Amerifreeze Cold Storage - Executive Summary

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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY POLICIES 
 
   Amerifreeze 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 Amerifreeze RMP program assigns and documents the specific responsibilities for developing, implementing and  integrating the  EPA RMP standards into its safety program.  The Amerifreeze RMP program focuses attention on "managing risks as an integral part and key to the way we manage our ammonia based refrigeration system" rather than a project we expect to complete and put on the shelf when the filing date has passed. 
 
    Amerifreeze Cold Storage believes that Employee participation is the key to a successful program.  Operating level employees, particularly the Ammonia Refrigeration Contractors and the Contra 
cted Refrigeration System Operators, have been deeplly involved and they assume the major responsibility for operating the Amerifreeze facility safely. 
 
    The Amerifreeze Emergency Response Program is being developed with complete cooperation and support from the Allegheny County Emergency Management Team.  All Ammonia Refrigeration System Operators have received documented emergency response training. 
 
 
II.  STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED 
 
    Amerifreeze Cold Storage is a Public Refrigerated Warehouse. 
    The refrigeration system contains no more than 14,000 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 14000 pounds of ammonia over a 10 minute period was considered. 
    Under worst case weat 
her conditions ammonia could travel up to 1.6 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 2800 pound ammonia vapor loss from failure of a psv to reseat or from ruptured vapor piping.  
    Under worst case weather conditions ammonia could travel up to 0.3 mile before dispersing. 
    This release is very, very unlikely to occur during the life of the Amerifreeze 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 0.1 mile before dispersing 
    This release is very unl 
ikely to occr during the life of the Amerifreeze facility. 
 
 
IV.   DESCRIPTION OF THE AMERIFREEZE ACCIDENTAL RELEASE PREVENTION PROGRAM 
 
    Amerifreeze has established a service contract with  Allegheny County Emergency Management which includes an annual employee training and response exercise  to practice, train and update the Amerifreeze Emergency Response Program. 
 
   Amerifreeze conducts an annual PSM/RMP implementation progress audit of the entire PSM/RMP prograr to identify strengths and weaknesses and make improvements.  Amerifreeze considers the PSM/RMP manuals to be active documents that must be updated and revised regularly to maintain their viability. 
 
    Amerifreeze emphasizes and insists on  "employee participation" from the contracted refrigeration system operators in all aspects of the developent, implementation, and integration of their PSM/RMP program. 
 
    Amerifreeze maintains a pro-active "open-door" policy toward neighbors and concerned community citizens.   
Facility tours and risk management discussions are 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 since operations began at Amerfireeze. 
 
VI.  Emergency Response Program 
 
    Contracted facility employees have been trained to respond defensively to an 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 Local Emergency Response Unitt. 
 
VII.  PLANNED CHANGES TO IMPROVE SAFETY 
 
    Amerifreeze 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 active documents and procedures tha 
t will require constant attention, development, and revision before "Safety" becomes becomes second nature. 
 
    Amerifreeze 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 Contractors have 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 Amerifreeze Cold Storage Co.will complete the "Integration" of the following features into their RMP Program: (a) includes "one-on-one" involvement with specified and qualified trainers,  (b) written to minimize redundancies in paperwork and maximize documentation, and   (c) written to be understood and used by the Refrigeration System Operators.  
 
         (3)   All recommendations developed during the PHA were designed to improve the safety performance of the 
Amerifreeze Cold Storage Co. Ammonia Refrigeration Process.  Amerifreeze 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.
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