Bruno's Distribution Center - Executive Summary
Bruno's Inc. has developed a Risk Management Program for Anhydrous Ammonia to comply with the Environmental Protection Agency's (EPA) Risk Management Program regulation 40 CFR 68. Bruno's Inc. is a company proactive in ensuring safety of the community as it relates to the companies use of Anhydrous Ammonia (referred to as ammonia). Ammonia is the refrigerant used at the Bruno's Distribution Center. This summary will give descriptions of the Risk Management Plan as follows: |
1. The accidental release prevention and emergency response policies at Bruno's Distribution Center.
2. Facility information and the substance handled.
3. The worst case release scenarios and alternative release scenarios.
4. The general accidental release program and chemical specific prevention steps.
5. The five year accident history.
6. The emergency response program.
7. Planned changes to improve safety.
1. THE ACCIDENTAL RELEASE PREVENTION AND EMERGENCY REPSONSE POLICIES AT
Bruno's Distribution Center management is dedicated to safety in the use of ammonia as a refrigerant. In addition to complying with EPA standards as part of the Risk Management Program, Bruno's also complies with the Occupational Safety and Health Administrations (OSHA) Process Safety Management Program (PSM). Bruno's trains all employees on the Chemical Safety Right To Know standard in 29 CFR 1910.1200. As part of 29 CFR 1910.1200 all employees are also trained in the use of the M.S.D.S sheets and various chemical warning labels. Company and distribution center senior management are dedicated to supporting proactive safety and accident prevention.
2. FACILITY INFORMATION AND THE REGULATED SUBSTANCE HANDLED:
Bruno's Distribution Center is a 1,300,000 square foot warehouse distributing general grocery and perishable items to Bruno's, Food World, Food Fair, and Food Max stores in Alabama, Georgia, Florida, and Mississippi. Approximately 500,000 square feet is ref
rigeration space for perishable items such as frozen food, fresh meat, and fresh produce. The main refrigeration chemical used is ammonia. There is an ammonia pump system with numerous pipes running from a compressor room to the roof of the building. The ammonia travels to evaporators on the roof. It then returns to the compressor room after passing through a condenser. During ammonia travel through the system, it undergoes various changes in temperature and liquid/vapor form, depending on the pressure. There is approximately 42,000 lbs. of ammonia liquid and vapor in the system.
3. THE WORST CASE RELEASE SCENARIO AND ALTERNATIVE RELEASE SCENARIOS:
a. Worst Case Release Scenario: The worst case release scenario at the Bruno's Distribution Center would be if there was a rupture in the Chemical Pressure Receiver (CPR 1). CPR 1 holds approximately 18,000 lbs of liquid ammonia and some residual vapors. If CPR 1 is ruptured at the bottom, leaving a 1 inch size hole,
the liquid would spew out into the air. Once ammonia hits the open air, it will turn into a vapor. The room will immediately turn into a white fog making it hard to see. Before an employee can even enter the area, they would need to be in SCBA, Level A equipment. The ammonia vapors will be removed through an automated ventilation system to the outside atmospere. This amount of ammonia vapor, into the open air, could have a toxic endpoint of up to 1.5 miles.
This worse case scenario is unlikely to happen because of the following reasons: CPR 1is located inside of a concrete room. Power equipment is not allowed in the room. The room is manned by a refrigeration engineer 24 hours a day. These refrigeration engineers are also Hazardous Waste Operations and Emergency Response (HAZWOPER) technicians (they know how to shut the system down). Security patrols the area frequently. There is a thick blanket of insulation around the steel storage tanks. The whole system is
b. Alternative Release Scenarios: One alternative release scenario is if a valve seal leaks. In a valve seal leak, the ammonia escapes through the seal at a very low level. You could have 1 to 2 lbs. escaping every minute and may lose up to 100 lbs. in an hour. This amount can have a toxic endpoint within .05 miles. This would keep the release within the facility grounds.
This alternative release scenario is also unlikely to happen because of the constant preventive maintenance taking place on the system. The system is inspected weekly. Additionally, there are scensors throughout the system that inform a computer in the control room if there are any leaks. With the inspection and the scensor system, leaks are taken care of quickly. Even during normal maintenance, escaping ammonia is minimal.
4. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS:
Bruno's Distribution Center complies with
OSHA standard 29 CFR 1910.119, Process Safety Management for Highly Hazards Chemicals. Bruno's has a written PSM. PSM is management of the whole ammonia flow process. In the process you are evaluating every aspect and point of the ammonia system asking the question "What If this valve has a leak, what do we do?" "What if this accumulator is ruptured, what do we do?" Bruno's Distribution Center has an established PSM Team and (HAZWOPER) Team. The PSM and HAZWOPER Teams are made up of 12 employees. Four of these employees are HAZWOPER Technicians. With the 2 teams, periodic training takes place to keep all up to date on changes or updates.
5. Five Year Accident History:
There was one major ammonia leak within the last 5 years. This took place on April 21, 1998. It occured when a pressure relief valve was broken off of a compressor by a scrubbing machine. Ammonia escaped out of the broken valve, forming a white cloud in the room. Within minutes the level of ammo
nia reached the Lower Explosive Limit. An ignition source set off a flash fire and exploded. Approximately 8000 lbs. of ammonia was lost. What did not explode was controlled by water through the sprinkler system.
There has not been any other releases of ammonia into the atmosphere within the last five years. There has been some small leaks do to repair of pipes, seals, and other basic maintenance. These releases had a minimal amount escape. In measurement, these were less then 1 lb. released.
6. EMERGENCY RESPONSE PROGRAM:
The Bruno's Distribution Center has an established Emergency Response Program set up to guide employees on what to do if an emergency arises. The following are areas of training and preparation that the Bruno's Distribution Center employees are given.
a. Evacuation for fire or other emergencies 2 times a year.
b. Tornado and hazardous weather response 2 times a year.
c. Emergency Response Plan set up for the Jefferson Coun
d. 31 member trained first aid team.
e. 7 fire teams; 1 for each shift and department.
f. Alarm Tests.
g. HAZWOPER Team.
h. PSM Team.
i. Respirator Protection Program.
j. Contractor Safety Program.
k. Monthly Supervisor Safety Training.
7. PLANNED CHANGES TO IMPROVE SAFETY:
Bruno's Distribution Center is on a contiuous supervisor and employee safety training program to enhance safety in the work place. Over the next year, Bruno's will be working on further training on the EPA RMP and PSM programs. Bruno's will continually strive for excellence in safety.