Freezer Services of Michigan, LLC - Executive Summary |
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I. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY POLICIES Freezer Services of Michigan, LLC recognizes management's responsibility in protecting it's employees, equipment, property, and the environment. The safety and health of all personnel are very important. The control of accidents has been and will continue to be a basic responsibility of all personnel in the facility. The Freezer Services PSM/RMP program assigns and documents the specific responsibilities for developing, implementing and integrating the OSHA PSM and the EPA RMP standards into its safety program. The Freezer Services PSM/RMP program focuses attention on "Making PSM/RMP the way we manage our ammonia based refrigeration system" rather than a project we expect to complete and put on the shelf when the fileing date has passed. Freezer Services believes that Employee participation is the key to a successful program. Operating level employees, particularly the Chief Refrigeration Engineer and the Refrigeration System Operator, have been deeplly involved and they assume the major responsibility for operating the Hamtramck Michigan facility safely. The Freezer Services Emergency Response Program has been developed with the complete cooperation and support of the Hamtramck Fire Department. All Freezer Services employees have received documented emergency response training. II. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED Freezer Services of Michigan, LLC is a Public Refrigerated Warehouse. The refrigeration system contains no more than 20,000 pounds of Anhydrous Ammonia. Anhydrous Ammonia is the only Hazardous Material on site in quantities above the threshold quantity. III. SUMMARY OF WORST CASE AND ALTERNATIVE RELEASE SCENARIOS The WORST CASE release scenario involves the complete rupture of the High Pressure Receive. A maximum of 15000 pounds of ammonia over a 10 minute period was considered. Under worst case weather conditi ons ammonia could travel up to 1.5 miles before dispersing. A WORST CASE release is very, very, very, unlikely to occur during the life of the facility, this is because of the release prevention and mitigation features incorporated in the PSM/RMP program. An alternative case release scenario that we call WORST CASE CREDIBLE was slightly more likely. A 3000 pound ammonia vapor loss from failure of a psv to reseat or from ruptured vapor piping. Unsder worst case weather conditions ammonia could travel up to .2 mile before dispersing. This release is very, very unlikely to occur during the life of the Freezer Services facility. An alternative case release that we call MOST LIKELY, MOST SEVERE was slightly more likely still. A 100 pound ammonia loss from a failing ammonia transfer hose during the unloading operation. Under worst case weather conditions ammonia could travel up to .1 mile before dispersing This release is very unlikely t o occr during the life of the Freezer Services facility. IV. DESCRIPTION OF THE FREEZER SERVICES ACCIDENTAL RELEASE PREVENTION PROGRAM Freezer Services conducts an annual training and response exercise with the Hamtramck Fire Department to practice, train and update the Freezer Services Emergency Response Program. Freezer Serices conducts an annual PSM/RMP implementation progress audit of the entire PSM/RMP prograr to identify strengths and weaknesses and make improvements. Freezer Services considers the PSM/RMP manuals to be "living" documents that must be updated and revised regularly to maintain their viability. Freezer Services emphasizes and insists on "employee participation" from the refrigeration system operators in all aspects of the developent, implementation, and integration of their PSM/RMP program. Freezer Services provides a comprehensive, computer based, user friendly training program with "one-on-one" teacher involvement in specific trainin g modules for each ammonia refrigeration employee. Freezer Services maintains a pro-active "open-door" policy toward neighbors and concerned community citizens. Facility tours and risk management discussions are scheduled and conducted upon written request. V. FIVE YEAR ACCIDENTAL RELEASE HISTORY There have been no releases of ammonia that resulted in an injury, or that had an off-site impact, or that resulted in significant property damage either on-site or off-site. VI. Emergency Response Program Facility employees have been trained to respond to accidental ammonia release. The site emergency plan has been coordinated with the community emergency plan under the jurisdiction of the Local Emergency Planning Commission (LEPC) and the Hamtramck Fire Department. VII. PLANNED CHANGES TO IMPROVE SAFETY Freezer Services recognizes that (even though their Ammonia release and injury experience has been excellent) their PSM/RMP program will provide much needed i mprovement to their safety effort. The PSM/RMP program is considered to be a set of "living" documents and procedures that will require constant attention, development, and revision before "Safety" becomes becomes second nature. Freezer expects to improve safety performance by emphasizing the following elements of their PSM/RMP Program (1) Employee Participation is the "Key" to a successful program. Both the Chief Refrigeration Engineer and his assistant Refrigeration System Operator are deeply involved in Verifying the P&ID's, Developing and updating the Standard Operating Procedures, and performing the documented Preventive Maintenance Inspections. (2) The Freezer Services PSM/RMP Program is: (a) computer based, (b)user friendly, (c) includes "one-on-one" involvement with specified and qualified trainers, (d) written to minimize paperwork and maximize documentation, and (e) written to be understood and used by the operating level employees. (3) All recommendations developed during the HAZOP were designed to improve the safety performance of the Freezer Services Ammonia Refrigeration Process. Freezer Services expects to evaluate each recommendation in a timely manner and implement, as soon as possible, those recommendations that will reduce the possibility of a release and/or mitigate the consequences of an unintentional release. |