Associated Wholesale Grocers, Inc. - Executive Summary |
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This is to inform all intrested persons, including employees that Associated Wholesale Grocers, Inc. is complying with OSHA's Process Safety Management Standard, Title 29 Code of Federal Regulations (CFR) 1910.119, and EPA's Risk Management Program regulations Title 40 CFR part 68, to deal with the risks involved with the storage, handling, and processing of hazardous chemicals. In this way we promote overall plant, worker, and public safety. These programs enable our facility 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 prevent accidental fatalities, injuries and illnesses and avoid physical property damage. Our safety programs are applied to any activity involving hazardous chemicals, or a combination of these activities. Any group of vessels which are interconnected and seperate vessels which are located such that a hazardous chemical could be involved in a potential release shall be considered a single process. Our safety programs prevent accidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment. These rules are detailed and improved as necessary. These rules are communicated to and accepted by all employees at the facility. The ammonia refrigeration process provides freezing and sub-freezing temperatures for frozen food products. The ammonia refrigeration process is set up in two stages. The low side operates from -19 to -10 degrees F to maintain a freezer temperature of 0 degrees F. The high side operates between 15 and 25 degrees F to maintain a loading dock temperature of 32 degrees F. The aggregate amount of ammonia in the system is 12,500 lbs. The following is a brief description of a worst-scenario of an accidental release. A worst-case scenario release would occur in the highly improbable event that the hig h pressure receiver containing 4,500 pounds of ammonia ruptured, resulting in a ten minute release of its entire contents. Under worst-case weather conditions, ammonia could travel .4 miles before dispersing enough to no longer pose a hazard to the public. This scenario is unlikely for the following reasons: worst-case weather conditions are uncommon, the vessel is enclosed in building that would withstand and help to contain such a release, industry standards for the manufacture and quality control of pressure vessels were employed in its/their construction, the accident prevention program in place at the facility including the mechanical integrity program for regular maintenance, inspection and testing, and replacement of equipment, if necessary; installed ammonia sensors in the system to warn of leaks; alarms and the auto-dialing system in place to warn operating personnel of process upsets; and the emergency response plan and equipment in place at the facility. A more likely, y et still imporbable accident scenario would involve the failure of a transfer hose during unloading resulting in a release of 1000 pounds of ammonia over a time period of ten minutes. Under common weather conditions, ammonia could travel 0.1 miles before dispersing enough to no longer pose a hazard to the public. Transfer hose failure was chosen as the alternative release scenario because it is a temporary connection and constructed of materials are other than steel. This scenario is unlikely for the following reasons: emergency equipment such as an excess flow valve on the tank truck and valves to isolate the trasfer hose; the facility accident prevention program in place at the facility including operating procedures to have personnel present at all times during unloading, and the mechanical integrity program for regular maintenance, inspection and testing, and the replacement of equipment, if necessary; and the emergency response plan and equipment in place at the facility. The general accidental release prevention program includes a multifacited approach beginning with the design of the process, ANSI/IIAR 2-1991 Standards for Equipment, Design, and Installation of Ammonia Mechanical Refrigeration Systems were used to design and install the system. Our process is maintained by both interanl and external resources that follow recognized and published mechanical integrity programs. Our operating personnel have more than twenty-five years of experience directly related to ammonia refrigeration systems and their operation, our auditing program as outlined in OSHA's PSM Standard 29 CFR 1910.119 is utilized to verify and validate the critical operating components of teh covered process. There ahve been no accidental releases of teh covered process. This facility's emergency response program is based on the OSHA requirements for Emergency Action Plans (29 CFR 1910.38 dn 1910.119) and HAZWOPER (29 CFR 1910.120). We have trained employees for emergency response and maintain a written emergency response plan. This plan is coordinated with the local Emergency Planning Committee (LEPC) and the local fire department. We will be conducting annual drills for implementation fo the emergency response plan at the facility with the participation of the LEPC, the local fire department and our third party response contractors. |