Associated Food Stores Inc. - Executive Summary |
|
ASSOCIATED FOOD STORES INC. PSM/RMP ROGRAM I. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY POLICIES Associated Food Stores Inc. recognizes management's responsibility in protecting it's employees, equipment, property, and the environment against the hazards of an unintentional ammonia release. The safety and health of all employees and the public is very important. The control of accidents has been and will continue to be a basic responsibility of all personnel in the facility. Associated Food Stores Inc PSM/RMP program assigns and documents the specific responsibilities for developing, implementing and integrating the OSHA PSM and the EPA RMP standards into its safety program. Associated Food Stores Inc PSM/RMP program focuses attention on "Making PSM/RMP the way we manage our ammonia based refrigeration system" rather than a project we expect to complete and p ut on the shelf when the filing date has passed. Associated Food Stores Inc believes that Employee participation is the key to a successful program. Operating level employees, particularly the Maintenance and Refrigeration Manager and the Refrigeration System Operators, have been deeplly involved in the PSM/RMP program development, implementation and integration and they assume the major responsibility for operating the Farr West, Utah facility safely. Associated Food Stores Inc. Emergency Response Program has been developed with the complete cooperation and support of the local and County Fire Departments. All Associated Food Stores Inc employees have received documented emergency response training. II. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED Associated Food Stores Inc. manages a Major Wholesale Grocery Distribution Facility in Far West, Utah. The refrigeration system is required for the Storage and Distribution of Frozen TurkeysFood Items. The refrigeration system contains no more than 15,118 pounds of Anhydrous Ammonia. Anhydrous Ammonia is the only Hazardous Material on site in quantities above the threshold quantity. III. SUMMARY OF WORST CASE AND ALTERNATIVE RELEASE SCENARIOS The WORST CASE release scenario involves the complete rupture of the High Pressure Receiver. A maximum release of 15,188 pounds of ammonia over a 10 minute period was considered. Under worst case weather conditions ammonia could travel up to 1.1 miles before dispersing. A WORST CASE release is very, very, very, unlikely to occur during the life of the facility, this is because of the release prevention and mitigation features incorporated in the Associated Food Stores Inc. PSM/RMP Program and the well developed and tested designs for Ammonia Refrigeration Systems. An alternative case release scenario that we call WORST CASE CREDIBLE was slightly more likely. A 3000 pound ammonia vapor loss from failure of a psv to reseat or fr om ruptured vapor piping. Unsder worst case weather conditions ammonia could travel up to .1 mile before dispersing. This release is very, very unlikely to occur during the life of the Associated Food Stores Inc facility. An alternative case release that we call MOST LIKELY, MOST SEVERE was slightly more likely still. A 100 pound ammonia loss from a failing ammonia transfer hose during the unloading operation. Under worst case weather conditions ammonia could travel up to .1 mile before dispersing This release is very unlikely to occur during the life of the Associated Food Stores Inc. facility. IV. DESCRIPTION OF THE ASSOCIATED FOOD STORES INC..ACCIDENTAL RELEASE PREVENTION PROGRAM Associated Food Stores Inc. conducts an annual training and response exercise with the Weber Fire District to practice, train and update the Associated Food Stores Inc. Emergency Response Program. Associated Food Stores Inc. conducts an annual PSM/RMP implementation progress audit o f the entire PSM/RMP program to identify strengths and weaknesses and make improvements. Associated Food Stores Inc. considers the PSM/RMP manuals to be "living" documents that must be updated and revised regularly to maintain their viability. Associated Food Stores Inc. emphasizes and insists on "employee participation" from the refrigeration system operators in all aspects of the developent, implementation, and integration of their PSM/RMP program. Associated Food Stores Inc. provides a comprehensive, computer based, user friendly training program with "one-on-one" teacher involvement in specific training modules for each ammonia refrigeration employee. Associated Food Stores Inc. maintains a pro-active "open-door" policy toward neighbors and concerned community citizens. Facility tours and risk management discussions are scheduled and conducted upon written request. V. FIVE YEAR ACCIDENTAL RELEASE HISTORY There have been no releases of ammonia that resul ted in an injury, or that had an off-site impact, or that resulted in significant property damage either on-site or off-site. VI. Emergency Response Program Facility employees have been trained to respond to accidental ammonia release. The site emergency plan has been coordinated with the community emergency plan under the jurisdiction of the Local Emergency Planning Commission (LEPC) and the Weber Fire District. VII. PLANNED CHANGES TO IMPROVE SAFETY Associated Food Stores Inc. recognizes that (even though their Ammonia release and injury experience has been excellent) their PSM/RMP program will provide much needed improvement to their safety effort. The PSM/RMP program is considered to be a set of "living" documents and procedures that will require constant attention, development, and revision before "Safety" becomes becomes second nature. Associated Food Stores Inc. expects to improve safety performance by emphasizing the following elements of their PSM/RMP Program (1) Employee Participation is the "Key" to a successful program. Both the Maintenance and Refrigeration Manager and the Refrigeration System Operators will be deeply involved in Verifying the P&ID's, Developing and updating the Standard Operating Procedures, and performing the documented Preventive Maintenance Inspections. (2) The Associated Food Stores Inc. PSM/RMP Program will increasingly become: (a) computer based, (b) user friendly, (c) based on "one-on-one" involvement with specified and qualified trainers, (d) revised and re-written to minimize paperwork and maximize documentation, and (e) revised and re-written to be understood and used by the operating level employees. (3) All recommendations developed during the HAZOP were designed to improve the safety performance of the Moroni Feed Ammonia Refrigeration Process. Moroni Feed expects to evaluate each recommendation in a timely manner and implement, as soon as possibl e, those recommendations that will reduce the possibility of a release and/or mitigate the consequences of an unintentional release. |