CS Integrated Hatfield - Executive Summary |
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CS INTEGRATED LLC Hatfield EXECUTIVE SUMMARY OF THE EPA RISK MANAGEMENT PLAN CS Integrated Management has elected to implement the requirements of the Risk Management Plan at all locations in order to operate each facility in accordance with regulations and support of best industry standards. The ultimate objective is to minimize the risk of an accidental ammonia release. The facility management has developed an Emergency Response Plan along with training to ensure a fast and efficient response in the event of an accidental hazardous material release, fire or other emergency situation. In order to prevent a potential accidental ammonia release at any CS Integrated facilities, the Company has an ongoing review process for design and operating procedures. This assists in ensuring the refrigeration systems comply with OSHA, EPA and all other local, state and federal regulatory agency safety standards, as well as its own internal standards. CS Integrated has a rigorous emergenc y response training program that follows the guidelines of federal, state and local regulatory agencies. The management believes that cooperative emergency response training must include company employees, local emergency responders and regulatory agency people in order to provide a safe workplace and a safe environment. In an emergency, all personnel are trained to cooperate with fellow employees and other support personnel as directed by the Emergency Response Incident Commander. CS Integrated Hatfield is a refrigerated warehousing facility. The large majority of products stored are refrigerated foods for human consumption and inherently pose no known environmental or safety risks. Ammonia, a regulated substance, is the commonly used refrigerant in industrial grade refrigeration systems that maintain low storage temperatures and can be safely managed by trained operators. The ammonia refrigeration process functions within a closed piping network serving the facility operations. The refrigeration system in this facility contains approximately 37000 pounds of ammonia inventory for this process. In accordance with the EPA's requirements, various accidental release scenarios are performed in order to develop a radius of potential impact around the facility. The primary purpose of this is to assist the local Emergency Planning Commission with additional information if an accidental release was to occur. The release model used was the EPA supplied RMP *Comp, CS Integrated also uses ALOHA for internal training on release modeling. In the worst case scenario, a pipe at the high pressure receiver liquid outlet is broken allowing the entire liquid ammonia charge of that receiver to be released in ten minutes. -2- Based on the RMP *Comp models, this scenario could have a potential offsite area of concern extending to a radius of 1.2 miles. In an alternate scenario, a relief valve opens from some process upset and allows a ten minute release of ammonia gas fr om the high pressure receiver. Based on the RMP *Comp model, this scenario could present a potential offsite area of concern extending to a radius of .1 miles. These release scenario plans are maintained at the site and are used for training and provide information for Responders and for the LOCAL EMERGENCY PLANNING COMMITTEE. CS Integrated is committed to safe management and operation of the closed Ammonia Refrigeration System. Maintenance employees are trained to observe operational procedures designed to be as fail-safe as possible to prevent accidental release of ammonia at any time. Should any accidental release occur, all maintenance employees are certified Emergency Hazardous Material Responders and are required to observe safe emergency response procedures. They are trained to work in conjunction with the local Emergency Planning Commission to minimize the impact of any accidental releases. As part of CS Integrated's safety programs, we have adopted the OSHA Process Saf ety Management Plan as an integral part of our base safety manual. The OSHA PSM Program has been implemented and covers the entire scope of safe operation procedures of the ammonia refrigeration system from start-up and normal operations to potential emergency response operations and subsequent clean-up and restoration of systems. Normal operations rely on the following: X The Maintenance Management Procedures are used to perform preventative maintenance and to maintain records of all maintenance work performed. This helps to ensure that the closed ammonia system continues to work safely, reliably and efficiently in the originally intended manner. X Any set specifications of systems temperature, pressure, level or power interruption, that are exceeded or violated will normally trigger an alarm and safety shutdown. Maintenance technicians are notified of a deviation from normal operational specifications through indicator or alarm systems. X In the event of deviations, t echnicians are trained to analyze the situation, follow personal safety procedures at all times, determine that everything is under control and correct problems and/or deviations. X If a problem cannot be corrected immediately, the equipment needing repair service will be safely locked out of service until such time as repairs have been completed. -3- X If a problem cannot be safely handled by the Maintenance Personnel, procedures are in place to obtain the required resources to correct the situation. During the past five years there were no accidental releases at this facility. EMERGENCY RESPONSE OPERATIONS READINESS INCLUDES THE THE FOLLOWNG PROGRAMS: X Written procedures for emergency operations include emergency evacuation procedures, emergency shutdown instructions, emergency response training expectations, emergency response unit coordination plans, regulatory agency notification and other pertinent information. X The Emergency Response Plan is for managi ng emergency responses. It identifies response teams, assigns specific emergency tasks to each team, provides emergency contact information and sets up procedures for recovery of information systems. It also provides forms for logging emergency operations from beginning to end of these operations and forms to facilitate a systematic incident investigation and corrective measures to prevent recurrence of a similar incident. X The Emergency Response Training program includes all maintenance employees and local emergency responders. This establishes an effective and informed emergency response team that is familiar with systems and potential hazards in each CS Integrated facility. It is the intent of CS Integrated to not only meet any regulatory requirement, but also take a pro-active approach into implementing these requirements as part of a working safety plan. CS Integrated is in a constant review process of its operations and industry standards to provide a safe working e nvironment for our employees, customers and neighbors. |