M. Caratan, Inc. - Executive Summary
I. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY POLICIES |
M. Caratan, Inc. 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 M. Caratan, Inc. 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 M. Caratan Inc. 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.
M. Caratan, Inc. believes that Employee participation is the key to a successful program. Operating level employees, particularly the Refrigeration Operator, has been deeplly involved in all
aspects of the development and implementation of the M. Caratan, Inc. PSM/RMP program he has voluntarily assumed major responsibility for operating the M. Caratan, Inc. facility safely.
The M. Caratan, Inc. Emergency Response Program has been developed with the complete cooperation and support of the Delano Fire Department. All M. Caratan, Inc. employees have received documented emergency response training.
II. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED
M. Caratan, Inc. grows, processes, stores and ships table grapes to a wide market area.
The refrigeration system contains no more than 65,000 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 65000 Pounds of ammonia over a 10 minute per
iod was considered.
Under worst case weather conditions ammonia could travel up to 3.1 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 13000 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 .3 mile before dispersing.
This release is very, very unlikely to occur during the life of the M. Caratan, Inc. 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 mi
le before dispersing
This release is very unlikely to occr during the life of the M. Caratan, Inc. facility.
IV. DESCRIPTION OF THE M. CARATAN, INC. COLD STORAGE CO. ACCIDENTAL RELEASE PREVENTION PROGRAM
M. Caratan, Inc. conducts an annual training and response exercise with the Delano Fire Department to practice, train and update the Emergency Response Program
M. Caratan, Inc. conducts an annual PSM/RMP implementation progress audit of the entire PSM/RMP program to identify strengths and weaknesses and make improvements. M. Caratan, Inc. considers the PSM/RMP manuals to be "living" documents that must be updated and revised regularly to maintain their viability.
M. Caratn, Inc. emphasizes and insists on "employee participation" from the refrigeration system operator in all aspects of the developent, implementation, and integration of their PSM/RMP program.
M. Caratan, Inc. provides a comprehensive, computer based, user friendly training program with "o
ne-on-one" teacher involvement in specific training modules for each ammonia refrigeration employee.
M. Caratan, Inc. 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 Fire Department.
VII. PLANNED CHANGES TO IMPROVE SAFETY
M. Caratan recognizes that even though their Ammonia 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".
M. Caratan, Inc. 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 Operator 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) M. Caratan, Inc. will complete the "Integration" of the following features into their PSM/RMP Program: (a) computer based system that is user friendly. (b) "One-on-one" involvement with specified and qualified trainers. (C) A Program written to minimize paperwork and maximize documentation; and, (e) A program written to be understood and used by the Refrige
ration System Operators.
(3) All recommendations developed during the HAZOP were designed to improve the safety performance of the M. Caratan, Inc. Ammonia Refrigeration Process. M. Caratan, Inc. 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.