The Pillsbury Company - Geneva - Executive Summary |
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Executive Summary The Risk Management Program (RMP) includes an Executive Summary as required by 40CFR 68.155. This Executive Summary includes a discussion of the various Risk Management Program elements as follows: 1. Accidental release prevention and emergency response policies 2. Stationary source activities 3. Regulated substances handled 4. Worst-case and alternative release scenarios 5. General and chemical-specific accidental release prevention program 6. Five-year accident history 7. Emergency response program 8. Planned changes to improve safety 9. Summary 1. Accidental Release Prevention and Emergency Response Policies It is Pillsbury's policy to comply with all of the requirements of the EPA's Accidental Release Prevention Program regulation as well as all other applicable Federal and State rules and regulations. The Geneva Plant has developed an OSHA Process Safety Management (PSM) Manual that documents safety and risk management policies pertaining to the preventio n of accidental releases and emergency response. In addition to the PSM Manual, the Geneva Plant has developed a Risk Management Program that includes the OSHA PSM elements, a description of the risk management system, the Offsite Consequence Analysis (OCA), and the five-year accident history. 2. Stationary Source Activities This new Pillsbury facility includes ammonia process refrigeration equipment. The ammonia is supplied from an engine room owned and operated by Millard Refrigerated Services (MRS) adjacent to the plant. Ammonia vapor is returned to MRS in the closed system, for compression and condensing to provide liquid back to the Pillsbury refrigeration loads. MRS has an overall PSM program for their equipment and the overall system. MRS has their own RMP program. This RMP is only for the refrigeration equipment owned and located on Pillsbury property. The Geneva Plant is located in Kane County, Illinois. The facility produces frozen dough products. The dough is processed , filled, frozen, packaged and stored in a frozen goods warehouse (adjacent facility operated by MRS) prior to shipment. Ammonia is used to provide refrigeration for process cooling and flash freezing (at Pillsbury) and for refrigerated and frozen finished goods storage (at MRS). 3. Regulated Substances Handled The ammonia for the refrigeration system at the Geneva Plant is a regulated substance under the EPA's Risk Management Program rule. The ammonia system is a closed loop which recirculates and reuses the same material. Infrequent makeup to the system is only to replace material lost due to maintenance activities and a small intermittent purge. The Pillsbury system consists of a receiver and evaporators and has a maximum intended inventory of 23,000 pounds of ammonia. The MRS engine room includes the compressors and condensers for the overall system. 4. Worst-Case and Alternative Release Scenarios For the worst case and alternative release scenarios, the EPA Model Risk M anagement Program and Plan for Ammonia Refrigeration (May 1996), the International Institute of Ammonia Refrigeration (IIAR) Risk Management Guidelines for Ammonia Refrigeration (1998) and the EPA Risk Management Program Guidance for Ammonia Refrigeration (November 1998) were used for guidance. The Ammonia Guidance tables were used to derive the hazard distances for worst-case and alternative release scenarios. Releasing the contents of the Low Pressure Receiver which can contain up to 20,000 pounds (83.5% at -40F) of ammonia represents the worst-case scenario. The resulting distance to the endpoint extends offsite, and public receptors are within the distance to the endpoint. The alternative release scenario was chosen as a quarter-inch hole, which would be representative of a pump seal leak or a gasket rupture. The resulting distance to the endpoint also extends offsite, and public receptors immediately adjacent to the facility are within the distance to the endpoint. Discuss ion The results included in this analysis indicate that the worst-case release for the ammonia process can extend offsite and reach public receptors. However, it is important to emphasize that a worst-case release is extremely unlikely to occur because of the many safety features inherent in the design and operational systems for the plant. On the other hand, the alternative release scenario is based on credible assumptions. The alternative scenario was selected from a number of possible scenarios, based on their potential to reach offsite. As mentioned in the Ammonia Model RMP, this scenario would be representative of a gasket leak or a pump seal leak. 5. Prevention Programs For the Geneva Plant ammonia system, Pillsbury followed the ANSI/IIAR 2-1992 Standard for Equipment, Design, and