The Pillsbury Company - Belvidere - Executive Summary
Executive Summary |
The Risk Management Plan (RMP) for The Pillsbury Company's (Pillsbury) Belvidere, Illinois facility includes this Executive Summary as required by 40 CFR 68.155. The Executive Summary includes a discussion of the Risk Management Program implemented at the Belvidere facility, which includes the following elements:
1. Accidental release prevention and emergency response policies
Pillsbury's environmental policy mandates compliance with all of the requirements of EPA's Accidental Release Prevention Program and regulations (40 CFR 68). The frozen food manufacturing and storage facility in Belvidere has developed a Process Safety Management (PSM) program that meets the requirements of 29 CFR 1910.119, and includes a PSM manual that documents safety and risk management policies and procedures pertaining to the prevention of accidental releases and emergency response. In addition, the facility has developed a Risk Management Program (RMProgram) that meets the Program 3 re
quirements of 40 CFR 68. The RMProgram includes a management system, hazard assessment including an offsite consequence analysis (OCA), accident investigation and reporting, the PSM prevention program and the emergency response plans.
2. Stationary Source Activities
The Belvidere facility is located near the northwest edge of the City, approximately 2 miles north of Interstate Highway 90 and approximately 0.5-mile west of Illinois Route 20. The facility is located south of the Kishwaukee River with other industrial facilities along the river with vacant lots and scattered residential areas to the northeast and east. The City of Belvidere lies to the south, west and northwest of the facility. The Belvidere facility manufactures, packages and stores frozen vegetables for markets locally and nationally.
3. Regulated Substances Handled
The ammonia refrigeration system at the Belvidere facility consists of production engine room (PER) and freezer engine room (FER), two separate refriger
ation systems or processes that are subject to EPA's RMProgram. The maximum intended inventory of ammonia (anhydrous) is approximately 108,000 pounds (PER-80,000 lbs; FER-28,000 lbs). Both systems are closed-loop processes and ammonia recharge to these systems is very infrequent. The high-pressure receiver in the PER system is the largest vessel containing ammonia at the Belvidere facility. This vessel is located outside near the northwest portion of the manufacturing building. Ammonia leak detectors are located throughout the process areas and trigger audible alarms in the event of a leak.
4. Worst-Case and Alternative Release Scenarios
The worst-case and alternative release scenario analysis were conducted in accordance with EPA's Risk Management Program Guidance for Offsite Consequence Analysis (April 15, 1999) and the Risk Management Program Guidance for Ammonia Refrigeration (Ammonia Guidance) (November 1998). The equations and tables in the Ammonia Guidance document were used
to obtain the distance to the endpoint (0.14mg/l or 200 ppm for ammonia) for the worst-case and alternative release scenarios.
For the worst-case scenario, the high pressure receiver (HPR) in the PER refrigeration process, containing the largest quantity of ammonia, was chosen as the vessel that would fail releasing the entire quantity (54,000 pounds) of ammonia over a 10 minute period. Using the calculated ammonia release rate of 5,400 pounds per minute (lb/min) and urban terrain, the resulting distance to the endpoint extends offsite, and public receptors are within the distance to the endppoint. The alternative release scenario chosen was the release of ammonia from a 0.25-inch equivalent diameter hole representative of a process-piping break, pump seal leak or a gasket rupture (Ammonia Guidance, Section 4.2). Using a hole diameter of 0.25" and a gauge pressure of 180 psig, the ammonia release rate was determined to be 134 lb/min (Ammonia Guidance, Simplified Bernoulli Equation 3)
, representing a scenario in which 4,000 pounds of ammonia is released over a 30-minute period. Using urban terrain, the resulting distance to the endpoint extends offsite, and public receptors immediately adjacent to the facility are within the distance to the endppoint.
The results included in this analysis indicate that the worst-case release of ammonia from the HPR can impact offsite public receptors. However, it is important to emphasize that the occurrence of a worst-case release is extremely unlikely because of the numerous safety features inherent in the design, operation and maintenance of the ammonia refrigeration systems at the Belvidere plant. The alternative release scenario, on the other hand, is based on more credible failure assumptions, its potential to reach offsite receptors and was selected from among a number of possible scenarios. The alternative scenario is, according to the Ammonia Guidance document, representative of a pipe break, gasket or valve packing failu
5. Prevention Program
For the Belvidere facility, Pillsbury has instituted a Program 3 Prevention Program. The facility already implements and operates a OSHA PSM program which is equivalent to and meets the Program 3 accidental release prevention requirements of 40 CFR 68. The PSM program implementation represents one of the most effective ways to address and prevent accidental releases of ammonia and for minimizing the impacts of any releases that do occur. The key elements of the Prevention Program at the Belvidere facility are summarized below:
Process Safety Information - A comprehensive set of process safety information (PSI) has been compiled for the ammonia refrigeration system at the Belvidere facility. The PSI includes data on process-related chemicals, equipment, operation and technology.
