Ralphs Compton Facility - Executive Summary |
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Ralphs Grocery Co. Compton Facility Risk Management Plan Executive Summary ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Ralphs Grocery Co. has a long-standing commitment to worker and public safety. We are committed to operating and maintaining all of our processes in a safe and responsible manner. We have implemented a combination of accident release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public, as well as to protect the environment. These programs include governmental requirements, such as the Environmental Protection Agency's (EPA) Risk Management Program (RMP) rule and the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) standard. DESCRIPTION OF THE FACILITY AND REGULATED SUBSTANCES Ralphs Grocery Co., Compton distribution center, located in Compton, California, operates an anhydrous ammonia refrigeration system. The refrigeration system operat es to provide cooling for creamery manufacturing and food warehousing operations at the site. The facility is recognized as a covered source under the RMP rule as the facility maintains quantities of regulated substances listed in the RMP rule. The Compton Facility does not maintain specified quantities of any RMP regulated flammable substances, but does utilize the following RMP regulated toxic substance: 7 Anhydrous Ammonia HAZARD ASSESSMENT RESULTS EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these hypothetical scenarios. Unless otherwise specified, no credit was taken for administrative controls or mitigation measures in evaluating the off-site impact of the scenarios. WORST CASE RELEASE SCENARIO The worst case scenario (WCS) associated with the toxic substances at the facility is a failure of the perishables ammonia refrigeration sys tem high pressure receiver, resulting in an instantaneous release of 20,000 pounds of anhydrous ammonia. According to EPA's Off-site Consequence Analysis (OCA) Guidance Table, this release could impact off-site public receptors. No credit for administrative controls were taken into account in evaluating this scenario. Specific systems to prevent this scenario from occurring, as well as mitigate its effects should they occur, include: Ammonia Gas Detector and Alarm Systems: This system is designed to detect toxic vapor releases and to automatically activate alarm systems to alert operations personnel of a possible emergency situation. Sprinkler Fire Water System: This system could be used to mitigate and suppress toxic vapor clouds from migrating from the facility boundaries. Pressure Relief Systems: Pressure relief systems help to ensure that over-pressures within tanks are mitigated. Surveillance: Security personnel routinely monitor the process and facility perimeters. A LTERNATIVE RELEASE SCENARIOS Anhydrous ammonia: The alternative case scenario (ARS) for anhydrous ammonia assumes a leak in an ammonia loading hose. This scenario leads to a 4000 pound release of anhydrous ammonia in 10 minutes. Although active mitigation measures do exist if this scenario were to occur, no active mitigation measures were taken into account in evaluating this scenario. According to EPA's Off-site Consequence Analysis (OCA) Guidance Table, this release could impact off-site public receptors. Specific systems to prevent this scenario from occurring, as well as mitigate its effects should they occur, include: Emergency Shutdown Systems: A manual emergency shutdown system is designed to shut down the pumps and put the transfer valves in a fail-safe position. Ammonia Gas Detector and Alarm Systems: This system is designed to detect toxic vapor releases and to automatically activate alarm systems to alert operations personnel of a possible emergency situation. F ire Water System: This system could be used to mitigate and suppress toxic vapor clouds from migrating from the facility boundaries. Surveillance: Operations personnel routinely monitor the process and facility perimeters. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at the facility. Because processes at the facility that are regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. Employee Participation The facility encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to all inf ormation created as part of the facility accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the facility; the plan addresses each accident prevention program element. In addition, the facility has a number of initiatives under way that address process safety and employee safety issues. These initiatives include forming teams to promote both process and personal safety. The teams typically have members from various areas of the plant, including operations, maintenance, engineering and plant management. Process Safety Information The facility keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments within the facility are assigned responsibility for maintaining up-to-date process safety information. A table summarizing the reference documents and their location is readily available as part of the written employee participation plan to help employees locate any necessary process safety information. Chemical-specific information, including exposure hazards and emergency response / exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the facility has documented safety-related limits for specific process parameters. The facility ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). The facility also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Process Hazard Analysis The facility has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The facility primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the mo st systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding is documented and retained. To help ensure that the process controls and/or process h azards do not eventually deviate significantly from the orginal design safety features, the facility periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. Operating Procedures The facility maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annually certifie d as current and accurate. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process. In addition, the facility maintains guidance on how to respond to upper or lower limit exceedances for specific process or equipment parameters. This information, along with written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. Training To complement the written procedures for process operations, the facility has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in facility operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years. All of this training is documented for each operator, including the means used to verify that the operator understood the training. Contractors The facility uses contractors to supplement its work force during periods of increased maintenance or construction activities. The facility has procedures in place to ensure that contractors working on or near process equipment: (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, ( 6) inform facility personnel of any hazards that they find during their work. This is accomplished by providing contractors with: (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, the facility evaluates contractor safety programs and performance during the selection of a contractor. Facility personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSRs) The facility conducts a PSSR for any new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Mechanical Integrity The facility has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment. Maintenance personnel receive training on (1) an overview of the pr ocess, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provides a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or an MOC team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Another integral part of the mechanical integrity program is quality assurance. The facility incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipm ent is suitable for its intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices The facility has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout - tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change The facility has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. Incident Investigation The facility promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incid ent or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to facility management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations. Compliance Audits To help ensure that the accident prevention program is functioning properly, the facility periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and management personnel participate as audit team members. The audit team develops findings that are forwarded to facility management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. CHEMICAL SPECIFIC PREVENTION STEPS The processes at the facility have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all EPA RMP-covered processes at the facility. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors. In addition to the accident prevention program activities, the facility has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The followi ng types of safety features are used in various processes: Release Detection 7 Release detectors with alarms Release Containment / Control 7 Valves to permit isolation of the process (manual or automated) 7 Automated shutdown systems for specific process parameters (e.g., high level, high temperature) 7 Curbing or diking to contain liquid releases 7 Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pumps) 7 Atmospheric relief devices Release Mitigation 7 Fire suppression and extinguishing systems 7 Trained emergency response personnel 7 Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) FIVE-YEAR ACCIDENT HISTORY In the last five years there has not been an accident or incident involving an EPA RMP chemical at Ralphs Grocery Co. facility in Compton, California that resulted in an on-site death, injury, or property damage; or a known off-site death, injury, eva cuation, shelter-in-place, property damage or environmental damage. EMERGENCY RESPONSE PROGRAM INFORMATION The facility maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and postincident cleanup and decontamination requirements. In addition, the facility has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive trai ning in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to facility processes or other facility facilities. The emergency response program changes are administered through the MOC process, which includes informing and/or training affected personnel in the changes. The overall emergency response program for the facility is coordinated Compton Fire Department. The facility has around-the-clock communications capability with appropriate Fire Department officials. This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. The facility also conducts periodic emergency drills that involve the Fire Department. PLANNED CHANGES TO IMPROVE SAFETY The facility resolves all findings from PHAs, some of which result in modifications to the process. The following types of changes are planned: - Install add itional barriers to protect process equipment from collision with vehicles - Mark equipment to better facilitate proper identification - Revise procedures to improve clarity |