Siemer Milling Company - Teutopolis Plant - Executive Summary |
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1.1 EXECUTIVE SUMMARY Accident Release Prevention Program and Emergency Response Policy It is the policy of 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 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. Management is committed to providing the resources necessary to implement this policy. Employee participation in the release prevention program is encouraged and supported by management. Key personnel are responsible for conducting an d implementing the findings from the Process Hazard Analysis (PHA) for the chlorine system. Employees are also members of the facility emergency response team. The 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. We are committed to providing appropriate training to all employees regarding safety procedures. Each new employee is provided comprehensive safety training during his or her initial orientation for the facility. In addition, We conduct regularly scheduled safety training for all employees each year. Additional training is provided to maintenance personnel for the systems they are responsible for. Members of the plant emergency response team receive annual training to ensure that response actions are promptly and safely completed. Facility Description This facility utilizes flour m ills to produce flour. The raw materials used in the processes are wheat and chlorine gas. Support operations include a chlorine system, a quality control laboratory, and administrative offices. 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 Chlorine 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 is mitigated by enclosure which reduces the release by 55%; the nearfield dispersion environment 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 3.5 miles before dispersing to the endpoint concentration of 3.0 parts per million (PPM). The selected alternative-release scenario for the chlorine system is a release resulting from damage or rupture of the chlorine vapor line (pigtail) from the ton cylinder to the chlorine manifold. The pigtail has an inside diameter of 3/8 inch. The operating pressure of the cylinder is 150 psig. The alternative-release rate was derived from the equation below, which is based on the hole size, tank pressure, and the properties of chlorine. QR = HA X P t X Where: QR = Release rate (pounds per minute)\ HA = Hole or puncture area = p/4 d =p/4 (3/8 in) =0.11 in P t = Tank pressure (pounds per square inch - absolute (psia))= 14.7 psi + 150 psig = 164.7 psia (absolute) T t = Tank temperature (K) = 70 F x 4.2 K/ F = 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). Therefore: QR = 30.5lbs X 55% = 16.8 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 0.27 miles. Passive mitigation measure (enclosure) is currently in place and reduces rate of release by 55%. The meteorological data used for this alternative-release scenario was a wind speed of 3 meter/sec, and atmospheric stability classification of D (neutral stability), and an urban dispersion environment in the nearfield. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The facility is governed by a set of OS HA 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 * 40 CFR Part 264, Hazardous Waste Contingency Plan * 29 CFR Part 119, Process Safety Management The key concepts in our release prevention program are employee participation, appropriate design and maintenance of equipment, and appropriate training of all employees. Five Year Accident History We have had on reportable accidental release of chlorine that has not affected the public or the environment. Emergency Response Program We have personnel trained in emergency response at the facility 24 hours per day, seven days per week. These personnel receive semiannual training o n emergency procedures and response techniques. Our company response program has been coordinated with the Effingham County LEPC. Drills are performed annually to test all aspects of the plan. Planned Changes to Improve Safety American Ingredients and our company complete 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. We are committed to using these methods to identify and implement ways to improve the safety of these systems. Refresher training is held annually. |