Winn Dixie Montgomery, Inc.-Mongomery Warehouse - Executive Summary
WINN-DIXIE MONTGOMERY, INC.- MONTGOMERY WAREHOUSE FACILITY |
RISK MANAGEMENT PLAN
1. Corporate Prevention and Emergency Response Approach
The Winn-Dixie Montgomery, Inc. Facility (Montgomery Warehouse) is the Retail Support Center for Winn-Dixie Stores, Inc. located in Montgomery, Alabama. 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 Montgomery Warehouse is located at 6080 Mobile Highway in the southeastern section of Montgomery, Alabama. 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 Montgomery Warehouse has a two-stage ammonia refrigeration system which exceeds the 10,000 lb. RMP threshold quantity. The ammonia refrigeration systems equipment is located in the southwest corner of the property in a machine or compressor room. The high pressure receiver (HPR) or storage tank is located inside the compressor room in the warehouse building. The HPR is the largest capacity vessel in the ammonia refrigeration system capable of holding approximately 18,830 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 18,830 lbs. of ammonia gas over a ten minute period. Under worst case weather conditions, and considering passive mitigation the ammonia gas could travel 1.3 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .14 m
g/L), using the Ammonia Guidance.
The Alternative Release Scenario is a mitigated leak rate of 475.9 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 passive mitigation, the ammonia gas could travel 0.4 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 Montgomery Warehouse refrigeration process in the Program 3 level. The Montgomery Warehouse facility will use its PSM program as the required Program 3 Prevention Program.
The Montgomery Warehouse has a program in place to comply with the OSHA Pr
ocess 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, the Montgomery 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 processes to ensure consistency of operation and minimize human error. In addition, all refrigeration mechanics receive training through the Refrigeration Engineers and Technicians Association (RETA) training course. These measures ensure that all refri
geration 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 Montgomery 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 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 Montgomery Warehouse facility has had no accidental releases of ammonia in the past five years.
6. Emergency Response Program
The Montgomery 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 City of Montgomery Fire Department and Hazardous Materials Response Team, and the Regional Local Emergency Planning Committee. Notification is made locally by dialing 911, and by notifying Alabama State Warning Point at (800) 834-0699