National Cold Storage Co. - Executive Summary |
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I. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY POLICIES National Cold Storage 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 National Cold Storage 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 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. National Cold Sorage believes that Employee participation is the key to a successful program. Operating level employees, particularly the Tri-Com Service Manager and the Refrigeration System Opera tors, have been deeplly involved in implementing the PSM/RMP Program and they assume the major responsibility for operating the Los Angeles facility safely. The National Cold Storage Emergency Response Program is being developed with the cooperation and support of the Los Angeles Fire Department. All National cold storage employees have received documented emergency response training. II. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED National Cold Storage processes ducks for the Los Angeles Markets. The refrigeration system contains no more than 18,000 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 6500 pounds of ammonia over a 10 minute period was considered. Under worst case weather cond itions ammonia could travel up to 1.0 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 1300 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 .1 mile before dispersing. This release is very, very unlikely to occur during the life of the 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 to occr during t he life of the Fieldbrook facility. IV. DESCRIPTION OF THE NATIONAL COLD STORAGE ACCIDENTAL RELEASE PREVENTION PROGRAM National Cold Storage will conduct an annual training and response exercise with the Los Angeles Fire Department to practice, train and update the Emergency Response Program. National Cold Storage will conduct an annual PSM/RMP implementation progress audit of the entire PSM/RMP program to identify strengths and weaknesses and make improvements. National Cold Storage considers the PSM/RMP manuals to be "living" documents that must be updated and revised regularly to maintain their viability. National Cold Storage 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. National Cold Storage provides a comprehensive, computer based, user friendly training program with "one-on-one" teacher involvement in specific trai ning modules for each ammonia refrigeration employee. National Cold Storage 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 at National Cold Storage Los Angeles facility that resulted in an injury, or that had an off-site impact (evacuation or shelter-in-place), or that resulted in significant property damage either on-site or off-site. An ammonia release considered by National Cold Storage to be very serious occurred in October of 1998 and was the immediate cause for upgrading and improving the National Cold Storage Safety Program. VI. EMERGENCY RESPONSE PROGRAM Facility employees have been trained to respond to accidental ammonia release. The site emergency response plan is being coordinated with the community emergency plan under the jurisdi ction of the Local Fire Department. VII. PLANNED CHANGES TO IMPROVE SAFETY National Cold Storage recognizes that 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. National Cold Storage 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 Tri-Com Service Manager and the Refrigeration System Operators 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 National Cold Storage 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 Ammonia Refrigeration Process. National Cold Storage 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. |