New Jacksonville Warehouse - Executive Summary |
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WINN-DIXIE LOGISTICS, INC. - JACKSONVILLE WAREHOUSE RISK MANAGEMENT PLAN EXECUTIVE SUMMARY 1. Corporate Prevention and Emergency Response Approach The Winn-Dixie Jacksonville (Jax) Warehouse Facility is a distribution warehouse, located in Jacksonville, Florida, owned by Winn-Dixie Logistics, Inc. Winn-Dixie requires each facility to develop and maintain accident prevention programs and an emergency response plan appropriate to the site. Each site is also responsible for regulatory compliance issues that apply to the site. Winn-Dixie?s corporate and division environmental and safety personnel provide assistance in training for site employees and in budgeting and procurement of safety and training services. 2. Description of Stationary Source The Winn-Dixie Jax Warehouse is located at 15500 West Beaver Street in Jacksonville, Florida. The facility consists of areas for dry, cooler, and freezer storage of perishable and non-perishable items for distribution to the Winn-Dixie Supermarkets. The Jax Warehouse has an ammonia refrigeration system which exceeds the 10,000 lb. RMP threshold quantity. The ammonia refrigeration system?s equipment is located in the machine or compressor room. The high pressure receiver (HPR) is located inside the compressor room. The HPR is the largest capacity vessel in the ammonia refrigeration system, capable of holding approximately 15,169 lbs. of ammonia. This vessel was used to determine the OCA for the Facility. 3. Description of the Worst Case and Alternative Release Scenarios The Worst Case release scenario is the rupture of the HPR vessel, releasing 15,169 lbs. of ammonia gas over a 10-minute period. Under worst case weather conditions and considering passive mitigation in rural topography, the ammonia gas could travel 1.3 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .14 mg/L), using the EPA Ammonia Guidance method. The Alternative Relea se Scenarios is a pipe leak at a mitigated release rate of 388 lb./min. from the HPR liquid supply line due to pipe connection failure from worker/human error or corrosion of the pipe. Under normally expected weather conditions, taking into consideration the passive mitigation in rural topography, the ammonia gas could travel 0.4 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .14 mg/L), using the Ammonia Guidance method. 4. Prevention Program The Jax Warehouse exceeds the ammonia threshold quantity for the OSHA Process Safety Management (PSM) Standard, 1910.119, and is therefore subject to the PSM requirements. For RMP compliance purposes, this places the Jax Warehouse process in the Program 3 level. The Jax Warehouse will use its PSM program as the required Program 3 Prevention Program. The Jax Warehouse has a program in place to comply with the OSHA Process Safety Management Standard, 29 CFR 1910.119. The PSM Program includes a preventative maintenance plan which requires all ammonia refrigeration equipment to be periodically inspected and serviced. This will ensure that the equipment remains in good operating condition and will minimize the probability of accidents due to faulty equipment. In developing the PSM Program, the Jax Warehouse also developed written operating procedures for the refrigeration process. These procedures cover all phases of operation and include information on safety devices. These procedures will be used to train all operators and mechanics who work on the ammonia refrigeration process to ensure consistency of operation and minimize human error. In addition, all refrigeration mechanics receive training through the Refrigeration Engineers and Technicians Association (RETA) training course. These measures ensure that all refrigeration operators and mechanics are properly trained. Existing safe work practices such as Lockout/Tagout and Hot Work Permit , were reviewed and updated to ensure that all non-routine work can be performed safely. Other components of the prevention program include collection and review of all equipment information, the development of updated Piping & Instrumentation Diagrams (P&IDs), and the correction of any equipment design deficiencies found. These actions will ensure that the equipment meets all refrigeration industry standards and that accurate equipment information will be available when needed. To ensure that the Jax Warehouse refrigeration staff has the skills necessary to identify unsafe conditions, Process Hazard Analysis (PHA) training was conducted. The staff also performed a PHA of this process. Other PSM procedures, including Management of Change, Pre-Startup Safety Review, Compliance Audits, and Incident Investigation are also part of the program to ensure continued safe operation and prompt correction of deficiencies. The PSM Program receives full support of plant management and involve ment of employees at all levels. 5. Accident History The Jax Warehouse has had no accidental releases of ammonia in the past five years. The facility is brand new and will charge the ammonia system at the end of October. 6. Emergency Response Program The Jax Warehouse has an Emergency Response Program in place. The program complies with 29 CFR 1910.38. The site also has internal emergency response capability at this time and is developing a program to comply with paragraph (q) of 29 CFR 1910.120. The current plan consists of evacuation procedures, actions to follow concerning small ammonia releases, and procedures for a response by Winn-Dixie Warehouse Hazmat trained personnel. The City of Jacksonville's Hazardous Materials Response Team is expected to help coordinate and assist if an incident were to occur. Notification is made locally by dialing 911, and by notifying Florida State Warning Point at 1-(800) 832-8224. |