Coldwater Seafood Corporation - Executive Summary |
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Executive Summary: Risk Management Plan submission for Coldwater Seafood, Cambridge, MD Coldwater Seafood and its parent company, Icelandic Freezing Plants, operate a facility in Cambridge, MD which produces a variety of frozen seafood products under the Icelandic brand name as well as many private labels. Frozen fish, harvested from the North Atlantic for the most part, arrives in bulk from other locations. The fish is cut and formed into various products (fish sticks, filets, etc.), breaded, seasoned, cooked, and then quickly frozen to maintain its quality and safety. After packaging, the product is stored in our refrigerated warehouse facility until shipped to the customer. Most large refrigerated facilities use a chemical called anhydrous ammonia as a vital part of the refrigeration system. Ammonia performs the same functions as the hydrochlorofluorocarbon - "Freon" refrigerants used in home air conditioners, refrigerators, automobiles, etc. Ammonia is the most environmentall y friendly, energy- and capital-efficient refrigerant available for industrial applications; "Freons" are not suitable for many industrial uses. Anhydrous ammonia is also used widely as a fertilizer, both for direct injection into the ground and for manufacture of other fertilizers. Because of its moderate toxicity and slight flammability, it is considered a hazardous material. Coldwater is committed to maintaining a safe manufacturing operation for our employees and the surrounding community. This commitment includes the ammonia refrigeration system. To further safety in our facility, the refrigeration system is constructed under permit from local authorities, such as the building and fire departments. Additionally, we adhere where appropriate to industry-consensus codes and standards, including the ASHRAE Safety Code for Refrigeration and the IIAR-2 standard of the International Institute of Ammonia Refrigeration. Finally, to comply with requirements of the Maryland Occupation al Safety and Health Administration and the United States Environmental Protection Agency, we implement a method called Process Safety Management to ensure that the refrigeration system is operated and maintained safely. We use a variety of methods to ensure that accidental releases of hazardous materials are prevented to the greatest extent possible. In addition to professional design and installation to accepted engineering standards, our Process Safety Management program includes elements addressing: 7 Employee Participation: We involve our employees at all appropriate points in our program. 7 Process Safety Information: We maintain information relating to the safety of ammonia and the design limits of the refrigeration system so that our employees are fully informed. 7 Process Hazards Analysis: We conduct detailed studies of our refrigeration system and some major modifications to identify the important hazards and safeguards. 7 Operating Procedures: We provide written operating procedures to help our staff stay within the safe operating limits of the refrigeration equipment. 7 Mechanical Integrity (Maintenance and Quality Control): We use a comprehensive program of inspections and preventive maintenance to keep mechanical failures from occurring. 7 Training: We train our mechanics in safe operation and maintenance of the refrigeration system. 7 Management of Change: Alterations to the refrigeration system are screened to verify that they are within the original safe design limits. 7 Pre-Startup Safety Review: For certain types of major changes, we conduct a formal safety review before startup to ensure that the new equipment has been designed and installed properly. 7 Contractors: We carefully screen contractors who work on our property to ensure that they have a safe work record. 7 Hot Work Permits: We strictly control welding and other work that could start a fire near the ammonia equipment. 7 Emergency Response: Should a serious incident occur, we maintain our own emergency response program, coordinated with the Cambridge Fire Department. 7 Incident Investigation: After an incident, we investigate to determine the causes and any suitable actions to address them. 7 Compliance Audits: Approximately every three years, we examine the safety program in detail to identify areas for improvement. 7 Trade Secrets: OSHA and EPA require us to maintain a trade secrets program in case confidential information affecting the safety of the ammonia refrigeration system is ever found. 7 Management System: An overall management system monitors the ongoing progress of safety items. As required by the EPA, we have analyzed "worst-case" and "alternative" hypothetical ammonia release scenarios and their consequences, details of which appear in other portions of this Risk Management Plan. The methodology used to evaluate these accidents is prescribed by regulation, and makes no effort to estimate the likelihood or "risk" of these incidents. Coldwater Seaf ood uses other methods to develop plausible scenarios for emergency planning and response drills. The "worst-case" release scenario involves loss of the contents of a high-pressure receiver vessel over ten minutes. As required, this scenario has offsite impact, meaning that a level of 200 ppm ammonia is reached beyond the property line. There is a vessel inside the facility larger than the outdoor receiver, so this "worst-case" scenario is not the largest amount in a vessel on-site. Due to the indoor location and highly-refrigerated liquid the larger vessel contains, the distance to the 200 ppm level is shorter, so that vessel is not considered the "worst-case." The alternative scenario involves lifting of a relief valve, a safety device provided on all vessels to prevent accidents such as the one specified as the "worst-case." The alternative scenario also has offsite impact. We estimated that the release would end after ten minutes, a plausible value considering the controls we have in place to detect relief valve releases and considering the normal behavior of ammonia in vessels. We used a high-quality commercial computer model (PHAST Professional) to estimate the offsite impacts. (See the Risk Management Plan, available from the Environmental Protection Agency, for details on the offsite impacts; due to National Security concerns, the U.S. Government has advised the regulated community not to disclose the actual numerical data in this Executive Summary.) There have been three accidental releases of ammonia in the past five years; the largest release was approximately 5,000 lbs. There were no injuries from the incidents, but community emergency response officials performed precautionary evacuations in the near neighborhood for some. All releases came from safety relief valves, which are vital safety devices designed to release small amounts of material in order to prevent serious accidents. As removing the relief valves is imprudent and illegal, we tightened procedures and installed detection/mitigation controls for the highest-risk areas. The choice of "alternative" scenario was in part based on this experience. Coldwater Seafood has an Emergency Response Plan, coordinated with local emergency response and management agencies, to ensure that the facility is properly prepared and equipped to respond to a fire or an unplanned discharge of ammonia (or other hazardous substance). The plan addresses the action that will be taken and describes the various elements that are critical to ensure the safety of individuals in and around the facility. The plan includes elements such as: - Overview - Facility Description - Emergency Response Organization - Emergency Response Procedures - Notification Procedures - Evacuation Procedures - Mitigation Scenarios and Procedures - Incident Termination - Emergency Preparedness and Planning - Appendices Through our Process Safety Management program, we systematically look for possible system c hanges to improve safety in our facility. Because our program has been in operation for some time, the frequency of such changes is low. At time of writing, there are no important changes planned for safety reasons. As changes are made (or as process hazards analysis studies are updated - which we do on a regular schedule), safety issues and improvements are identified and made as a matter of course. Our adherence to accepted codes and standards drastically reduces the number of safety issues in a change; safety is designed in rather than added later. |