worker and public safety by operating and maintaining all of our processes in a safe and responsible manner.  We have implemented a combination of accident release prevention program and emergency planning program to help ensure the safety of our employees and the public, as well as to protect the environment.  These programs include governmental requirements, such as the Environmental Protection Agency's (EPA) RMP Rule and the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) standard.   
 
II.  Stationary Source and Regulated Substance 
 
Ralphs Grocery Company Stockton Distribution Center, located at 4199 Gibraltar Court,  
Stockton, California, operates a refrigeration system using anhydrous ammonia, a regulated substance, above the threshold quantity listed under the RMP rule.  The refrigeration system provides cooling for food warehousing operations at the site. The Stockton facility does not maintain specified quantities of any RMP regulated flammable substances.   
 
III.  Worst-Case and Alternative Release Scenarios 
 
Worst-Case Release Scenario 
 
The worst-case release scenario associated with the storage and handling of anhydrous ammonia at the facility would be a failure of the control pressure receiver.  Twenty-two thousand (22,000) pounds of ammonia would be instantaneously released, and it is assumed that the vessel would be emptied in ten minutes.  The distance to the toxic endpoint for the ammonia released is estimated to be 1.8 miles from the facility.  According to EPA's Off-site Consequence Analysis (OCA) Guidance Table, this release could impact off-site public receptors.  No credit for admi 
nistrative controls was taken into account in evaluating this scenario.   
 
Specific systems to prevent or mitigate this scenario include an ammonia gas detector and alarm systems, a sprinkler system, pressure relief systems, and security surveillance.   
 
Alternative Release Scenario 
 
The alternative release scenario for anhydrous ammonia assumes a leak in the piping.  This scenario leads to a release of 8,700 pounds of anhydrous ammonia in ten minutes.  Although active mitigation measures do exist, no active measures were taken into account in evaluating this scenario.  According to EPA's Off-site Consequence Analysis (OCA) Guidance Table, this release could impact off-site public receptors.   
 
Specific systems to prevent or mitigate this scenario include a manual emergency shutdown system, an ammonia gas detector and alarm systems, a sprinkler system, pressure relief systems, and security surveillance.   
 
IV.  General Accident Release Prevention Program and Chemical Specific Preventio 
n Steps 
 
In addition to the RMP regulation, the facility is also subject to the OSHA PSM standard.  The following are elements of the PSM and accident prevention program.   
 
Employee Participation 
 
The facility encourages employees to participate in all facets of process safety management and accident prevention.  Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team.  Employees have access to all information created as part of the facility accident prevention program.  
 
Process Safety Information 
 
The facility keeps on file documents used to maintain safe operation of the processes.  Chemical-specific information, including exposure hazards, emergency response and exposure treatment, is provided in material safety data sheets (MSDS).  This information is supplemented by documents that specifically address known corrosion concerns and hazards.  For specific p 
rocess areas, safety-related limits for process parameters are provided and the process is maintained within these limits through the use of process control and monitoring instruments, highly trained personnel, and protective instrument systems (e.g. automated shutdown systems). 
 
The facility also maintains technical documents on the design and construction of process equipment, such as materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc.  This information provides the basis for establishing inspection and maintenance activities, and for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised.   
 
Process Hazard Analysis (PHA) 
 
The facility uses the Hazard and Operability (HAZOP) analysis technique to conduct the PHA, which is performed by a team of people with design and engineering expertise.  This team identifies and evaluates hazards of the process and suggests accident pre 
vention and mitigation measures.  The findings from the PHA are forwarded to local and corporate management for resolution.  Implementation of mitigation options is based on a relative risk ranking assigned by the team, with release scenarios assigned the highest risk receiving immediate attention.  All approved mitigation options being implemented are tracked to completion.  The final resolution of each finding is documented and retained.   
 
The facility periodically updates and revalidates the PHA results.  Reviews are conducted every five (5) years for the life of the process.  Findings from the reviews are also documented, retained, and forwarded to management for consideration.   
 
