Winn-Dixie Atlanta, Inc.-Atlanta Warehouse - Executive Summary |
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EXECUTIVE SUMMARY 1. Corporate Prevention and Emergency Response Approach The Winn-Dixie Stores, Inc. (Winn-Dixie) Atlanta Warehouse Facility (Atlanta Warehouse) is the headquarters for the Atlanta Division of Winn-Dixie located in Atlanta, Georgia. 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 Atlanta Warehouse is located at 5400 Fulton Industrial Boulevard in the southwest corner of the city of Atlanta, Fulton County, Georgia. The facility consists of areas for dry, cooler, and freezer storage of perishable and non-perishable items for distribution to the Winn-Dixie Supe rmarkets. The Atlanta Warehouse has an ammonia refrigeration system that exceeds the 10,000 lb. RMP threshold quantity. The ammonia refrigeration systems equipment is located in the compressor room in the southeast area of the building, except for the high pressure receiver (HPR). The HPR is the largest capacity vessel in the ammonia refrigeration system capable of holding approximately 4,590 lbs. of ammonia. The HPR is located outside of the warehouse next to the southeast property boundary. The Atlanta Warehouse facility also has propane on site which exceeds the flammable 10, 000 lb. RMP threshold quantity. The propane is maintained in three above ground storage tanks that each have a capacity of 110,000 gallons. Propane is used as a backup fuel for the facilitys forklifts and in the boiler to heat the facility. The propane storage tanks are located along the southeast corner of the property border near the railroad tracks. The propane is delivered by truck to the facility . 3. Description of the Worst Case and Alternative Release Scenarios The Worst Case release scenario for ammonia is the rupture of the HPR, releasing 4,590 lbs. of ammonia gas over a ten minute period. Under worst case weather conditions, the ammonia gas could travel 0.8 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 alternative-case release scenario was characterized by a leak rate of 1,074.4 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, taking into consideration the automatic pressure cutoff system at the facility, 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. The Worst Case release scenario fo r propane is the failure of the storage tank when filled to the greatest amount which would release 110,000 lbs. of propane. It is assumed that the entire contents are released as vapor which finds an ignition source, 10% of the released quantity is assumed to participate in the resulting explosion. The distance to the endpoint of 1 psi for the worst case analysis is 0.40 miles using the OCA Guidance. The Alternative-Case release scenario for propane is an accident during truck filling of the propane storage tank. Failure of the 2-inch diameter process pipe happens due to truck driver error. The resulting unconfined vapor cloud travels to the lower flammability limit. The distance to the endpoint for the lower flammability limit for the alternative scenario is less than 0.1 miles (528 feet), using the OCA Guidance. This release has the possibility of extending beyond the facility boundary since the storage tank is next to the property boundarys fence line. 4. Prevention Progr am Prevention Program 2 The facility exceeds the flammable threshold quanity for its propane system and is therefore subject to the RMP requirements. This places the propane process in the program 2 level. The facility will address the required Program 2 Prevention Program for the propane process by expanding its PSM program for the applicable seven elements. The seven elements of the Prevention Program 2 are Process Hazard Review, Process Safety Information,Prevention Maintenance Program,Operating Procedures, Incident Investigation, compliance audits, and Safety Training. Prevention Program 3 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. The facility also exceeds the flammable threshold quantity for its propane system and is therefore subject to the RMP requirements. For RMP compliance purposes, this places the Atlanta Warehouse facilitys refrigeration process in the Program 3 level. Atlanta Warehouse will use its PSM program as the required Program 3 Prevention Program for ammonia. The Atlanta Warehouse facility has a program in place to comply with the OSHA Process Safety Management Standard, 29 CFR 1910.119. The PSM Program was reengineered 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, Atlanta Warehouse also developed written operating procedures for the refrigeration processes. 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 Atlanta 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 Atlanta Warehouse facility has had no accidental releases of ammonia or propane in the past five years. 6. Emergency Response Program The Atlanta 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 Fulton County Fire Department and Hazardous Materials Response Team, and the State Emergency Response Commission. Notifica tion is made locally by dialing 911, and by notifying the Georgia State Warning Point at (800) 241-4113 or (404) 656-6905. |