General Mills Operations, Inc - Executive Summary

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Accident Release Prevention Program and Emergency Response Policy 
It is the policy of the General Mills Operations, Inc. (GMOI), Buffalo, New York, facility management to implement the requirements of this Risk Management Program (RMP) in accordance with the USEPA regulations under 40 CFR Part 68 and with the corresponding regulations under OSHA's Process Safety Management (PSM) program. The objective is to minimize the risk of a release of a hazardous material and if a release occurs, to minimize the potential impact to GMOI employees, the public and the environment. This objective will be accomplished by utilizing general good operating procedures, providing appropriate training to all employees, and coordinating response activities, as necessary, with the local emergency response providers. 
GMOI management is committed to providing the resources necessary to implement this policy. 
Facility Description 
The GMOI, Buffalo, New York, facility utilize flourmills to 
produce flour. The raw materials used in the processes are wheat and chlorine gas. Support operations include a grain elevator, warehouse, a quality assurance/control laboratory, and administrative offices. Figure 1-1 shows the site location. Figure 1-2 shows the site plan. 
One chemical is utilized at the facility, in sufficient quantities to be subject to the requirements of 40 CFR Part 68, RMP. The chemical is chlorine and is used to bleach or age the flour. 
Worst-Case and Alternative-Release Scenarios 
The worst-case release scenario for a chlorine release included a release of all the contents of one of the 2,000-pound chlorine cylinders in a 10-minute period (per EPA guidelines). This release translates to a release of 2,000 pounds of chlorine in 10 minutes or 200 pounds/min. Other assumptions included in the worst-case assessment are:  the chlorine is a liquefied gas; the cylinder is not diked; the release does not take place indoors; the nearfield dispersion environ 
ment is characterized as urban; 10-minute averaging period; the wind speed is 1.5 meters/sec, and the atmospheric stability is classified as F (stable). The results of the worst-case assessment for chlorine show that the plume must travel 3.23 miles before dispersing to the endpoint concentration of 3.0 parts per million (ppm). Figure 1-3 shows the worst-case release radius. 
The selected alternative-release scenario for the chlorine system is a release resulting from  damage or rupture of the chlorine vapor line from the chlorine manifold to the chlorine distribution system. The pipe has an inside diameter of 3/8 inch. The operating pressure of the cylinder is 94 psig. The alternative-release rate was derived from the following equation, which is based on the pipe size, tank pressure, and the properties of chlorine. 

       where:        QR =    Release rate (pounds per minute) 
               HA =    Hole or puncture area = p/4 d2 = p/4 (3/8 in)2 = 0.11 in2 
               Pt =    Tank pressure (pounds per square inch - ab 
solute (psia)) =         14.7 psi + 94 psig = 108.7 psia (absolute) 
               Tt =    Tank temperature (K) = 700F x 4.2 K/0F = 294 K 
               GF =    Gas Factor, incorporating discharge coefficient, ratio of         specific heats, molecular weight, and conversion factors =         29 (EPA guidance document Appendix B, Exhibit B-1). 
       QR = 20.3 pounds per minute 
       This equation gives an estimate of the release rate. 
From Reference Table 17, Dense Gas Distances to Toxic Endpoint - 60 Minute Release, Urban Conditions, D Stability, Wind Speed 3.0 Meters per Second the distance to the endpoint concentration of 0.0087 mg/l is 0.54 miles. Figure 1-4 shows the alternate case release scenario. 
No active or passive mitigation measures are currently in place. The meteorological data used for this alternative-release scenario was a wind speed of 3 meter/sec, an atmospheric stability classification of D (neutral stability), and an urban dispersion environment in the nearfield. 
General Accidental Release Preventi 
on Program and Chemical Specific Prevention Steps 
The Buffalo facility is governed by a set of OSHA and USEPA regulations that require planning and facility activities intended to prevent a release of hazardous material, or if a release inadvertently occurs, to minimize the consequences of a release to the employees of the facility, the public, and to the environment. These regulations include: 
* 40 CFR Part 68, Accidental Release Prevention 
* 40 CFR Part 112, Spill Prevention, Control and Countermeasure 
* 29 CFR Part 119, Process Safety Management 
The key concepts in GMOI release prevention program are employee participation, appropriate design and maintenance of equipment, and appropriate training of all employees. 
Employee participation in the release prevention program is encouraged and supported by GMOI management. Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the chlorine system. GMOI employees are also  
members of the facility emergency response team. 
GMOI policy is to construct all new equipment, systems, and facilities in accordance with the most current building and safety codes. This ensures the appropriate safety and release prevention systems are included from the beginning of each project. 
GMOI is committed to providing appropriate training to all employees regarding safety procedures. New employees are provided comprehensive safety training during their initial orientation for the facility. In addition, GMOI conducts regularly scheduled safety training for all employees each year. Additional training is provided to maintenance personnel for the systems they are responsible for. 
Five Year Accident History 
GMOI has not had a release of chlorine from Buffalo that has affected their employees, the public or the environment. 
Emergency Response Program 
GMOI does not have personnel trained in emergency response at the facility. 
Planned Changes to Improve Safety 
GMOI and Ameri 
can Ingredients, Inc. completes a thorough review of the chlorine systems each time a design change is implemented. The system is also evaluated each time the PHA is revised. GMOI is committed to using these methods to identify and implement ways to improve the safety of these systems. 
American Ingredients, Inc. will rebuild the chlorine manifold, revise the system mounting brackets and replace the PVC chlorine vapor piping to remove stress from the PVC piping.
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