Henningsen Cold Storage Co. - Executive Summary |
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I. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY POLICIES Henningsen Cold Storage Co. 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 Henningsen Cold Storage Co. 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 Heningsen 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. Henningsen Cold Storage Co. believes that Employee participation is the key to a successful program. Operating level employees, particularly the Refrigeration Engineer, has b een deeplly involved in all aspects of the development and implementation of the Henningsen PSM/RMP program he has voluntarily assumed major responsibility for operating the Forest Grove facility safely. The Henningsen Emergency Response Program has been developed with the complete cooperation and support of the Forest Grove Fire Department. All Henningsen employees have received documented emergency response training. II. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED Henningsen Cold Storage Company 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 A High Pressure Receiver. A maximum release of 17000 Pounds of ammonia over a 10 minute period was c onsidered. Under worst case weather conditions ammonia could travel up to 1.2 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 3400 pound ammonia vapor loss from failure of a psv to reseat or from leaking vapor piping. Unsder worst case weather conditions ammonia could travel up to .1 mile before dispersing. This release is very, very unlikely to occur during the life of the Henningsen 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 disper sing This release is very unlikely to occr during the life of the Henningsen facility. IV. DESCRIPTION OF THE HENNINGSEN COLD STORAGE CO. ACCIDENTAL RELEASE PREVENTION PROGRAM Henningsen Cold Storage Co. conducts an annual training and response exercise with the Forest Grove Fire Department to practice, train and update the Henningsen Emergency Response Program Henningsen Cold Storage Co. conducts an annual PSM/RMP implementation progress audit of the entire PSM/RMP program to identify strengths and weaknesses and make improvements. Henningsen considers the PSM/RMP manuals to be "living" documents that must be updated and revised regularly to maintain their viability. Henningsen Cod Storage Co. 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. Henningsen Cold Storage Co. provides a comprehensive, computer based, user frien dly training program with "one-on-one" teacher involvement in specific training modules for each ammonia refrigeration employee. Henningsen Cold Storage Co. 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 releases. The site emergency plan has been coordinated with the community emergency plan under the jurisdiction of the Local Emergency Planning Commission (LEPC) and the Forest Grove Fire Department. VII. PLANNED CHANGES TO IMPROVE SAFETY Henningsen Cold Storage Co. recognizes that even though their Amm onia release and injury experience has been excellent, their PSM/RMP program will provide much needed improvement 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 "second nature". Henningsen 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. The Refrigeration Engineer has been deeply involved in Verifying the P&ID's, Developing and updating the Standard Operating Procedures, and performing the documented Preventive Maintenance Inspections. (2) The Henningsen Cold Storage Co.will complete the "Integration" of the following features into their PSM/RMP Program: (a) computer based, (b)user friendly, (c) includes "one-on-one" involvement with specified and qualified trainers, (d) written to minimi ze paperwork and maximize documentation, and (e) written to be understood and used by the Refrigeration System Operators. (3) All recommendations developed during the HAZOP were designed to improve the safety performance of the Henningsen Cold Storage Co. Ammonia Refrigeration Process. Henningsen 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. |