Ketchikan - Executive Summary |
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This is to inform all interested persons, including employees that Alaska General Seafoods is complying with OSHA's Process Safety Management Standard (called Process Safety Management or PSM), Title 29 Code of Federal Regulations (CFR) 1910.119, and EPA's Risk Management Program regulations (called RM Program), Title 40 CFR Part 68, to deal with the risks involved with the storage, handling, and processing of hazardous chemicals. In this way we promote overall plant, worker, and public safety. These programs enable our facility to prevent the occurrence, and minimize the consequences, of significant releases of toxic substances as well as fires, explosions, and other types of catastrophic accidents. Overall, these programs prevent accidental fatalities, injuries and illnesses and avoid physical property damage. Our safety programs are applied to any activity involving hazardous chemicals including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. Any group of vessels which are interconnected and separate vessels which are located such that a hazardous chemical could be involved in a potential release shall be considered a single process. Our safety programs prevent accidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment. These rules are detailed and improved as necessary. They are also communicated to and accepted by all employees at the facility. This is an old facility with an old ammonia refrigeration system and a new Owner. There are two separate systems on site, one for the main process plant and cold storage facilities and one for the ice house and ice storage system. The total ammonia on site is 14,300 lbs. The accidental release prevention program is based on extensive training and maintenance and past history. The previous refrigeration engineer had incorrectly stated the volume of ammonia conta ined in the system. A new process addition in the winter of 2000 led to the discovery of more ammonia in the system than previously reported and the new calculated volume is above the threshold amount, prompting the completion of an OSHA and EPA compliance manuals. There have not been any releases in the last five years. The worse case scenario was considered to be a rupture of the high pressure receiver. The end point radius is 1.1 miles. The possible rupture is not mitigated by any factors. This system is protected by relief valves which are well maintained making the failure unlikely. The alternate scenario considered was a leak in a high pressure ice house ammonia pipe or high pressure receiver which is a separate system and located at the North edge of the property. The end point radius is 0.1 miles. The catastrophic failure is unlikely because the system is protected by relief valves, a preventative maintenance program and regular inspections. Ammonia is not corrosive to the piping materials. The general accidental release prevention program relies on extensive maintenance, training and standard operating procedures. All areas of the system are protected by relief valves which discharge into the atmosphere. The emergency response program is a two level program that is monitored by ammonia detectors located in the engine room. The first level alarm is a threshold alarm which will notify the refrigeration operator that a threshold amount of ammonia has been detected. The second level alarm (1000 PPM) will kill all power to the machinery room, and begin the emergency ventilation system. There are no planned changes at this time, the administration and maintenance of the program will be undergoing a continual evolution to maintain a smooth operation without any difficulties. The undersigned certifies that to my best knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. At the time of this writing the required training is in progress. The date entered in the electronic submittal is 1-1-00 altho the actual date of completion may be later. Steve Meuter Plant Manger |