Winn-Dixie Orlando Warehouse Facility - Executive Summary
WINN-DIXIE STORES, INC.- ORLANDO WAREHOUSE FACILITY |
RISK MANAGEMENT PLAN
1. Corporate Prevention and Emergency Response Approach
The Winn-Dixie Stores, Inc. Orlando Warehouse Facility (Orlando Warehouse) is in the Orlando Division of the Winn-Dixie Stores, Inc. located in Orlando, Florida. The property is also the site for the Orlando Division headquarters. Winn-Dixie Stores, Inc. 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. Winn-Dixie Stores, Inc.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 Orlando Warehouse is located at 3015 Coastline Drive in the north central part of Orlando, Florida. The warehouse consists
of areas for dry, frozen, and cooler storage of non-perishable and perishable items for distribution to the Winn-Dixie Supermarkets.
The Orlando Warehouse has an ammonia refrigeration system which exceeds the 10,000 lb. RMP threshold quantity. The ammonia refrigeration systems equipment is located in the northeast corner of the building in the northeast corner of the property in the compressor room. To the south of this room outside, the high pressure receiver (HPR) is located along with the balance tank. All other refrigeration equipment is located in the compressor room inside the warehouse building. The HPR is the largest capacity vessel in the ammonia refrigeration system, capable of holding 10,700 lbs. of ammonia.
3. Description of the Worst Case and Alternative Release Scenarios
The Worst Case release scenario is the rupture of the HPR vessel, releasing 10,700 lbs. of ammonia gas over a 10-minute period. Under worst case weather conditions, the ammonia gas could trave
l 1.8 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 EPA Ammonia Guidance method.
The Alternative Release Scenario is a leak at a rate of 1685 lb./min. from the HPR liquid supply line due to pipe connection failure from worker/human error or corrosion of the pipe. Under normally expected weather conditions, the ammonia gas could travel 0.7 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.
4. Prevention Program
This 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 Orlando Warehouse process in the Program 3 level. The Orlando Warehouse facility will use its PSM program as the required Program 3 Prevention Program.
rlando Warehouse has a program in place to comply with the OSHA Process Safety Management Standard, 29 CFR 1910.119. The PSM Program was established in 1998 for the ammonia process. 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 Orlando Warehouse also developed written operating procedures for the refrigeration process. These procedures cover all phases of operation and include information on safety devices. These procedures will be used to train all operators and mechanics who work on the ammonia refrigeration process to ensure consistency of operation and minimize human error. In addition, all refrigeration mechanics receive training through the Refrigeration Engineers and Technicians Association (R
ETA) training course. 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 review of all equipment information, the development of updated Piping & Instrumentation Diagrams (P&IDs), and the correction of any equipment design deficiencies found. 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 Orlando Warehouse refrigeration staff has the skills necessary to identify unsafe conditions, Process Hazard Analysis (PHA) training was conducted. The staff also performed a PHA of this process. Other PSM procedures, including Management of Change, Pre-Startup Safety Review, Compliance Audits, and Incide
nt Investigation are also part of the program to ensure 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 Orlando Warehouse facility has had no accidental releases of ammonia in the past five years.
6. Emergency Response Program
The Orlando Warehouse Facility has an Emergency Response Program in place. The program complies with 29 CFR 1910.38. The site also has some internal emergency response capability and is developing a program to comply with paragraph (q) of 29 CFR 1910.120. The current plan has been coordinated with the Orange County Fire Department and Hazardous Materials Response Team, and the Regional Local Emergency Planning Committee. Notification is made locally by dialing 911, and by notifying Florida State Warning Point at (800) 320-0519.