Rose Packing Company Inc. - Executive Summary |
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The accidental release prevention and emergency response policies at our facility. It is the company's policy: 7 To continuously perform preventative maintenance on all aspects pertaining to the refrigeration system. The success of this policy is evidenced by the safe operation of the facility since its original construction in 1957. 7 That no vehicles, such as fork lifts, are permitted near ammonia refrigeration components, including piping. Vehicle drivers are trained to use caution wherever refrigeration units are present. 7 That all operators and maintenance personnel must be properly trained before they are permitted to work on, or operate, the refrigeration system. 7 That all key operators and maintenance personnel are required to undergo 24 hour hazardous material training as per OSHA 1910.120 regulations. This is done to insure their ability to participate in the correction or repair of conditions that might result in an accidental release. 7 That every employee, visitor, contractor or truck driver is informed of the safety aspects of the facility. Description of our facility and the regulated substances handled, including how and why we use ammonia. Refrigeration is an essential component of the health and safety in everyday life of the consumer, who uses it to prevent spoilage. In the same way, our company employs refrigerated working areas where our meat products are prepared. Our building is basically a large refrigerator/freezer used to keep food fresh while it is being processed, or stored awaiting shipment. Anhydrous ammonia is utilized as the essential refrigerant in the cooling system. Unlike the now-banned or restricted chlorofluorocarbons (CFCs such as certain Freons and Genetrons), ammonia is not an environmental ozone depleter. When in the environment, it readily enters the natural nitrogen cycle, supplying fixed nitrogen to plants, which in turn use it as an essential growth nutrient. In addition, ammonia is a highl y efficient refrigerant. This translates to lower energy costs, thereby resulting in a savings to the consumer, less dependence upon foreign energy imports, as well as less production of public-utility-generated greenhouse gases. Description of the "worst-case release scenario" and the "alternative release scenario", including administrative controls and mitigation measures to limit the distances for each reported scenario. We used the EPA-supplied RMP-Comp software package to perform the release scenario calculations. As part of our modeling, we have assumed that the building structure will act in the capacity of passive mitigation, to decrease the rate of release to the environment. We have performed a "worst case scenario" calculation for a release from a ruptured storage vessel that could potentially hold 938 cubic feet of ammonia. However, it is our normal operating policy to keep this vessel filled to only about 19 to 31% of capacity. From our calculations we have co ncluded that there would be offsite consequences to the neighboring community in the event of an ammonia release. However, due to our continuous inspection and maintenance procedures, we feel such a release is extremely unlikely. We have also performed "alternative release scenario" calculations. The alternative release we have presented would be if a fork lift completely broke one of the major lines in the system. In this instance the effect on the surrounding location would be drastically less than in the worst case scenario described above. This is even assuming no active mitigation devices. However, our protection systems and devices in the refrigeration system make off-site impact even less likely. General accidental release prevention program and prevention steps relating to the ammonia refrigeration system. Preventative maintenance has been the hallmark of the safety program at our facility. We have daily walk-throughs by experienced and trained maintenance perso nnel. Our five maintenance personnel have a total of 42 years of safe operation of refrigeration systems between them. Our facility strives to comply with the OSHA PSM program. The aspects of the program include: PROCESS SAFETY INFORMATION, including hazard, technology, and equipment information on ammonia refrigeration. EMPLOYEE INVOLVEMENT, including providing employees and their representatives access to our PSM records. PROCESS HAZARD ANALYSIS OPERATING PROCEDURES, including clear instructions for safely conducting activities involving our system and safe work practices. TRAINING, especially in safety aspects and refresher courses. CONTRACTORS, especially assuring that we use knowledgeable, trained experts that follow safety rules of the facility. PRE-STARTUP SAFETY REVIEW, confirming in a safety review that chages to our system are properly designe and installed correctly. MECHANICAL INTEGRITY, including procedures to maintain the ongoing integrity of our ref rigeration equipment. HOT WORK PERMITS. MANAGEMENT OF CHANGE, including informing and training affected employees on the changes prior to start-up. INCIDENT INVESTIGATION, including all incidents relating to our refrigeration system that have the potential for injury. EMERGENCY PLANNING AND RESPONSE, including development and implementation of an emergency action plan. COMPLIANCE AUDITS, on a regular basis. Our refrigeration system has extensive control and safety devices that act to insure efficient and safe operation. For example we have multiple back-up alarms for our level controllers in our storage tanks. We also have a mechanical controller to act in concert with the electronic controls. Five year accident history relating to the ammonia refrigeration system. In the past five years we have not had a single minor or major incident concerning ammonia. There has been in no lost time to the employee or to others. Emergency response program. We have a safety program that involves all employees at our facility. Operators and maintenance personnel are trained in how to properly make investigations under potentially hazardous circumstances, inspect equipment, and maintain safe working conditions. Operators and maintenance personnel, as well as our management and security personnel, have all been trained in what steps to take in an emergency situation and who to call. Our program utilizes the Mabis 10 Haz Mat team, as well as the Haz Mat responders from the company which installed the equipment, in all situations where a response is required. A number of our operators and maintenance personnel are trained to participate in a Haz Mat response. Planned changes to improve safety. 7 We our continuing our annual Haz Mat Responder Training for key operators and maintenance personnel. 7 We continue to have on-the-job-training. 7 We stay aware of the current technologies for safe and efficient operation of our system and work to apply t hem to our site. 7 We have an on-going effort to convert our automatic controllers to a computerized control system. This will further improve safety by allowing off-site control of our refrigeration system equipment. 7 Over the years we have re-built our system to move all piping into locations that are easily accessible from the roof, eliminating the need to enter room where suspected leaks may have occurred. Evaporators have been moved to recessed locations to make it nearly impossible for there to be inadvertent contact with moving vehicles. |