Land-O-Sun Dairies, L.L.C. - Executive Summary |
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RISK MANAGEMENT SUBMISSION STATEMENT Land-O-Sun Dairies 1291 New Cut Road Spartanburg, SC 29308 This is to inform all interested persons, including employees that Land-O-Sun Dairies, Spartanburg, SC is complying with OSHAs Process Safety Management Standard (called Process Safety Management or PSM), Title 29 Code of Federal Regulations (CFR) 1910.119, and EPAs Risk Management Program regulations (called RM Program), Title 40 CFR Part 68, to deal with the risks involved with the storage, handling, and processing of hazardous chemicals. In this way we promote overall plant, worker, and public safety. These programs enable our facility to prevent the occurrence, and minimize the consequences, of significant releases of toxic substances as well as fires, explosions, and other types of catastrophic accidents. Overall, these programs prevent accidental fatalities, injuries and illnesses and avoid physical property damage. Our safety programs are applied to any activity inv olving hazardous chemicals including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. Any group of vessels which are interconnected and separate vessels which are located such that a hazardous chemical could be involved in a potential release shall be considered a single process. Our safety programs prevent accidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment. These rules are detailed and improved as necessary. They are also communicated to and accepted by all employees at the facility. DESCRIPTION OF PROCESS The Spartanburg Facility is an ice cream processing, freezing, and storage facility as well as a fluid milk processing and storage facility. The facility uses ammonia in an industrial refrigeration system to maintain temperatures in milk tanks, coolers, chillers, and freezers. The refrigeration system is al so used to freeze ice cream. Ammonia refrigeration is the only process subject to the Risk Management Legislation. WORST CASE SCENARIO Failure of the high pressure receiver containing 7925 lbs. of ammonia with the receiver quantity limited to 80 % of the vessel capacity by facility procedures resulting in a ten minute release. Under worst-case weather conditions, ammonia could travel 1.6 miles before dispersing enough to no longer pose a hazard to the public. This scenario is unlikely for the following reasons: worst- case weather conditions are uncommon; the vessel is enclosed in a building that would withstand and help to contain such a release; industry standards for the manufacture and quality control of pressure vessels; ammonia is not corrosive in this service; pressure safety valves limit operating pressure in this vessel; the accident prevention program in place at the facility including the mechanical integrity program for regular maintenance, inspection and testing, and replacement of equipment, if necessary; installed ammonia sensors in the system to warn of leaks; alarms and the auto-dialing system in place to warn operating personnel of process upsets; and the emergency response plan and equipment in place at the facility. ALTERNATIVE RELEASE SCENARIOS Failure of = purge line would result in a release of 720 lbs. of ammonia over a time period of sixty minutes. Under common weather conditions, ammonia could travel .1 miles before dispersing enough to no longer pose a hazard to the public. Transfer hose failure was chosen as the alternative release scenario because it is a temporary connection and constructed of materials other than steel. This scenario is unlikely for the following reasons: emergency equipment such as an excess flow valve on the tank truck and valves to isolate the transfer hose; the facility accident prevention program in place at the facility including operating procedures to have personnel present at all times during unloading, and the mechanical integrity program for regular maintenance, inspection and testing, and replacement of equipment, if necessary; and the emergency response plan and equipment in place at the facility. ACCIDENT HISTORY There have been no reportable accidents within the past five years. EMERGENCY RESPONSE PROGRAM This facilitys emergency response program is based on the OSHA requirements for Emergency Action Plans (29 CFR 1910.38 and 1910.119) and HAZWOPER (29 CFR 1910.120). We have trained employees for emergency response and maintain a written emergency response plan. This plan is coordinated with the Local Emergency Planning Committee (LEPC) and the local fire department. We conduct annual drills for implementation of the emergency response plan at the facility with the participation of the LEPC and the fire department. The facility is equipped with a siren to warn plant personnel of an emergency. The last training at the plant w as on January 30, 1999. |