The Pillsbury Company - Atlanta - 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 the all of the requirements of the EPA's Accidental Release Prevention Program regulation and all applicable Federal and state rules and regulations. The Atlanta plant has developed an OSHA Process Safety Management (PSM) Manual that documents safety and risk management policies pertaining to the prevention of acci dental releases and emergency response. In addition to the PSM Mnaual, the Atlanta plant has developed a Risk Management Program that includes a description of the management system, the Offsite Consequence Analysis (OCA), the five-year accident history, the Prevention Program elements, and an Emergency Response Program. 2. Stationary Source Activities The plant is located in the City of Atlanta, in Fulton County, Georgia. The plant was acquired by Pillsbury in 1999. The plant produces par-baked goods and frozen dough. The ammonia refrigeration process is used for cooling and blast freezing and for frozen finished goods storage. 3. Regulated Substances Handled The ammonia for the refrigeration system at the Atlanta 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 los t due to maintenance activities and a small intermittent purge. The system consists of compressors, receivers, evaporators and condensers and has a maximum intended inventory of 18,000 pounds of ammonia. Ammonia leak detectors have been located throughout the ammonia areas. All ambient detectors trigger a leak alarm. 4. Worst-Case and Alternative Release Scenarios For the worst case and alternative release scenarios, the EPA Model Risk Management 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 High Pressure Receiver which can contain up to 17,800 pounds (87.5% at 90F) 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. Discussion 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 menti oned in the Ammonia Model RMP, the alternate ammonia scenario would be representative of a pump seal, gasket, or valve packing leak. 5. Prevention Programs For the Atlanta Plant ammonia system, Pillsbury implemented an RMP Program 3 Prevention Program which is equivalent to the OSHA Process Safety Management (PSM) program. This is one of 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, equipment, technology, process flow diagrams and P&IDs. Process Hazards Analysis (PHA) - A PHA was conducted to satisfy the PSM requirements in 1997 and 2000. Recommendations made by the PHA team to improve safety are currently being addressed. Operating Procedures - Equipment Operating and Maintenance Manuals, in addition to plant specific procedures, provide written guidance for ammonia system operations. Training - Training is provided for all personnel involved with ammonia plant operations. Maintenance (Mechanical Integrity) - Equipment inspections, testing, and preventative maintenance activities are scheduled according to manufacturers' recommendations and/or IIAR Bulletin 109. Management of Change (MOC) - An MOC procedure has been developed and is implemented to ensure all changes are adequately reviewed and appropriate sections of the PSM updated. Pre-Startup Review (PSR) - A PSR policy and procedure has been developed to address startups following equipment or system changes. A PSR was conducted prior to startup of the new High Pressure Receiver (HPR) in 2000. Compliance Audits - A PSM audit was performed in 1999. Findings from the audit are being addressed. Incident Investigation - An incident investigation policy and procedure has been developed to hel p determine the root cause of an incident and to help develop measures to prevent recurrence. Employee Participation - A PSM employee participation program has been developed to make the employees aware of the PSM program, the PHA, and its findings. Employees were involved in the PHA and are trained on the operation of the ammonia system. Hot Work Permit - A hot work permit program has been developed and implemented for hot work conducted in and around the ammonia systems. Contractor Safety - Contractor safety procedures are in place to ensure the contractor is aware of the hazards involved in the work, and to verify the contractor will follow safe work practices in place. 6. Five-Year Accident History There have been no releases of ammonia that meet the RMP accident criteria in the last five years. 7. Emergency Response Program The Atlanta plant has an emergency response program which is described in the site Emergency Response Plan (ERP). This plan includes procedures f or evacuations, notifying 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 Atlanta Fire Department and the Atlanta Emergency Management Agency. The facility has conducted risk management plan communication meetings with employees and has notified immediate offsite receptors. A public communications meeting was held on January 24, 2000 in cooperation with the Atlanta Fire Department and the Atlanta Emergency Management Agency. In addition, the Atlanta Fire Department and Atlanta Emergency Management Agency have been informed of the revisions to the ERP and Offsite Consequence Analysis for the the new ammonia storage vessel. Immediate neighbor or community response would typically be sheltering in-place or an evacuation order would be given, depending on the severity of the incident. 8. Planned Changes to Improve Safety All recommendations from the PHA and compliance audit are being addressed. 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 communicated t he information in this Risk Management Plan to the local community. |