Kroger Memphis Distribution Center - Executive Summary |
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RM PLAN EXECUTIVE SUMMARY A. Accidental Release Prevention and Emergency Response Policies Memphis Distribution Center recognizes management's responsibility in protecting its employees, the public, the environment, equipment, and property. The safety and health of all personnel are very important. The control of accidents has been and will continue to be a basic responsibility of all personnel in the Memphis facility. To accomplish the company's goal in preventing accidents, the facility has established a Plant Safety Program. The objectives of the Plant Safety Program are to: maximize safety performance, eliminate human suffering and the economic burden resulting from injuries and accidents and reduce losses associated with damage of property. One of the activities associated with the Plant Safety Program has been the development and implementation of accidental release prevention and emergency response programs which are designed to comply with OSHA's Process Safety Manage ment (PSM) standard (Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119), and EPA's Risk Management Program (RM program) regulation (Risk Management Programs for Chemical Accidental Release Prevention, 40 CFR Part 68). Mr. Mabry Ford, Distribution Maintenance Manager, is responsible for implementation of the Risk Management Program. The purpose of the accidental release prevention and emergency response programs is to prevent the occurrence, and minimize the consequences of significant releases of toxic substances as well as fires, explosions, and other types of catastrophic accidents. Overall, these programs help prevent accidental fatalities, injuries and illnesses environmental impacts and physical property damage. The accidental release prevention and emergency response programs help prevent accidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment. These rules are detailed a nd improved as necessary. They are also communicated to and accepted by all employees at the facility. In addition to the Plant Safety Program, Memphis Distribution Center follows these corporate safety guidelines. Employee Handbook Plant Safety Rules Kroger Company Contractor Safety Rules Kroger Company Safety Inspection and Abatement Plans Behavioral Accident Prevention Process (BAPP) B. Stationary Source and Regulated Substances Handled Memphis Distribution Center is part of the Kroger Company . The facility is a warehouse that stores perishable and frozen food products for assembly and distribution to over 100 retail outlets. The facility operates an ammonia refrigeration system to provide cooling and freezing capabilities. The amount of anhydrous ammonia (CAS #7662-41-7) contained in the system is in excess of 10,000 pounds. The maximum inventory in the system is approximately 36,000 pounds. Since an ammonia release from the system could pose a risk of offs ite public and/or environmental impact and the system is regulated under the OSHA PSM standard (29 CFR 1910.119), the system is subject to the Program 3 requirements of the EPA's RM program. C. Summary of Worst-Case and Alternative Release Scenarios The worst-case release scenario at the Memphis Distribution Center facility involves the release of 18,367 pounds of ammonia over a 10 minute period due to the failure of the Medium Temperature Vertical Recirculator vessel. This quantity represents the maximum capacity of the recirculator vessel. Under worst-case weather conditions, ammonia could travel 1.7 miles before dispersing enough to no longer pose a hazard to the public. This distance has been calculated based on the method provided in the EPA Risk Management Program (40 CFR 68) Guidance for Ammonia Refrigeration. The worst-case release scenario is unlikely for the following reasons: The worst-case weather conditions which were used for this scenario are not typical; I ndustry standards were followed for the manufacture and quality control of the tank; The recirculator is located in an enclosed area that could help to contain such a release; The recirculator is located in a low traffic area within the engine room which minimizes the possibility of loss of containment due to vehicular impact (e.g., from forklifts etc.); Computer controls limit the maximum ammonia inventory in the vessel to 80 percent liquid level; system shutdown is initiated at 90 percent liquid level; Ammonia is not corrosive in this service and the vessel is relatively new; An ammonia detector which is tied to emergency ventilation fans is located near the recirculator in the engine room; Pressure safety valves limit operating pressure in the vessel; The facility has a preventive maintenance program in place to maintain the on-going integrity of vessels; The facility has a training program designed to ensure that the system is operated by qualified person nel; and, The facility emergency response procedures enable trained personnel to respond quickly to isolate any potential releases. The alternative release scenario at the Memphis Distribution Center facility involves the release of 4,260 pounds of ammonia over a 60 minute period through