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Schwan's has historically placed a high priority on chemical 
safety. The corporate environmental compliance manager has been  
assigned overall responsibility for chemical safety in general and  
for ammonia refrigeration safety in particular since 1991.  
Schwan's maintains 3 - shift coverage of emergency responders  
trained to the 24-hour technician level at all facilities with  
ammonia refrigeration systems covered by this rule. 
The Pasadena, TX facility manufactures frozen egg rolls. Anhydrous  
ammonia is used in the refrigeration system at this facility.  
Ammonia is the most efficient and environmentally compatible  
refrigerant available. Although it is toxic at high concentration  
and is an irritating gas, it is not a cumulative metabolic poison,  
does not cause cancer or other dread diseases and does not cause  
lasting environmental damage. The refrigeration system at this  
facility contains about 45,000 pounds of ammonia. 
Schwan's calculates ammonia worst case release scenarios  
using the  
Model RMP for Ammonia Refrigeration, May 1996. All Schwan's  
manufacturing facilities are located in areas that meet the  
definition of "urban". Schwan's has chosen to calculate worst case  
release poundage for the largest high-pressure receiver in the  
system, filled to full calculated hydraulic capacity. Reduced  
volume for administrative controls was not used, since the  
described scenario would probably occur only as a result of a  
catastrophic vessel rupture caused by a total filling of the  
vessel, closure of all vessel block valves, failure of all  
pressure relief valves, with a simultaneous increase in liquid  
temperature sufficient to overpressure the vessel to the point of  
It is the professional judgement of Schwans Environmental Health  
and Safety Department that a release rate of 400 lb./min. should  
be used as an alternate case scenario in lieu of the 100 lb./min.  
rate suggested in the Model RMP. 
The "urban" site condition will be used. 
Based on t 
he above, the worst-case ammonia release scenario for  
the Pasadena, TX facility will be 14,700 pounds released over a  
10-minute period. The alternate case will be a release rate of 400  
pounds per minute. Both scenarios have off-site impacts. 
The ammonia refrigeration system is covered by the OSHA Process  
Safety Management (PSM) rule, 29 CFR 1910.119. 
The Pasadena, TX facility maintains a 3-shift emergency response  
team, trained at the 24-hour technician level. The team numbers 20  
members. The training is conducted by the Vendor. The training is  
designed with a heavy emphasis on ammonia safety, mechanical  
isolation, personal protective equipment up to use of Level `A'  
suits and interaction with an incident command system (ICS).  
Copies of emergency plans are filed with the Fire Department and  
annual facility walkthroughs are conducted with Fire Officers.  
Preplanned command posts and staging areas have been designated  
and Incident Command transfer and liaison functions have 
established. A post-incident debriefing is conducted after each  
Since a continuous improvement philosophy is deeply imbedded in  
the Schwan's corporate culture, improvements in system safety are  
implemented as a result of employee-based Total Quality Management  
(TQM) teams, a designated PSM team and as a result of system  
engineering modifications and extensions. Post incident  
debriefings and incident investigations are used to identify  
additional improvements to system safety.
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