Process Hazard Analysis - An initial process hazard analysis (PHA) was conducted to satisfy the PSM requirements in 1994. The most recent PHA was completed in December 1998 and seve
ral recommendations were made by the PHA team to improve the safety of the systems. The Belvidere facility has implemented some of the changes, based on the recommendations. Any remaining changes are expected to be completed by June 30, 2000.
Operating Procedures - Written standard operating procedures (SOPs) and safe work practices have been developed and implemented at the Belvidere facility. The SOPs and practices are reviewed annually and certified as reflective of current plant practice.
Training - Written training programs have been developed at the Belvidere facility to provide initial and refresher training to employees and operators on safe work practices and process operations. Operator 1-2-3 training is provided to each operator before they are certified to operate the ammonia refrigeration systems at the Belvidere facility.
Maintenance - All the major ammonia refrigeration equipment is included in the preventive maintenance program. Equipment inspections, testing and p
reventive maintenance activities are conducted in accordance with a written maintenance schedule and per IIAR Bulletin 109.
Management of Change - A Management of Change (MOC) procedure has been developed at the Belvidere facility. The MOC procedure is used to address all changes to process chemicals, technology, equipment and procedures as well as facility changes affecting the ammonia refrigeration process at the facility so as not to compromise the safety and integrity of the process.
Pre-startup Review - Pre-startup reviews (PSR) are conducted whenever a modification to the process requires the PSI to be updated. Checklists are used to direct the PSR process and ensure that all essential elements of the prevention program (i.e., engineered systems and documentation) were in place prior to startup.
Compliance Audits - A compliance audit program has been developed to ensure that the risk management program meets the requirements of 40 CFR 68. The PSM audit is conducted at least ev
ery three to verify compliance with both PSM and RMP requirements. An initial compliance audit was conducted in 1995. Findings from the most recent audit in 1998 are being addressed in a timely manner and implementation of changes is expected to be completed in 1999.
Incident Investigation - The Pillsbury Company routinely investigates any release incident or accident that occurs at the Belvidere facility. An incident investigation procedure has been developed to help the investigation team determine the root cause of an incident and help develop measures to prevent recurrence.
Employee Participation - An employee participation program is in place at the Belvidere facility. Employees are involved in collecting and maintaining PSI, PHA studies, PSR, training, incident investigations, emergency response and other safety and risk management issues. This provides an important way in which employees take and retain ownership of the risk management program.
Hot Work Permit Program - A h
ot work permit program has been developed and is implemented whenever hot work is to be performed in and around the ammonia refrigeration systems. Hot work permit forms are reviewed and revised annually.
Contractor Safety - The Belvidere facility has procedures in place to address Contractor safety. They include using contractors that are trained in their jobs, follow SOPs and understand the hazards associated with their work. In addition, the Belvidere facility pre-qualifies contractors through a process of review and selection based on the contractors' past safety records.
6. Five -Year Accident History
During the last five years, there have been no releases of ammonia at the Belvidere facility that meet the RMP reporting criteria.
7. Emergency Response Plan
The Belvidere facility has a written emergency response plan (ERP). The ERP includes procedures for evacuations, notifying response agencies and adjacent businesses, a listing of emergency equipment along with a schedule for
maintaining the equipment, and procedures for responding to any release that may occur. The ERP also includes first aid procedures for exposures to ammonia. The ERP is coordinated with the City of Belvidere Fire Department and other emergency management agencies including the Boone County Emergency Management Agency, the designated local emergency planning committee (LEPC) for Boone County. The ERP is reviewed on an on-going basis and revised as needed.
The facility has conducted risk management plan communication meetings with employees and the public. A public communication meeting was held on April 24, 1999 to inform immediate offsite receptors in cooperation with the Belvidere Fire Department and the Boone County Emergency Management Agency.
8. Planned Changes to Improve Safety
All safety-related recommendations resulting from MOC activities have been implemented at the Belvidere facility and there are no pending changes. Recommended changes resulting from PHAs have been imp
lemented since December 1998 and are expected to be completed over the next year. However, it is Pillsbury's policy to review operating, maintenance and emergency response procedures on a on-going basis to ensure that they are always applicable. Recommendations generated from this continuous review process are typically addressed in a very short time frame.
The design, operation and maintenance of the ammonia refrigeration processes 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 appropriately at the Belvidere facility. The likelihood of an ammonia release is greatly minimized through the implementation of these programs. Pillsbury's Belvidere facility has also developed an ERP to address an ammonia release event in coordination with the local first responders.