Winn Dixie Charlotte, Inc.-Charlotte Warehouse - Executive Summary |
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WINN-DIXIE CHARLOTTE, INC.- CHARLOTTE WAREHOUSE FACILITY RISK MANAGEMENT PLAN EXECUTIVE SUMMARY 1. Corporate Prevention and Emergency Response Approach The Winn-Dixie Charlotte, Inc. (Winn-Dixie) Charlotte Warehouse Facility (Charlotte Warehouse) is the division headquarters for the Charlotte Division of Winn-Dixie Charlotte, Inc., located in Charlotte, Mecklenburg County, North Carolina. 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-Dixies 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 Charlotte Warehouse is located at 2401 Nevada Boulevard in the southwest corner of the city of Charlotte, Mecklenburg County, North Carolina. 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 Charlotte 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 area of the property in the machine or compressor room. The high pressure receiver (HPR) or storage vessel is located outside this room. The HPR is the largest capacity vessel in the ammonia refrigeration system capable of holding 11,624 lbs. of ammonia. The Charlotte Warehouse is also building a new ammonia refrigeration system 2 to be added in July of 1999. This process will contain a total charge of ammonia of 32,000 pounds. The HPR of this process which is the largest vessel has a capacity of 12,000 pounds and is the subject of an alternative, since it was determined that the outside HPR of process no.1 would have the worst offsite con sequences. 3. Description of the Worst Case and Alternative Release Scenarios The Worst Case release scenario is the rupture of the Ammonia Refrigeration System 1 HPR vessel, releasing 11,624 lbs. of ammonia gas over a ten minute period. Under worst case weather conditions, the ammonia gas could travel 1.80 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. Since there are two separate ammonia refrigeration systems at the Winn-Dixie Chatlotte facility, two alternative release scenarios are required to be reported. The Ammonia Refrigeration System 1 alternative-case release scenario is characterized by a release rate of 988.4 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 0.60 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. The Ammonia Refrigeration System 2 alternative-case release scenarios is characterized by a mitigated release rate of 149.3 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 of the enclosure, the ammonia gas could travel 0.20 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 Charlotte Warehouse refrigeration processes in the Program 3 level. The Charlotte Warehouse f acility will use its PSM program as the required Program 3 Prevention Program. The Charlotte Warehouse 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, the Charlotte 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 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 Charlotte 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 proce dures, 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 Charlotte Warehouse facility has had no accidental releases of ammonia in the past five years. 6. Emergency Response Program The Charlotte 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 Charlotte Fire Department and Hazardous Materials Response Team, and the Regional Local Emergency Planning Committee. Notification is made locally by dialing 911, and by notifying North Carolina Department of Env ironmental Management at 1-(800) 858-0368. |