Superbrand Dairy Inc. - Greenville - Executive Summary

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SUPERBRAND DAIRY- TAYLORS, SOUTH CAROLINA FACILITY 
RISK MANAGEMENT PLAN 
 
 
EXECUTIVE SUMMARY 
 
 
1. Corporate Prevention  and Emergency Response Approach 
 
The Superbrand Dairy, Inc. Facility (Superbrand Dairy) is a manufacturing facility owned by Winn-Dixie Stores, Inc.(Winn-Dixie)  located at Taylors, South Carolina.  Winn-Dixie requires each facility to develop and maintain accident prevention programs and an emergency response plan appropriate to the site.  Each site is also responsible for regulatory compliance issues that apply to the site.  Winn-Dixies corporate and division environmental and safety personnel provide assistance in training for site employees and in budgeting and procurement of safety and training services. 
 
2. Description of Stationary Source 
 
Superbrand Dairy is located at 2819 Wade Hampton Blvd. in the city of Taylors, S.C.  The facility consists of areas for manufacturing and packaging of Milk and Ice Cream, and freezer and cooler storage of these perishable ite 
ms for distribution to the Winn-Dixie Supermarkets. 
 
Superbrand Dairy has one ammonia refrigeration system that exceeds the 10,000 lb. RMP threshold quantity.  The ammonia refrigeration systems equipment is located in the compressor room in the southwest corner of the building and property.  All of the equipment for the  system is located inside the building, except for the high pressure receiver (HPRs). The HPR is the largest capacity vessel in the ammonia refrigeration system capable of holding approximately 16,179 pounds of ammonia.  The HPR is located outside of the dairy building. 
 
The Superbrand Dairy facility also has propane on site which exceeds the flammables 10, 000 lb. RMP threshold quantity.  The propane is kept in six above ground storage tanks that have a total capacity of 660,000 pounds combined.  Propane is used as a backup fuel on site for the facilitys two boilers.  The propane storage tanks are located along the northeast property border.  
 
3. Description of the W 
orst Case and Alternative Release Scenarios 
 
The Worst Case release scenario for ammonia is the rupture of the HPR, releasing 16,179 lbs. of ammonia gas over a ten minute period.  Under worst case weather conditions, the ammonia gas could travel 2.2 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .14 mg/L), using the Ammonia Guidance. 
 
The alternative-case release scenario was characterized by a leak rate of 459 lb./min. from the HPR liquid supply line due to pipe connection failure from corrosion of the pipe.  Under normally expected weather conditions, the ammonia gas could travel 0.4 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .14 mg/L), using the Ammonia Guidance. 
 
The Worst Case release scenario for propane is the failure of the storage tank when filled to the greatest amount which would release 110,000 lbs. of propane.  It is as 
sumed that the entire contents are released as vapor which finds an ignition source, 10% of the released quantity is assumed to participate in the resulting explosion.  The distance to the endpoint of 1 psi for the worst case analysis is 0.40 miles (2006 feet) using the OCA Guidance. 
 
The Alternative-Case release scenario for propane is an accident during filling of the propane storage tank.  Failure of the process pipe connected to the transfer hose happens due to truck driver error.  The contents of the pipe is released.  The resulting unconfined vapor travels to the lower flammability limit.  The distance to the endpoint for the lower flammability limit for the alternative scenario is less than 0.1 miles (528 feet), using the OCA Guidance.  This release has the possibility of extending beyond the facility boundary since the storage tank is next to the property boundarys fence line. 
 
4. Prevention Program 
 
This facility exceeds the ammonia threshold quantity in the ammonia refrigera 
tion system for the OSHA Process Safety Management (PSM) Standard, 1910.119, and is therefore subject to the PSM requirements. The facility also exceeds the flammables threshold quantity for its propane system and is therefore subject to the RMP requirements.  For RMP compliance purposes, this places the Superbrand Dairy facilitys refrigeration process in the Program 3 level and the propane process in Program 2 level.  
 
Prevention Program 2 
 
The facility will address the required Program 2 Prevention Program for the propane process by developing the seven required elements for the propane system.  The seven elements of the Prevention Program 2 are Process Hazard Review, Process Safety Information, Mangement of Change, Incident Investigation, training, compliance audits, and emergency response plan. 
 
Prevention Program 3 
 
Superbrand Dairy will use its PSM program as the required Program 3 Prevention Program for ammonia.  The Superbrand Dairy facility has a program in place to comply wi 
th the OSHA Process Safety Management Standard, 29 CFR 1910.119.  The PSM Program was reengineered in 1998 for the ammonia process.  The PSM Program includes a preventative maintenance plan which requires all ammonia refrigeration equipment to be periodically inspected and serviced.  This will ensure that the equipment remains in good operating condition and will minimize the probability of accidents due to faulty equipment.  In developing the PSM Program, Superbrand Dairy also developed written operating procedures for the refrigeration processes.  These procedures cover all phases of operation and include information on safety devices.  These procedures will be used to train all operators and mechanics who work on the ammonia refrigeration processes to ensure consistency of operation and minimize human error.  In addition, all refrigeration mechanics receive training through the Refrigeration Engineers and Technicians Association (RETA) training course.  These measures ensure that al 
l refrigeration operators and mechanics are properly trained.  Existing safe work practices such as Lockout/Tagout and Hot Work Permit, were reviewed and updated to ensure that all non-routine work can be performed safely.  Other components of the prevention program include collection and review of all equipment information, the development of updated Piping & Instrumentation Diagrams (P&IDs), and the correction of any equipment design deficiencies found.  These actions will ensure that the equipment meets all refrigeration industry standards and that accurate equipment information will be available when needed.  To ensure that the Superbrand Dairy refrigeration staff has the skills necessary to identify unsafe conditions, Process Hazard Analysis (PHA) training was conducted.  The staff also performed a PHA of this process.  Other PSM procedures, including Management of Change, Pre-Startup Safety Review, Compliance Audits, and Incident Investigation are also part of the program to ensu 
re continued safe operation and prompt correction of deficiencies.  The PSM Program receives full support of plant management and involvement of employees at all levels. 
 
5. Accident History 
 
The Superbrand Dairy facility has had no accidental releases of ammonia or propane in the past five years. 
 
6. Emergency Response Program 
 
The Superbrand Dairy facility has an Emergency Response Program in place.  The program complies with 29 CFR 1910.38.  The site also has some internal emergency response capability and is developing a program to comply with paragraph (q) of 29 CFR 1910.120.  The current plan has been coordinated with the Madison County Fire Department and Hazardous Materials Response Team, and the Regional Local Emergency Planning Committee.  Notification is made locally by dialing 911, and by notifying South Carolina State Warning Point at (888) 481-0125.
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