Winn-Dixie Louisiana, Inc.-Hammond Facility - Executive Summary
WINN-DIXIE LOUISIANA, INC. -HAMMOND FACILITY |
RISK MANAGEMENT PLAN
1. Corporate Prevention and Emergency Response Approach
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
Two facilities, Superbrand Dairy and Winn-Dixie Hammond Warehouse, owned and operated by Winn-Dixie Stores, Inc., are located at 3925 Highway 190 West in Hammond, Louisiana. The Dairy facility manufactures milk, juice, and bottled water for distribution to the Winn-Dixie Supermarkets. The Hammond Warehouse consists of areas for dry, cooler, and freezer storage of pe
rishable and non-perishable items for distribution to the Winn-Dixie Supermarkets.
The Superbrand Dairy has an ammonia refrigeration system which exceeds the 10,000 lb. RMP threshold quantity. The ammonia refrigeration system's equipment is located in the northwest corner of the building in the northwest corner of the property in the machine or compressor room. The high pressure receiver (HPR) is located inside the compressor room. The HPR is the largest capacity vessel in the ammonia refrigeration system, capable of holding approximately 10,800 lbs. of ammonia. This vessel will be used to determine the worst-case OCA for the two facilities.
The Hammond Warehouse has an ammonia refrigeration system which exceeds the 10,000 lb. RMP threshold quantity. The ammonia refrigeration system's equipment is located in the northwest corner of the building in the northwest corner of the property in the machine or compressor room. The high pressure receiver (HPR) is located inside the compres
sor room. The HPR is the largest capacity vessel in the ammonia refrigeration system, capable of holding approximately 9,740 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 10,800 lbs. of ammonia gas over a 10-minute period. Under worst case weather conditions and considering passive mitigation, the ammonia gas could travel 1.1 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 OCA Ammonia Guidance.
The Alternative Release Scenario for the Dairy is a leak at a rate of 212 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, taking into consideration the automatic pressure cutoff system at the facility, the ammonia gas could travel 0.3 miles before dispersing eno
ugh to no longer pose a hazard to the public or environment (reaching a concentration less than .14 mg/L) using the Ammonia Guidance.
The Alternative Release Scenario for the Warehouse is a leak at a rate of 144 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, taking into consideration the automatic pressure cutoff system at the Warehouse, the ammonia gas could travel 0.2 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
Both processes exceed the ammonia threshold quantity for the OSHA Process Safety Management (PSM) Standard, 1910.119, and are therefore subject to the PSM requirements. For RMP compliance purposes, this places the Superbrand Dairy and Hammond Warehouse processes in the Program 3 level. Winn-Dixie will use its PSM prog
ram as the required Program 3 Prevention Program.
Winn-Dixie has a program in place to comply with the OSHA Process Safety Management Standard, 29 CFR 1910.119. The PSM Program was re-engineered 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, Winn-Dixie 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 Engi
neers and Technicians Association (RETA) 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 Winn-Dixie 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 Incident 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 Winn-Dixie facilities have had no accidental releases of ammonia in the past five years.
6. Emergency Response Program
The Hammond Warehouse has an Emergency Response Program in place. The program complies with 29 CFR 1910.38. The site also has internal emergency response capability at this time and is developing a program to comply with paragraph (q) of 29 CFR 1910.120. The current plan consists of evacuation procedures and allowing the W.D. Hazardous Materials Response Team to handle any release at the warehouse. The local Fire Department & the Haz.Mat. Response Team will be notified for back-up. Notification is made locally by dialing 911, and by notifying Louisiana State Warning Point at 1-(504) 925-65