a defective pressure safety valve (PSV) on the high pressure receiver, which lifts to relieve high system pressure but fails to reseat properly. Under alternative release weather conditions, ammonia could travel 0.1 miles before dispersing enough to no longer pose a hazard to the public. This distance has been calculated based on the method provided in EPA's Risk Management Program (40 CFR 68) Guidance for Ammonia Refrigeration. The alternative release scenario is unlikely for the following reasons: Industry standards were followed for the manufacture and quality control of the pressure relief devices; The system is operated at considerably lower pressures compared to the PSV's relief pre ssure setting; Ammonia is not corrosive in this service; The facility has a preventive maintenance program in place to maintain the on-going integrity of the pressure relief devices; The facility has a training program designed to ensure that the system is operated by qualified personnel; and, The facility emergency response procedures enable trained personnel to respond quickly to isolate potential releases from any leaking equipment. D. Description of the Accidental Release Prevention Program The prevention program consists of the following elements: Employee Participation: This program involves the employees in establishing and implementing the program. Employees are also to be involved when a process hazard analysis is conducted. The program also ensures that all employees have complete access to the program. Process Safety Information: Written information has been collected which enables the employees to identify and understand the potential hazards in t he system. The written information includes the ammonia MSDS and a description of the design of the ammonia refrigeration system. Process Hazard Analysis: Formal studies using the What-If/Checklist Technique have been conducted to examine the system and identify potential hazards. Any recommendations are resolved to improve facility safety. Operating Procedures: Written, detailed procedures have been developed which describe the steps which should be followed to safely operate the ammonia refrigeration system. Training: A training program has been developed which ensures that employees are trained on all aspects of the system and on the duties which they should perform to ensure the safe operation of the ammonia refrigeration system. Contractors: All contractors are screened and evaluated before they perform work on or near the ammonia refrigeration system. The contractors are also periodically evaluated to ensure that they perform work by following safe work practices. Pre-St artup Safety Review: A pre-startup safety review is required for all new ammonia projects to verify that all safety programs are in place, training has been performed, and construction has been completed according to design standards before the project is put into use. They are also performed when there is a change in the process safety information Mechanical Integrity: This program ensures that the ammonia refrigeration systems are built and maintained using preventive maintenance procedures to minimize unexpected breakdowns or failures. Hot Work Permit: These procedures ensure that a signed permit is obtained prior to any cutting, welding, or burning. Management of Change: Procedures are designed to ensure that all changes made to the ammonia refrigeration system are properly reviewed. Incident Investigation: Procedures ensure that any incidents (and near misses) are investigated, reviewed, and documented using an investigation team. Any recommendations are resolved to improve the safety of the facility. Compliance Audits: There are procedures to conduct regular audits of the RM prevention program to ensure that the program is in place and working properly. Any recommendations from audits are resolved to improve the RM program. E. Five-Year Accident History There have been no ammonia-related incidents at the Memphis Distribution Center within the last five years that have resulted in onsite or offsite impacts. F. Description of the Emergency Response Program An emergency response program has been implemented at the Memphis Distribution Center facility. This program contains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures. The program has been coordinated with the Memphis/Shelby County Emergency Management Agency. The emergency response program consists of the following elements: Organization Plan and Responsibilities Communications Procedures Detailed Action Plans First Aid Procedures Emergency Medical Treatment Procedures Evacuation Plans Description of Outside Assistance Available Site Re-Entry Procedures Training Programs and Drills G. Planned Changes to Improve Safety The following changes are planned to improve safety conditions and further strengthen the ongoing safety efforts at the Memphis Distribution Center facility: appointment of additional refrigeration specialists for the ammonia refrigeration system restricted access to engine room via use of electronic access cards continual support for the Behavioral Accident Prevention Process (BAPP) and the Safety Key Element Assessment (KEA) process. |