Bartlett Milling Company - Statesville NC - Executive Summary

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Bartlett and Company - Statesville NC 
            Executive Summary - Chlorine 
Accidental Release Prevention and Emergency Response Policies:  
It is our intent and policy to adhere to all applicable federal, state and local laws. 
To provide for the safety of our employees, our customers and the general public, Bartlett provides  corporate Environmental, Health, and Safety (EHS ) personnel to maintain and administer comprehensive safety and environmental programs and procedures.  EHS personnel audit and monitor facility compliance with the safety standards of the company. 
All locations are required to conduct their own internal audit utilizing checklist survey forms that are reviewed regularly and updated as necessary to ensure all applicable federal, state, and local regulations are covered.  EHS personnel conduct comprehensive annual audits at every location to measure regulatory compliance including those governing the safe handling and storage of chlorine. This requir 
es a timely written response with the completion date of all recommendations resulting from the audits. 
Each location has a "Manager " or "Site Safety  Coordinator" as an extension of the EHS.  They are given training to monitor the day to day safe work activities, maintain the required regulatory record keeping, conduct monthly safety meetings, conduct employee training, and act as the location's contact with corporate EHS. The manager or designated site safety coordinator acts as the location's emergency contact. 
Description of our Facility and the Regulated Substances Handled: 
This facility is a wheat flour mill.  We store wheat and grind, blend, package and distribute wheat flour and milling byproducts to institutional and retail bakers and feed manufacturers.  Chlorine is received by truck, is handled and stored on-site, and is a substance regulated by the EPA requiring us to comply with the Risk Management Program.  We use chlorine in 2,000 pound cylinders.  The chlorine  
is introduced to the process in gaseous form for sanitation and oxidation properties 
Chlorine is maintained under pressure in portable 2,000 pound cylinders.  A maximum of two cylinders are kept on site for use in flour production. One cylinder is connected to the process and the second is kept in reserve.  Therefore, the total facility chlorine storage capacity is 4,000 pounds.  The largest single storage vessel for chlorine at our facility contains 2,000 pounds. 
Worst Case Scenario: 
Our worst case scenario is the loss of the total contents of a 2,000 pound cylinder, released as a gas over 10 minutes resulting in total vaporization.  The maximum quantity released would be 2,000 pounds.  According to EPA's RMP*Comp modeling, this release (distance from point of dispersion to 0.0087 ml/L) would have off-site impact.  It should be noted that Bartlett has never had a release of an entire cylinder of chlorine from any facility. 
Alternative Release Scenario: 
The most common alter 
native release scenario from our facility would not reach an end point off-site.  The alternative release scenario modeled for the purpose of this plan is a 2-minute release from a storage cylinder representing a piping or fitting failure requiring a manual shut down.  The total amount of chlorine released in this scenario would be 17 pounds.  This release scenario (distance from point of dispersion to 0.0087 ml/L) would have off-site impact.  It should be noted that Bartlett has never had a release of this type from any facility. 
General Accidental Release Prevention Program and Chemical-Specific Prevention Steps:  
The chlorine system is designed, installed, and maintained in accordance with applicable ANSI and ASTM standards and ASME codes.  This facility complies with OSHA (29 CFR 1910.101), EPA's Accidental Release Prevention Rule, and all applicable federal, state, and local codes and regulations. 
Our chlorine system is protected from major releases by pressure regulating valv 
es, check valves, relief valves and manual shutoffs.  
Our chlorine system is inspected on a regular basis with maintenance and preventive maintenance scheduled and documented.  Liquid and vapor valves, piping, gauges, and relief valves are replaced when necessary and according to the guidelines in the ANSI standards. 
Training is provided to all employees at least annually, whenever there is a change in the process, or whenever competency with the regulations is questioned.  The training consists of classroom lectures, current videos, testing and certification, and on the job training. 
Five-year Accident History: 
There have been two accidents involving chlorine that caused injuries on site.  On September 19, 1998 two employees inhaled chlorine while connecting a full cylinder to replace an empty cylinder.  The pipe fitting being connected was not tightened properly and gas escaped. One employee involved missed the balance of the shift and the next day of work as a result.  On De 
cember 9, 1997 a piece of milling equipment choked and shut down which caused chlorine to escape from the equipment.  An employee working in the area was exposed to the gas.  The employee missed the balance of that shift and the next full day of work.  
                                                                                                                                                                      There have been no accidents involving chlorine that caused deaths or property or environmental damage, including evacuations on or off-site. 
Emergency Response Program: 
In the event of an emergency involving our chlorine system, it is our policy to notify the local community fire department and request that they respond to the emergency. In preparation for this, we have coordinated with all of the local response agencies by providing information and/or facility tours to ensure that they are familiar with and properly prepared for an incident at our facility. This will 
help to ensure that our community has the strategy for responding to and mitigating the threat posed by an chlorine release. This complies with the requirement for our facility to be included in the community emergency response plan prepared under EPCRA and coordinated with our LEPC. 
In addition, Bartlett has an Emergency Response and Contingency Plan for each facility that complies with the requirements of OSHA (29 CFR 1910.38 and 1910.1200).  The plan includes provisions for public notification, initial medical care, evacuations, and LEPC coordination. 
Planned Changes to Improve Safety: 
We do not plan to make any changes to the physical site. We will continue to provide our employees with ongoing annual training to ensure that they are current with safe chlorine use and handling procedures. We will also provide regular inspection and maintenance on all of the chlorine equipment.
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