Coburg Dairy, Inc. - Executive Summary |
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Executive Summary for Coburg Dairy, Inc. Coburg Dairy, Inc., located at 5000 LaCross Road in North Charleston, South Carolina, owns and operates a processing, packaging and storage facility for fluid dairy products. The facility is regulated under RMP due to onsite ammonia storage in excess of the RMP applicability threshold of 10,000 pounds. Ammonia is used at the facilitiy in the ammonia refrigeration system. The receipt, storage and conveyance of ammonia is the single highly hazardous process present at the North Charleston facility. The faciliity's overall approach and commitment to chemical safety is demonstrated by: 1) the existing Occupational Health and Safety Administration (OSHA) Process Safety Management (PSM) as specified by 29 CFR 1910.119 already in place at the facility, and 2) the hazard assessment, prevention program and emergency response provisions implemented specifically for ammonia in response to the RMP requirements. The management structure and oversig ht to ensurre safety is documented in the facility's RMP and includes compliance with applicable regulations, codes and standards (i.e. International Institute for Ammonia Refrigeration (IIAR) guidance for ammonia). Release Scenarios Worst-case and alternative release scenario assessments were conducted for the facility's single largest vessel based on US EPA's Risk Management Program Guidance for Ammonia Refrigeration (November 1998) and RMP*Comp Software. The worst-case release scenario is a 10-minute gaseous ground release of the contents of the single largest vessel at 100% capacity. The storage volume of this vessel is restriced to 80 percent of its total capacity by administrative controls. The alternative release scenaro assumes a 1/4 inch diameter gasket rupture. Public receptors were determined to be located within the impact zone of both the worst-case and alternative releases. No environmental receptors were located witnin the impact zone of either scenario. Five-Year Accident History The facility has had no RMP reportable accidents/releases of ammonia within the five years proceeding RMP submittal. Prevention Program The facility has implemented a Program Level 3 Prevention Proram for Ammonia, as required by the RMP rule, in accordance with the US EPA, OSHA, IIAR and vendor guidance for ammonia. These prevention program provisions are specifically intended to minimize the probability and/or consequences of any accidental ammonia release from the faciltiy and include such measures as process hazards analysis, operating procedures, training, contractors, pre-startup safety, mechanical integrity, hot work permit, management of change, incident investigation emergency planning and response, and compliance audits. The facility prevention program is an ongoing system based on periodic training, incident investigations, audits, procedure revisions, and RMP updates as required to reflect facility change and RMP requirements. Emergency Response Program The facility has coordinated response with the North Charleston HAZMAT Response Team to ensure that they will respond to any accidental release from the ammonia system that is too large for Coburg to handle alone. Safety Management and Changes The facility is committed to ensuring its operations are safe and in accordance with all RMP requirements, and has established a senior manager responsible for RMP development, implementation and compliance. This manager is committed to maintaining the safety of the RMP covered ammonia system through active adherence to the appropriate procedures and codes. To ensure that the appropriate changes occur as necessary to maintain/improve safety, ongoing hazard reviews, training, audits maintenance and investigations will be conducted as required by RMP. Updates to the RMP will be completed as necessary in response to these activities. Summary As documented in this submittal, the RMP for the facility has been completed in accordance with all 40 CFR 68 requirements and the facility has certified RMP compliance. As no incidents with the ammonia system has occured at Coburg, no investigations or follow-up changes have been performed (Section 7.11). Coburg employees will not respond to releases of regulated substances and coordination with local response agencies has been performed; therefore, an emergency response plan and associated training is not required for the Coburg facility (Sections 9.5 and 9.6). Complete ammonia refrigeration system will go on line at the end of August 2000. At that time, applicable procedures and programs will be reviewed and updated in the Process Safety/Risk Management Program Manual. |