Dillons Foods - Executive Summary |
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Note: for complete written RMP with Executive Summary, see attached text file below. The following is the written Executive Summary. EXECUTIVE SUMMARY Background Data In accordance with Title 40 of the Code of Federal Regulations Chapter 68 (40 CFR 68) promulgated by the Environmental Protection Agency (EPA), Dillons Foods (Dillons) submits this Risk Management Plan (RMP) for operations at their Hutchinson, Kansas facility. Dillons operations include storing frozen foods, grocery products, dry goods and distribution. Dillons has been in operation at this facility for over 40 years providing quality grocery products and over 500 jobs to the local community. Accidental Release Prevention and Emergency Response Policy Dillons is committed to protecting the health of its employees, the surrounding community, and the environm ent; therefore it is Dillonss policy to maintain compliance with 40 CFR 68 as well as Occupational Safety and Health Organization (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Federal Regulations Chapter 1910, Section 119 (29 CFR 1910.119), and OSHAs Hazardous Operations and Emergency Response regulations (29 CFR 1910.120). Stationary Sources and Regulated Substances Dillons is subject to 112(r) because ammonia, a regulated substance, is present at the facility in amounts greater than 10,000 pounds. Dillons is required to maintain low temperatures in the food processing areas of the plant that are within standards required by the United States Department of Agriculture (USDA). Dillons uses anhydrous ammonia (the 112(r) regulated substance) as a refrigerant to maintain the 546,000 ft2 facility within the required range of operating temperatures. Anhydrous ammonia is an industry-standard refrigerant for grocery distribution facilities. Dillons refrigeration system consisting of receivers, compressors, evaporators, condensers, and piping in three systems containing a maximum amount of 22,000 pounds of anhydrous ammonia. The largest of the three systems contains 12,000 pounds of anhydrous ammonia. Worst Case Release Scenario As required by 40 CFR 68 Subpart B, Dillons has evaluated a worst-case release scenario for anhydrous ammonia using the parameters specified by the EPA. Dillonss worst case release scenario is: the rupture of the high pressure ammonia receiver (2,468 gallons) when filled to 80% capacity (maximum fill capacity allowed by engineering controls) over a 10-minute period. Using the EPAs RMP*Comp program, the maximum distance to the toxic endpoint is 0.9 miles. The worst-case release scenario was developed following EPA regulations and is not considered to be a likely release scenario. During normal operations, Dillons maintains the receiver at no more than 50% capacity. Only during pump-down operations does the receiver have the potential to be filled to 80% of capacity. The receiver is operated in pump-down mode less than 1% of the time during the year. Alternative Release Scenario A more realistic release scenario (alternative release) was developed by Dillons taking into consideration the 5-year history of operations experience and the hazards identified in the process hazard analyses (PHAs) conducted under the Occupational Safety and Health Organization (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Federal Regulations Chapter 1910, Section 119 (29 CFR 1910.119). The most likely release scenario identified by Dillons would be a fracture or leak in a liquid line or unit containing ammonia liquid. Using EPAs RMP*Comp program, the maximum distance to the toxic endpoint is 0.27 miles. Accidental Release Prevention Program The ammonia refrigeration system is designed and constructed in accordance with ANSI/IIAR 2-1992 Sta ndard for Equipment, Design, and Installation of Ammonia Mechanical Refrigerating Systems. To prevent and mitigate accidental releases of anhydrous ammonia, Dillons has implemented several precautionary measures. Dillons has implemented OSHAs PSM program and as such, has evaluated and engineered for anhydrous ammonia releases. Some of the controls installed to prevent catastrophic releases of ammonia are process equipment (vents, pressure relief valves, backup pumps, and manual shutoffs) and automated controls (automatic shut-offs, ammonia leak detection system, and electrical distribution system grounding). In addition, Hutchinson Fire Department HazMat team responds to any ammonia release at the facility. Two (2) Dillons personnel are being trained to respond to potential ammonia releases (HazMat). Dillons has developed standard operating procedures for all employees and contractors that have contact with the ammonia refrigeration system that incorporate safety measures into the procedures. These safety procedures were developed by Dillons and are reviewed on an annual basis. Dillons encourages employee participation in development of the control measures used at the plant by means of company newsletters and training sessions. Any changes to the operating procedures are communicated to affected employees following written management of change procedures established by Dillons. Dillons understands that maintaining the refrigeration system in good working order is essential to preventing accidental releases; therefore Dillons has implemented a preventative maintenance program. The preventative maintenance program is scheduled, documented and managed using a computer maintenance management software system to ensure that regular maintenance occurs on the system To ensure that Dillonss control measures are effective in maintaining the safe operation of the plant, regularly scheduled audits are performed on the ammonia refrigeration system: 7 In accorda nce with the PSM program, Dillons conducts detailed PSM compliance audits every three years that incorporate review of process safety information, process hazard analysis, operating procedures, training programs, system mechanical integrity, management of change, pre-start up review procedures, compliance audit procedures, incident investigation procedures, employee participation programs, hot work permit procedures, and contractor safety procedures. 7 In addition, Dillons is audited by the AIB on an annual basis. 7 Dillons insurance carrier also conducts independent audits on an annual basis. Five-Year Accident History Over the last five years, Dillons has not experienced an accidental off-site release of anhydrous ammonia from the ammonia refrigeration system Dillons has documented emergency response procedures in a document entitled DILLONS FOODS EMERGENCY RESPONSE PLAN in order to facilitate response efforts in the event of an off-site anhydrous ammonia release. I ncluded in the SOP are measures to be taken internally by Dillons as well as measures to be taken by off-site response agencies. REVIEW: Dillons is training 2 on-site personnel to respond to accidental ammonia releases. These personnel are being trained in accordance with 29 CFR 1910.120, OSHAs Hazardous Operations and Emergency Response regulations according to their duties and function. These personnel are receiving initial training and an annual update training thereafter. As an additional training exercise, simulations of an emergency release with off-site effects are conducted twice yearly with the entire emergency response system. This involves coordination between Dillonss HazMat team and multiple local fire, ambulance and police departments; as well as the local hospital. This simulation will be critiqued and changes made to the SOP as appropriate. Dillons intends to do another simulation in the near future. To assure that the local governmental response agencie s are familiar with Dillonss emergency response procedures, Dillons has submitted copies of the SOP for review and approval by the local agencies. The following local agencies have reviewed and approved Dillonss SOP: 7 Hutchinson Fire Department 7 L.E.P.C. Local energy planning commission 7 HAZMAT Rsponse Inc. Wichita, KS To plan for an ammonia release with off-site effects, Dillonss SOP includes procedures/equipment to mitigate the release, procedures to inform local response agencies, transportation maps for response agencies, evacuation route maps, and procedures for public communication. In addition to the above local response agencies, Dillons has arranged emergency response assistance with a local clean-up contractor. In the event of an anhydrous ammonia release with off-site effects, the general public will be warned using the following methods: 7 Sirens 7 Broadcast message local radio stations. 7 Police and fire vehicles equipped with public address systems, and 7 Door-to-door notification of residents (if time permits). As backup measures, Dillons has arranged emergency response assistance with a local clean-up contractor and will coordinate those efforts with the Fire Department. Planned Changes to Improve Safety As a result of Dillonss initial process hazard analyses, several changes are planned at the facility to improve safety and prevent anhydrous ammonia releases. These changes are scheduled to be implemented by December 2001 and include improvements to operating procedures, relocation of ammonia equipment to safer locations, increased protection of ammonia equipment (e.g., guarding), and increased ammonia safety training. |