Winn-Dixie Stores, Inc.-Jacksonville Facility - Executive Summary
WINN-DIXIE STORES, INC.- JACKSONVILLE WAREHOUSE AND |
ASTOR PRODUCTS, INC. FACILITIES
RISK MANAGEMENT PLAN
1. Corporate Prevention and Emergency Response Approach
The Winn-Dixie Stores, Inc. (Winn-Dixie) Jacksonville Warehouse Facility is co-located with Astor Products, Inc. and both are adjacent to the corporate headquarters offices of Winn-Dixie Stores, Inc., located in Jacksonville, Duval County, Florida. 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 Jacksonville Warehouse is located at 5050 Edgewood Court in the northwest corner of the city of Jacksonvi
lle, Duval County, Florida. 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 Winn-Dixie Jacksonville Warehouse has an ammonia refrigeration system which exceeds the 10,000 lb. RMP threshold quantity. The ammonia refrigeration systems equipment is located in the southwest area of the property in the machine or compressor room. The high pressure receiver (HPR) or storage vessel is located inside this room. The HPR is the largest capacity vessel in the ammonia refrigeration system capable of holding 14,000 lbs. of ammonia.
The Astor Products, Inc.-Detergent Division which produces Blue Arrow laundry detergent is located at 5244 Edgewood Court within the same fenceline and property boundary as the Jacksonville Warehouse and both are owned and operated by Winn-Dixie. The Astor Products, Inc. facility produces detergent, coffee, and spices for sale in Winn-Dixie food stor
The Detergent Division, Blue Arrow, uses Oleum as a reactant in the sulfonation process to make detergent. Oleum is a toxic substance regulated under the RPM rule. Since the Astor facility stores Oleum in an amount over the RPM threshold quantity of 10,000 pounds, the facility is subject to the RMP rule. The Oleum storage tank capacity is a maximum of 219,800 pounds of Oleum.
3. Description of the Worst Case and Alternative Release Scenarios
Ammonia Refrigeration System
The Worst Case release scenario is the rupture of the HPR vessel, releasing 14,000 lbs. of ammonia gas over a ten minute period. Under worst case weather conditions, the ammonia gas could travel 1.4 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 Document.
The Alternative Release Scenario is characterized by a leak rate of 1,692 lb./min. from the HPR liquid supply line due to pipe connection fail
ure from worker/human error or corrosion of the pipe. Under normally expected weather conditions, the ammonia gas could travel 0.3 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 Document.
The Alternative Release Scenario for Oleum is characterized by a leak rate of 0.37 lb./min. from a liquid line that is assumed to fail, with the chemical feed pump continuing to pump Oleum onto the ground for a maximum duration of 30 minutes. This is an assumed maximum time that it would take to manually shut off the Oleum pump and is designed to be conservative. The Oleum pump operates at a rate of 29 lb/min, and the total quantity of spilled Oleum is, therefore, 870 lbs. Under normally expected weather conditions, taking into consideration the active mitigation to stop the leak, the Oleum could travel 0.10 miles before dispersing enough to no longer pose a hazard to the
public or environment (reaching a concentration less than .01 mg/L) using the OCA Guidance method.
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 Jacksonville Warehouse refrigeration process in the Program 3 level. The Jacksonville Warehouse facility will use its PSM program as the required Program 3 Prevention Program.
The Jacksonville 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 eq
uipment. In developing the PSM Program, the Jacksonville 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 correct
ion 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 Jacksonville 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.
The Astor facility exceeds the toxic threshold quantity for Oleum used in the sulfonation process and is therefore subject to the RMP requirements. For RMP compliance purposes, this places the Astor facilitys Oleum storage process in
the Program 2 level. The Astor facility has addressed the required Program 2 Prevention Program for the Oleum covered process for the applicable seven elements.
5. Accident History
The Jacksonville Warehouse facility has had only one minor accidental release of ammonia in the past five years. This is the only release the facility has ever had that exceeded a reportable quantity. The facility had a small gas leak that occurred over a seventeen day period until discovery. The total amount released is estimated to be approximately 4,000 lbs. of ammonia in the gaseous form. The quantity had escaped over time from a small leak from a thumb-size hole in a condenser coil. The condenser was immediately valved off to stop the flow of ammonia to the system as soon as discovery of the leak. The incident investigation determined that corrosion was the cause of the incident due to moisture in the tower. Also, it was determined by the incident investigation team that necessary chemicals
used in the towers leave a white/green residue on condenser coils making leaks hard to find. Actions taken as a result of this incident is to review remaining coils for the same type of corrosion to ensure integrity and check more thoroughly for leaks around towers.
The Astor facility has had no accidental releases of oleum in the last five years.
6. Emergency Response Program
The Jacksonville Warehouse and the Astor Facilities have 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 Jacksonville Fire Department and Hazardous Materials Response Team, and the Regional Local Emergency Planning Committee. Notification is made locally by dialing 911, and by notifying Florida State Warning Point at (800) 320-0519 or (904) 413-9911.