Publix Supermarkets, Inc.-Dacula Facility - Executive Summary
PUBLIX SUPER MARKETS, INC.- DACULA DISTRIBUTION AND MANUFACTURING FACILITY |
RISK MANAGEMENT PLAN
1. Corporate Prevention and Emergency Response Approach
The Publix Super Markets, Inc. (Publix) Dacula Distribution and Manufacturing Facility is located at 445 Hurricane Trail, Dacula, Gwinnett County, Georgia. Publix 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. Publix '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 Dacula Distribution and Manufacturing Facility (Dacula Facility) is located on the north side of State Road 316 just east of the boundary between Lawerenceville and Dacula Georgia. The warehouse consists of areas for dry, frozen, a
nd cooler storage of non-perishable and perishable items for distribution to the Publix Super Markets. The manufacturing facility produces milk, ice cream, and other dairy products which are then stored in the perishable warehouse until they are shipped
The Dacula Facility has an ammonia refrigeration system which exceeds the 10,000 lb. RMP threshold quantity. The ammonia refrigeration system's equipment is located in the perishable warehouse and in the compressor room. The control pressure receiver (CPR) or storage vessel is located inside this room. The CPR is the largest capacity vessel in the ammonia refrigeration system capable of holding approximately 43,058 lbs. of ammonia.
3. Description of the Worst Case and Alternative Release Scenarios
The Worst Case release scenario is the rupture of the CPR vessel, releasing 43,058 lbs. of ammonia gas into the compressor room over a ten minute period. Under worst case weather conditions and considering passive mitigation, the amm
onia gas could travel 2.2 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 results.
The Alternative Release Scenario is characterized by a leak rate of 189.4 lb./min. from a pipe attached to the CPR. Under normally expected weather conditions, taking into consideration the passive mitigation of the CPR being enclosed at the facility, the ammonia gas could travel 0.30 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 results.
4. Prevention Program
This Dacula Facility 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 Facility's refrigeration process in the Program 3 level. The Dacula Facility will use its PSM progra
m as the required Program 3 Prevention Program.
The Dacula Facility has a program in place to comply with the OSHA Process Safety Management Standard, 29 CFR 1910.119. The PSM Program for the ammonia process was established in 1995 and was audited in December 1997. 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 Dacula Facility also developed written operating procedures for the refrigeration process. These procedures cover all phases of operation and include information on safety devices. These procedures are used to train all operators and mechanics who work on the ammonia refrigeration processes to ensure consistency of operation and minimize human error. 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 periodic review of all equipment information, including Piping & Instrumentation Diagrams (P&IDs). The staff ensures that if equipment design deficiencies are identified that they are corrected. 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 Dacula Facility's refrigeration staff has the skills necessary to identify unsafe conditions. The training program includes Process Hazards Analyses, Operating Procedures, Maintenance Procedures, Emergency Response, and Safe Work Practices. The Ammonia Refrigeration Staff, with the assistance of a consultant, performed a PHA of the process in 1
995. Additional PSM procedures, including Management of Change, Pre-Startup Safety Review, Compliance Audits, and Incident Investigation also ensure the continued safe operation and prompt correction of deficiencies. The PSM Program receives full support of plant management and involvement of employees at all levels.
5. Accident History
The Dacula Facility has had no accidental releases of ammonia that have resulted in offsite consequences in the past five years.
6. Emergency Response Program
The Dacula Facility has Emergency React Procedures in place. The program complies with 29 CFR 1910.38. The site also has some internal emergency response capability and has developed a program to comply with paragraph (q) of 29 CFR 1910.120. The current plan has been coordinated with the Gwinnett County Fire and Emergency Services. Notification is made locally by dialing 911or contacting the State Notification point at 1-800-241-4113.