Operating Procedures 
 
The facility maintains written procedures that address various modes of process operations.  The procedures are periodically reviewed and annually certified as current and accurate.  Changes are made to the procedures when deemed necessary and through the management of change proces 
s.  Operating procedures are maintained at the facility and are available to all employees with ammonia refrigeration system related responsibilities.   
 
Training 
 
To complement the written operating procedures, the facility has implemented a comprehensive training program for all employees involved in operating a process.  The new employee receives basic training, provided in part by the ammonia refrigeration contractor.  Refresher training is periodically conducted to ensure operator skills and knowledge are maintained at an acceptable level.  All training is documented, including the means used to verify that the operator understood the training. 
 
Contractors 
 
The facility has procedures in place to ensure that contractors working on or near process equipment: (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their work place, (4) understand what they should do in the event of an emergency, (5) understand and foll 
ow site safety rules, (6) inform facility personnel of any hazards that they find during their work.  In addition, the facility evaluates contractor safety programs and performance during the selection of a contractor.  Facility personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. 
 
Pre-Startup Review 
 
The facility conducts a Pre-Startup Safety Review for any new facility or facility modification that requires a change in the process safety information.  The purpose of the review is to ensure that safety features, procedures, personnel, and equipment are prepared for startup.  This review provides an additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready.  A review involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are pr 
operly implemented. 
 
Mechanical Integrity 
 
The facility has established procedures to maintain safe operating conditions of the refrigeration system, including training, written procedures, inspections, correction of identified deficiencies, and quality assurance measures.  Prior to startup, the ammonia refrigeration contractor conducts a safety inspection to check the condition of the equipment, ensure all equipment has been installed and secured properly, that the appropriate equipment has been tagged and protected from physical hazards.  This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made.  In combination, these activities form a system that maintains the mechanical integrity of the process equipment.   
 
Incident Investigation 
 
The facility promptly investigates all incidents resulting, or could have resulted, in a fire/explosion, toxic gas release, major property damage, environmental loss, o 
r personal injury.  The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence.  The investigation team documents its findings, develops recommendations, and forwards these results to facility management for resolution.  Corrective actions are tracked to completion.  The final resolution of each finding or recommendation is documented and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings.  Incident investigation reports are retained for five (5) years. 
 
Compliance Audits 
 
To help ensure that the accident prevention program is functioning properly, the facility shall periodically conduct an audit of the program.  Compliance audits are conducted at least once every three (3) years.  Both hourly and management personnel participate as audit team members. Audit findings are forwarded to facility management for resolution and corrective actions are tracked to completion 
.  The final resolution of each finding is documented, and the two most recent audit reports are retained. 
 
V.  Five-Year Accident History 
 
This is a new facility for Ralphs Grocery Company and there have not been any accidents or incidents related to an ammonia release in the last five years.  There have been no on-site death, injury, or property damage; or a known off-site death, injury, evacuation, shelter-in-place, property damage or environmental damage. 
 
VI.  Emergency Response Program  
 
The Stockton Distribution Center does not have an in-house first responder team to handle release incidents and, therefore, relies upon the facility's emergency procedures and the response mechanisms provided by the City of Stockton Fire Department and San Joaquin County Office of Emergency Services (OES).  In the event emergency health services are required, the facility shall look to the Stockton Fire Department emergency medical personnel for assistance and transportation to the nearest medica 
l center. 
 
The emergency procedures provide directions for the facility occupants on proper notification of agencies, announcement of an emergency and evacuation of the buildings. 
 
VII.  Planned Changes To Improve Safety 
 
The facility is designed and constructed in accordance with the appropriate building and safety codes as well as  relevant fire codes.  Any improvements or requested changes to the facility have been addressed prior to startup and worker safety procedures are in place.  Currently, there are no planned changes to safety.
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