London International Group, LLC-Eufaula - Executive Summary |
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London International Group, LLC - Eufaula Manufacturing Executive Summary 1. Accidental release prevention and emergency response policies The facility uses aqueous ammonia (ammonium hydroxide) which is considered hazardous by EPA. The facility also utilizes Liquid Propane Gas (LPG) which is considered a flammble substance by EPA. The same properties that make aqueous ammonia and LPG valuable as a commodity also make it necessary to observe certain safety precautions during handling to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as that of our co-workers, and to reduce the threat to nearby members of the community. It is our policy to adhere to all applicable Federal and state rules and regulations. Safety depends upon the manner in which we handle aqueous ammonia and LPG, the safety devices inherent in the design of this facility, the safe handling procedures that we use, and the training of our personnel. The emergency response plan includes procedures for notification of the local fire authority and notification of any potential affected neighbors. 2. The stationary source and regulated substances handled One 6,400 gallon aqueous ammonia tanks is utilized in the condom manufacturing process. The tank is filled periodically from an outside vendor. One 18,280 gallon LPG tank is located onsite. LPG is used as a backup fuel for firing production ovens. Access to the site is restricted to authorized facility employees, authorized management personnel and authorized contractors. The regulate substances handled at this facility are aqueous ammonia and LPG. The total inventory of aqueous ammonia stored at this plant is 48,096 pounds. The total inventory of LPG stored at this plant is 110,000 pounds. 3. The worst-case release scenario(s) and the alternative release scenario(s), including administrative control and mitigation measures to limit the distance for each reported scenario AQUEOUS AMMONIA 30% Worst-Case Scenario - A catastrophic rupture of the ammonia tank would release 48,096 pounds of aqueous ammonia. It is assumed that the entire contents are released as liquid. The distance to the endpoint of 0.14 mg/l is 0.10 miles. This has the potential to extend past the facility's boundary. Alternative Release Scenario - A six square inch rupture occurs in the transfer hose. The release occurs in a diked area inside the building. There is a liquid release. The distance to the endpoint of 0.14 mg/l is 0.1 miles. This release does not have the potential to extend past the facility's boundary. LIQUIFIED PROPANE GAS (LPG) Worst-Case Scenario - A vapor cloud explosion of the LPG tank would release 110,000 pounds of LPG. It is assumed that the entire contents are released as vapor. The distance to the endpoint of 2.1 % LFL is 0.30 miles. This has the potential to extend past the facility's boundary. Alternative Release Scenario - A three square inch rupture occurs in the liquid space of the tank. The release results in a vapor cloud fire. The height of the column above the leak is 48 inches. The distance to the endpoint of 2.1 % LFL is 0.10 miles. This release does not have the potential to extend past the facility's boundary. 4. The general accidental release prevention program and the specific prevention steps This distribution facility complies with EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations. Routine maintenance and component checks will be performed monthly to insure safety and performance of the system. 5. Five-year accident history There has been no accidental releases of aqueous ammonia or LPG within the past five years. 6. The emergency response program In the event of a spill of aqueous ammonia or LPG, the following action will be taken: 1. Alert the main office, plant, fire department, police department, and all local emergency response agencies and teams. 2. Alert all em ployees and check all departments for fire, injuries or unsafe conditions. 3. Avoid inhalation of fumes or vapors released. 4. Supervisors and foremen to keep employees orderly and guided out of harms way. 5. Mr. William Klienhoff will give direction and assistance to employees. They will answer questions from local authorities and assist in any effort to control or manage the catastrophe. 6. Fire extinguishers are located in all departments to put out small fires. A sprinkler system is located throughout the manufacturing and warehousing facility. 7. If an evacuation of the plant is deemed necessary, employees will be escorted to the front parking lot for assembly, kept together and there await further instruction. 8. Care should be taken to see that the injured are taken care of and medical attention given at the earliest possible moment. Emergency numbers are as follows: Eufaula Fire Department ...................... 911 or (334)687-1200 Eufaula Police Departme nt .................. 911 or (334)687-1200 LEPC Local Emergency Planning Commission ................. (334)687-1521 |