GROCERS SUPPLY - Executive Summary |
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General Executive Summary for Grocers Supply Refrigerated Warehouse 1. Accidental Release Prevention and Emergency Response Policies We at GROCERS SUPPLY are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substance Handled Our facility's primary activities encompass a REFRIGERATED GROCERY WAREHOUSE. We have one regulated substance present at our facility. This substance is anhydrous ammonia. Ammonia (anhydrous) is used for THE REFRIGERATION PROCESS. The maximum inventory of Ammonia (anhydrous) at our faci lity is approximately 20275 pounds. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To evaluate the worst case scenarios, we have used RMP*COMP VER 1.06. For alternative release scenario analyses we have employed the EPA's OCA Guidance Reference Tables or Equations and the EPA's RMP Guidance for Ammonia Refrigeration Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from the ammonia refrigeration system . In this scenario 11200 lb. of Ammonia (anhydrous) is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. The released quantity has been limited to 5 5% of the maximum capacity of the source by a system of administrative controls. Passive mitigation systems such as enclosure(s) are also taken into account to calculate the scenario. These mitigation systems have the effect of reducing any impact to onsite and offsite receptors and the enviroment. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 1.2 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. One alternative release scenario for Ammonia (anhydrous) involves a release from AMMONIA REFRIGERATION SYSTEM. The scenario involves the release of 20273.38 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Passive mitigation controls such as enclosure(s) are taken into account to calculate the scenario, having the effect of reducing any onsite and offsite concequences. The release is also assumed to be controll ed by sprinkler system(s), emergency shutdown system(s) and manual shutoff valves. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.62 miles. Another alternative release scenario for Ammonia (anhydrous) involves a gas release from a damaged pipe in the equiptment room. The scenario involves the release of 2948.51 lb. of ammonia . Toxic gas is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Passive mitigation controls such as enclosure(s) are taken into account to calculate the scenario, having the effect of reducing any onsite and offsite concequences that may occur. The release is also assumed to be controlled by sprinkler system(s), emergency shutdown system(s) and manual shutoff valves. These active mitigation systems also have the effect of reducing onsite and offsite concequences. Under neutral weath er conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.19 miles. Another alternative release scenario for Ammonia (anhydrous) involves a release from a damaged pump seal in the equiptment room. The scenario involves the release of 20273.00 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 202.73 minutes. Passive mitigation controls such as enclosure(s) are taken into account to calculate the scenario, having the effect of reducing onsite and offsite concequences. The release is also assumed to be controlled by sprinkler system(s) and manual shutoff valves. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.085 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary step s to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information GROCERS SUPPLY maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is What If/Checklist (combined) and HAZOP. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of five years. Any findings related to the haza rd analysis are addressed in a timely manner. The most recent PHA/update was performed on 12/06/1996. Operating Procedures For the purposes of safely conducting activities within our covered processes, GROCERS SUPPLY maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations and normal shutdown . The information is regularly reviewed and is readily accessible to operators involved in the processes. Training GROCERS SUPPLY has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every once every year and more frequently as needed. Mechanical Integrity GROCERS SUPPLY carries out documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls compressors and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at GROCERS SUPPLY to manage changes in technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 06/30/1998. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in estab lished processes are conducted as a regular practice at GROCERS SUPPLY. The most recent review was performed on 05/07/1997. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits GROCERS SUPPLY conducts audits on a regular basis to determine whether the provisions set out under the RMP/PSM rule are being implemented. The most recent comliance audit was conducted on 12/13/1996. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation GROCERS SUPPLY promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the rel ease from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation GROCERS SUPPLY truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. GROCERS SUPPLY has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an acc idental release of a regulated substance occur. 5. Five-year Accident History GROCERS SUPPLY has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan GROCERS SUPPLY carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 713-865-4178 is the Local Emergency Planning Committee (LEPC) in our area. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Continued training and educational assistance are some of the major steps we want to take to improve safety at our facility. |