Installation of Ammonia Mechanical Refrigeration Systems and implemented an RMP Program 3 Prevention Program which is equivalent to the OSHA Process Safety Management (PSM) program. This is one o f the most important ways for preventing ammonia releases and for minimizing the impacts of any release that does occur. Some of the key elements of the Prevention Program are summarized below. Process Safety Information(PSI) - A comprehensive set of process safety information has been compiled for the ammonia system. The PSI includes data on the chemicals, the equipment and the technology of the process. Process Hazards Analysis (PHA)- A PHA was conducted before startup in 1999. Recommendations made by the PHA team to improve the safety of the systems have all been addressed. Operating Procedures - An Operations and Maintenance Manual provides detailed written operating procedures for the ammonia system and for safe work practices. Training - Training is provided to each operator and maintenance person before they are certified to operate the system. Maintenance - All of the covered ammonia equipment is included in the Geneva preventive maintenance program. Equipment inspecti ons, testing and preventive maintenance activities are performed following a structured schedule according to IIAR Bulletin 109. Management of Change (MOC) - An MOC procedure has been developed and is implemented for all changes made to the ammonia system, including the safety systems. Pre-startup Review (PSR)- Pre-startup reviews are conducted whenever a change results in a change to the PSI. Checklists are used to direct the PSR process. The checklists are used to ensure that all essential elements of the prevention program (i.e., engineered systems and documentation) were in place prior to startup. Compliance Audits - Since this is a new facility, a compliance audit will be conducted within the next three years. Incident Investigation - The Pillsbury Company routinely investigates any ammonia related incident or accident that occurs at the Geneva Plant. An Incident Investigation procedure has been developed to help the investigation team determine the root cause of an inciden t and to help them develop measures to prevent recurrence. Employee Participation - An employee participation program (for safety and risk management) is in place and training in PSM has been conducted for all affected employees. Employee involvement in PHA studies and review of operating procedures is an important way in which employees take and retain ownership of the risk management programs. Hot Work Permit Program - A hot work permit program is being used at the Geneva Plant whenever hot work is conducted in and around the ammonia systems. Contractor Safety - Contractor safety procedures have been developed and implemented. 6. Five-Year Accident History Since startup in 1999 there have been no releases of ammonia from the Geneva Plant that meet the RMP reporting criteria. 7. Emergency Response Program The Geneva Plant has an emergency response program which is described in the site Emergency Response Plan (ERP). This plan includes procedures for evacuations, notifyi ng response agencies and adjacent businesses, emergency equipment list with maintenance schedule, and procedures for responding to any release that may occur. The plan also includes first aid procedures for toxic exposures to ammonia. The ERP is coordinated with the Geneva Fire Department and Kane County Emergency Management Agency. The facility has conducted risk management plan communication meetings with employees and has plans to notify immediate offsite receptors. A public communications meeting will be held in cooperation with the Geneva Fire Department and Kane County Emergency Management Agency. 8. Planned Changes to Improve Safety All recommendations from initial PHAs, MOCs, and PSRs have been or are being addressed. However, it is Pillsbury's policy to review operating, maintenance and emergency response procedures on a routine basis to ensure they are always applicable. This continuous review process does generate further recommendations for improved safety during the course of operations, but these measures are typically addressed in a very short time frame. 9. Summary The design, operation and maintenance of the ammonia system according to IIAR Standards and Guidelines and the implementation of the PSM and RMP programs provide a high level of assurance that the hazards and risks associated with the use of ammonia are being managed in an appropriate manner. The likelihood of a release is minimized through the implementation of these programs. Pillsbury has developed an Emergency Response Plan which is coordinated through the local response agencies and has plans to communicate the information in this Risk Management Plan to the local community. |