Ashland Cold Storage Company Inc. - Executive Summary |
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The accidental release prevention and emergency response policies at our facility. It is the company's policy: 7 To continuously perform preventative maintenance on all aspects pertaining to the refrigeration system. The success of this policy is evidenced by the safe operation of the facility since its original construction in 1963. 7 That there is no smoking permitted anywhere in the building outside of a single designated smoking area. This keeps fire hazards to a minimum. 7 That no vehicles, such as forklifts, are permitted near ammonia refrigeration components, including piping. Vehicle drivers are trained to use caution wherever refrigeration units are present. 7 That all operators and maintenance personnel must be properly trained before they are permitted to work on, or operate, the refrigeration system. 7 That all operators and maintenance personnel are required to undergo 24 hour hazardous material training as per OSHA 1910.120 regulations. This is done to ins ure their ability to participate in the correction or repair of conditions that might result in an accidental release. 7 That every employee, visitor, contractor or truck driver is informed of the safety aspects of the facility. Description of our facility and the regulated substances handled, including how and why we use ammonia. Our company supplies refrigerated warehousing to companies in the food business. Our building is basically a large refrigerator/freezer used to keep food from spoiling. Refrigeration is an essential component of the health and safety in everyday life of the consumer. Our facility supplies refrigeration services to thousands of food-related businesses to help insure safe storage and shipment of their products. Anhydrous ammonia is utilized as the essential refrigerant in the cooling system. Unlike the now-banned or restricted chlorofluorocarbons (CFCs such as certain Freons and Genetrons), ammonia is not an environmental ozone depleter. When in the environment, it readily enters the natural nitrogen cycle, supplying fixed nitrogen to plants, which in turn use it as an essential growth nutrient. In addition, ammonia is a highly efficient refrigerant. This translates to lower energy costs, thereby resulting in savings to the consumer, less dependence upon foreign energy imports, as well as less production of public-utility-generated greenhouse gases. Description of the "worst-case release scenario" and the "alternative release scenario", including administrative controls and mitigation measures to limit the distances for each reported scenario. We used the EPA-supplied RMP-Comp software package to perform the release scenario calculations. As part of our modeling, we have assumed that the building structure will act in the capacity of passive mitigation, to decrease the rate of release to the environment. We have performed a "worst case scenario" calculation for a release from a ruptured storage vessel that could p otentially hold 423 cubic feet of ammonia. However, it is our normal operating policy to keep this vessel filled to only about 25 to 35% of capacity. From our calculations we have concluded that there would be offsite consequences to the surrounding community in the event of an ammonia release. However, due to our continuous inspection and maintenance procedures, we feel such a release is extremely unlikely. We have also performed "alternative release scenario" calculations. The alternative release we have presented would be if a forklift completely broke one of the major lines in the system. In this instance the effect on the surrounding location would be drastically less than in the worst case scenario described above. This is even assuming no active mitigation devices. However, our protection systems and devices in the refrigeration system make off-site impact even less likely. General accidental release prevention program and prevention steps relating to the ammonia r efrigeration system. Preventative maintenance has been the hallmark of the safety program at our facility. We have daily walk-throughs by experienced and trained maintenance personnel. Our five maintenance personnel have a total of 92 years of safe operation of refrigeration systems between them. Our facility strives to comply with the OSHA PSM program. The aspects of the program include: PROCESS SAFETY INFORMATION, including hazard, technology, and equipment information on ammonia refrigeration. EMPLOYEE INVOLVEMENT, including providing employees and their representatives access to our PSM records. PROCESS HAZARD ANALYSIS OPERATING PROCEDURES, including clear instructions for safely conducting activities involving our system and safe work practices. TRAINING, especially in safety aspects and refresher courses. CONTRACTORS, especially assuring that we use knowledgeable, trained experts that follow safety rules of the facility. PRE-STARTUP SAFETY REVIEW, confirming in a safety review that changes to our system are properly designed and installed correctly. MECHANICAL INTEGRITY, including procedures to maintain the ongoing integrity of our refrigeration equipment. HOT WORK PERMITS. MANAGEMENT OF CHANGE, including informing and training affected employees on the changes prior to start-up. INCIDENT INVESTIGATION, including all incidents relating to our refrigeration system that have the potential for injury. EMERGENCY PLANNING AND RESPONSE, including development and implementation of an emergency action plan. COMPLIANCE AUDITS, on a regular basis. Our refrigeration system has extensive control and safety devices that act to insure efficient and safe operation. For example we have multiple back-ups for our level controller. We also have a mechanical controller to back-up the electronic controls. We have an on-site electric-generating facility capable of supplying all electrical needs for operating 24 hrs/day, 365 days of the y ear. We also have, in addition, an emergency generator that is capable of supplying electricity to essential areas. Five year accident history relating to the ammonia refrigeration system. In the past five years we have only had a single minor incident concerning ammonia. It resulted in no lost time to the employee or to others. We requested that the individual undergo a cautionary medical examination, which indicated no lasting health effects. Emergency response program. We have a safety program that involves all employees at our facility. Operators and maintenance personnel are trained in how to properly investigate under potentially hazardous circumstances, inspect equipment, and maintain safe working conditions. Operators and maintenance personnel, as well as our management and security personnel, have all been trained in what steps to take in an emergency situation and who to call. Our program utilizes the City Haz Mat team, as well as the Haz Mat responders from the company that installed the equipment, in all situations where a response is required. Our operators and maintenance personnel are trained to participate in a Haz Mat response. Planned changes to improve safety. 7 We are have installed a newer, more reliable, state-of-the art generation of ammonia detector (chemically-based) to replace an older version previously in use at our facility. 7 We our continuing our annual Haz Mat Responder Training for all operators and maintenance personnel. 7 We continue to have on-the-job-training. 7 We stay aware of the current technologies for safe and efficient operation of our system and work to apply them to our site. 7 As the newest control technologies become available we plant to evaluate and install as appropriate. 7 We have an on-going effort to convert our automatic controllers to a computerized control system. This will further improve safety by allowing off-site control of our refrigeration system equipment. |