CS Integrated LLC - Executive Summary |
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I. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY POLICIES CS Integrated, LLC 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 CS Integrated 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 CS Integrated 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. CS Integrated believes that Employee participation is the key to a successful program. Operating level employees, particularly the Chief Refrigeration Engineer, has been deeplly involved and h e assumes the major responsibility for operating the Santa Fe Springs facility safely. The CS Integrated Emergency Response Program has been developed with the complete cooperation and support of the Sata Fe Springs Fire Department. All CS Integrated employees have received documented emergency response training. II. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED CS Integrated, LLC is a Public Refrigerated Warehouse. The refrigeration system contains no more than 20,000 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 Receiver. A maximum release of 17287 Pounds of ammonia over a 10 minute period was considered. Under worst case weather conditions ammonia could travel up to 1.2 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 3400 pound ammonia vapor loss from failure of a psv to reseat or from leaking 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 CS Integrated 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 the life of the CS Integrated facility. IV. DESCRIPTION OF THE CS INTEGRATED ACCIDENTAL RELEASE PREVENTION PROGRAM CS Integrated conducts an annual training and response exercise with the Santa Fe Springs Fire Department to practice, train and update the CS Integrated Emergency Response Program CS Integrated conducts an annual PSM/RMP implementation progress audit of the entire PSM/RMP program to identify strengths and weaknesses and make improvements. CS Integrated considers the PSM/RMP manuals to be "living" documents that must be updated and revised regularly to maintain their viability. CS Integrated 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. CS Integrated provides a comprehensive, computer based, user friendly training program with "one-on-one" teacher involvement in specific training modules for each ammonia refrigeration employee. CS Integrated maintains a pro-active "o pen-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 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. VI. EMERGENCY RESPONSE PROGRAM Facility employees have been trained to respond to accidental ammonia releases. The site emergency plan has been coordinated with the community emergency plan under the jurisdiction of the Local Emergency Planning Commission (LEPC) and the Santa Fe Springs Fire Department. VII. PLANNED CHANGES TO IMPROVE SAFETY CS Integrated 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 "living" d ocuments and procedures that will require constant attention, development, and revision before "Safety" becomes "second nature". CS Integrated 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 Chief Refrigeration Engineer has 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 CS Integrated 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 Chief Refrigeration Engineer. (3) All recommendations developed during the HAZOP were designed to improve the safety performance of the CS Integrated Ammonia Ref rigeration Process. CS Integrated 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. |