Winn-Dixie Midwest, Inc.-Louisville Warehouse - Executive Summary |
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WINN-DIXIE MIDWEST, INC.- LOUISVILLE WAREHOUSE FACILITY RISK MANAGEMENT PLAN EXECUTIVE SUMMARY 1. Corporate Prevention and Emergency Response Approach The Winn-Dixie Midwest, Inc. Louisville Warehouse Facility (Louisville Warehouse) is the headquarters of the Midwest Division located in Louisville, Kentucky. Winn-Dixie 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'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 Louisville Warehouse is located at 720 Locust Lane in the southeast corner of Louisville, Kentucky. The warehouse consists of areas for dry and cooler storage and loading dock areas for non-perishable and perishable items for distribution to the Winn-Dixie Supermarkets. The Louisville Warehouse has a single-stage ammonia refrigeration system which exceeds the 10,000 lb. RMP threshold quantity. The ammonia refrigeration system's 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 outside under a canopy to the north of the compressor room between the older and newer sections of the warehouse building. The HPR is the largest capacity vessel in the ammonia refrigeration system capable of holding 8,000 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 8,000 lbs. of ammonia gas over a 10-minute period. Under worst-case weather conditions, 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 .1 4 mg/L), using Ammonia Guidance results. The Alternative Release Scenarios is a leak at a rate of 1,117.6 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 0.30 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 results. 4. Prevention Program This facility exceeds the ammonia threshold quantity in the ammonia refrigeration system 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 Winn-Dixie Louisville Warehouse facility's refrigeration process in the Program 3 level. The Louisville Warehouse will use its PSM program as the required Program 3 Prevention Program for ammonia. Winn Dixie has a program in place to comply with th e 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, Louisville 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 (RETA) training course. These measures ensure that all re frigeration 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 Louisville Warehouse's 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 en sure 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 Louisville Warehouse facility has had no accidental releases of ammonia or propane in the past five years. 6. Emergency Response Program The Louisville 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 Jefferson County Fire Department and Hazardous Materials Response Team, and the Louisville-Jefferson County Local Emergency Planning Committee. Notification is made locally by dialing 911, or (502) 564-2380 and by notifying the Kentucky State Warning Point at (502) 564-2380. |