Spartan Stores - Executive Summary |
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Spartan Stores, Inc. (Spartan) is a distributor of retail grocery products. Their distribution facility is located at 850 76th Street, SE in Grand Rapids, Michigan. As required in the Risk Management Program rules listed in 40 CFR Part 68, this document contains information intended to prevent and minimize the impact or accidental release of extremely hazardous substances. The intent of the rule is to reduce the likelihood of a chemical release and the consequences of a release if one were to occur. The maximum inventory at this facility exceeds the U.S. Environmental Protection Agency (EPA) threshold of 10,000 pounds for anhydrous ammonia; therefore, an RMP is required for the facility. The refrigeration process utilizes anhydrous ammonia which is a regulated substance under the EPA Clean Air Act Risk Management Program. Spartan has a maximum inventory of 30,000 pounds of anhydrous ammonia. The 112(r) rule lists an anhydrous ammonia threshold of 10,000 pounds; therefore, an RMP wa s prepared for Spartan. During the past five years, Spartan has not had an accidental release that met the criteria of 40 CFR 68.42a. Therefore, Spartan qualified for regulation under Program 3. Because of the potential hazards when using ammonia as a refrigerant, it is of paramount importance that steps be taken to minimize the risk of a catastrophic release. Consequently, to minimize the risk of release, a Prevention Program that is based on the following key elements is in place: Spartan has purchased, installed, and maintains high-quality equipment; Spartan has developed plans and programs to ensure safe operation of the system; Spartan has provided process information and training to affected employees, and requires contractors to verify knowledge of training and of Spartan's procedures; Spartan conducts audits to ensure adherence to plans and programs as well as to continue the minimization of risk. Spartan has developed and implemented many standard operating procedures fo r the processes covered under the OSHA process safety management requirements. These procedures outline steps for each operating phase, operating limits, health and safety considerations as well as safety systems and their functions. The procedures outline safe work practices to provide for the control of hazards during operations. The process complies with good engineering practices and procedures are in place for maintaining mechanical integrity and planning for change. Employees are trained in safe operations, health and safety hazards, and emergency procedures with respect to their job tasks. Due to the extensive preventative maintenance procedures, training, and emergency response procedures that have been implemented at Spartan, it is highly unlikely that this scenario would occur. However, a hazard analysis was conducted to predict the offsite impact in the event of an emergency, according to the procedures outlined in the rule. The worst-case release quantity for toxi c gases is assumed to be released to the atmosphere over a period of 10 minutes. The maximum quantity of ammonia stored in any one vessel at Spartan is 30,000 pounds. Therefore, the release rate used in the consequence modeling was 3,000 pounds per minute for the entire 10-minute release period. No mitigation or administrative controls were considered. The rule requires that the worst-case impact assume that the all receptors in the radius from the point of release are affected. In addition to the fact that it is highly improbable that the entire contents of the ammonia tank would be released in one event, it is also improbable that the release would spread in all directions from the site. Therefore, it cannot be overstated that the results of this analysis do not reflect the type of release that would be anticipated to occur. For Program 3 processes, the rule requires that at least one alternative release scenario be analyzed for each regulated toxic substance. The alternativ e release scenario is more likely to occur than the worst-case release. Potential alternative release scenarios for Spartan include valve leaks, gasket leaks, and pipe breaks. Because a pipe break would result in the greatest release, this was determined to be the alternative release scenario. Monitoring equipment located inside Spartan will detect low levels of ammonia and alert staff of a possible leak. In the event of a release inside the facility, a prompt response and proper control measures would be implemented. For this reason, a pipe from the refrigeration system which is located outside of the facility was used in the alternative release scenario. There are no administrative controls to limit the quantity of ammonia in the pipe; therefore, the entire extent of the pipe was assumed to be filled with liquid ammonia. Since the pipe is located outside the building, no mitigation was considered. The pipe has a 2-inch diameter and is 500 feet long. The quantity that was as sumed to be released instantaneously from the pipe was 435 pounds. Spartan has been actively involved in emergency response planning for many years. They have worked closely with the Kent County Local Emergency Planning Committee (LEPC) over the past several years. Spartan is a Program 3 source and a non-responding facility. The Spartan Emergency Response Plan outlines procedures for internal response to incidental releases and notification and coordination with the local emergency response organizations in the event of an incidental release which cannot be contained and will have offsite impacts. Spartan has an ongoing process to evaluate health and safety and environmental programs. In addition, periodic audits are completed by outside contractors to identify areas for improvement. As a result of these efforts, Spartan has plans to redesign evacuation maps to be more readable at a glance. These maps will be posted in additional areas of the facility and provided to contr actors conducting work onsite. Bid procedures are being revised to require contractors be responsible for training their employees in the safety hazards relevant to their work onsite at Spartan. |