Cargill, Inc. - Dry Milling Division - Executive Summary

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Please note that our propane data is submitted voluntarily even though there is no regulatory requirement to do so at time of original plan development. 
1.  Accidental release prevention and emergency response policies: 
In our Cargill, Inc. Dry Milling Division, Ogden, Utah facility, we handle chlorine and propane, which are considered hazardous by United States Environmental Protection Agency.  The same properties which make chlorine valuable in our milling process also make it necessary to observe certain safety precautions in handling of chlorine to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as our co-workers, and to reduce the threat to nearby members of the community.  The same applies to propane since it is valuable to us as a back-up fuel source.  It is our policy to adhere to all applicable Federal and state rules and regulations.  Safety depends upon the manner in which we handle chlorine and propane, combined with the safety  
devices inherent in the design of this facility, combined with the safe handling procedures that we use, and the training of our personnel. 
Our emergency response procedures include notification of the local fire authority and notification of any potentially affected neighbors.  In addition, access to the site is restricted to authorized facility employees, management personnel, and contractors.  Our chlorine system is enclosed within our building to help keep it secure.  Our propane system is secured by a fence surrounding it. 
2.  The stationary source and regulated substances handled: 
The regulated substances at this faciltiy are chlorine and propane. 
The primary purpose of this facility is to convert wheat into flour.  Chlorine is used in our process to whiten the flour and provide special baking properties that our clients like for breads, muffins, cakes, etc. they make.  Chlorine is received by truck (transports) and is stored inside our flour mill.  The storage capacity of ea 
ch cylinder vessel is 2,000 pounds of chlorine.  We have a total capacity for six cylinders, therefore the maximum amount of chlorine that can be stored at our plant is approximately 12,000 pounds. 
Propane is also delivered by truck and is used as a back-up fuel source.  We have a 29,080 gallon tank which holds, at its maximum capacity, 99,000 pounds of propane.  The propane system also backs up our Cargill Nutrina Feed Mill heating system located on the same site. 
3.  The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario: 
Chlorine Worst-Case Scenario:  After careful review of potential worst-case scenarios, we feel that the largest quantity of a vessel (2000 pounds) released outside, during a cylinder unloading accident that causes rupture of the vessel, with no building passive mitigation effects, is our worst-case.  The distance to the toxic endpoint o 
f 3 ppm for the worst-case scenario is approximately 1.3 miles. 
Chlorine Alternative Scenario:  A pig tail snapping causes a flashing liquid release through a small hole approximately 1/4 inch diameter.  The liquid chlorine flashes immediately to vapor and fine liquid droplets and is carried downwind.  The distance to the toxic endpoint of 3 ppm for the alternative release scenario is estimated to be 0.2 miles.  This release has the possibility of extending beyond the facility boundary. 
Propane Worst-Case Scenario:  Failure of our storage tank, when filled to the greatest amount allowed, would release 99,000 pounds of propane.  It is assumed that entire contents are released as a vapor which finds an ignition source.  Ten percent of the released quantity is assumed to participate in the resulting explosion.  The distance to the overpressure endpoint of 1 pound per square inch (psi) for the worst-case scenario is approximately 0.36 mile. 
Propane Alternative Scenario:  A pull-away cau 
sing failure of a 25-ft length of 4-in. hose.  The excess flow valves function to stop the flow.  The contents of the hose are 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 estimated to be 25 feet and does not have the possibility of extending beyond the facility boundary. 
4.  The general accidental release prevention program and the specific prevention steps: 
This facility complies with EPA's Accidental Release Prevention Rule and with applicable state codes and regulations including OSHA's Process Safety Management Standard (chlorine system only).  This facility was designed and constructed in accordance with good engineering practices to provide a safe system for our employees as well as our neighbors and environment.  Our delivery drivers have been thoroughly trained in regard to chlorine and propane hazards and emergency response.  Our employees wat 
ch the delivery of each truck bringing chlorine and propane to our site.  In addition, we contract out to chlorine and propane system professionals to periodically inspect our chlorine system, and make any necessary adjustments to either equipment or procedures to continue to ensure safe handling and use of chlorine and propane. 
5.  Five-year accident history: 
Since June 21, 1994, there have been no accidental releases, injuries, or environmental damage resulting from our chlorine and propane systems. 
6.  The emegency response program: 
This facility's emergency response program is based upon the management system we have in place and the appropriate discovery and notification procedures to ensure coordination with our local emergency responders.  We have discussed this program with the Ogden Fire Department.  A representative of the Ogden Fire Department and State OSHA visited this plant in 1996.  In 1997, representatives from the Utah DEQ and our insurance company also visited our 
7.  Planned changes to improve safety: 
A process hazard analysis of our chlorine system was conducted on May 8, 1997 and a hazard review of our propane system was conducted on July 9, 1998.  From these reviews, the recommendations were: 
- Continued development and implementation of standard operating procedures (SOPs) and scheduled maintenance activities 
- Continued implementationof equipment manufacturers' operation and maintenance procedures 
- Continued implementation of a mechanical integrity program, including visual inspections and replacement of equipment as necessary 
- Continued implementation of a training program, and expansion of the program to cover more employees to make them aware of the chlorine and propane systems and their potential hazards 
- Develop a maintenace program for hoist and clasp 
- Call Van Waters and Rogers (our chlorine supplier) and determine differences between chlorine cylinders and any other chemcial delivery they make 
- Add to train 
ing SOP to verify chlorine cylinder is chlorine 
- Add to training SOP to check date stamp on chlorine cylinder 
- Have Research Products visually inspect the temper water system during routine inspections 
- Use a chain or nylon strap to hold down and help secure chlorine cylinders in case of an earthquake
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