Cargill, Inc. - Dry Milling Division - Executive Summary |
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1. Accidental release prevention and emergency response policies: In our Cargill, Inc. Dry Milling Division, Chattanooga, Tennessee facility, we handle chlorine, which is 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. 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, 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, who in turn would notify 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 a building on our property to help keep it secure. 2. The stationary source and regulated substances handled: The regulated substance at this faciltiy is chlorine. 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 a building on the south side of our property. The storage capacity of each cylinder vessel is 2,000 pounds of chlorine. We have a total capacity for eight cylinders, therefore the maximum amount of chlorine that can be stored at our plant is approximately 16,000 pounds. 3. The worst-case release scenario(s) and the alternative release s cenario(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 of 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. 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. 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 hazards and emergency response. Our employees watch the delivery of each truck bringing chlorine to our site. In addition, we contract out to chlorine 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. 5. Five-year accident history: Since June 21, 1994, there have been no accidental releases, injuries, or environmental damage resulting from our chlorine system. 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 Chattanooga Fire Department. A representative of the Chattanooga Fire Department visited this plant in January of 1998. 7. Planned changes to improve safety: A process hazard analysis of our chlorine system was conducted on April 3, 1997. From this review, the recommendations were: - Continued development and implementation of standard operating procedures (SOPs) and scheduled maintenance activities - Continued implementation of 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 emplo yees to make them aware of the chlorine system and its potential hazards - Labeling of equipment - Install barricades around tanks in the storage area - Call Van Waters and Rogers (chlorine supplier) and determine differences between chlorine cylinders and any other chemcial deliverys they make - Training documents for chlorine operations - Prepare maintenance schedule (checklist) for Cargill personnel - Check into automatic pressure gauge for >15 psi - Install dripleg to piping in chlorine storage room - Set up schedule to calibrate chlorine alarms - Set up annual inspection for temper water checklist - Remove old piping lines to patent flour agitators not in use |