The Pillsbury Company - Hillsdale - 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 and all applicable Federal and state rules and regulations.  The Hillsdale plant has developed an OSHA Process Safety Management (PSM) Manual that documents safety and risk management policies pertaining to the prevention of accid 
ental releases and emergency response.  In addition to the PSM Manual, the Hillsdale 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.                                           
The facility is designed and operated in accordance with the standards and guidelines of The Chlorine Institute, Inc. 
2.  Stationary Source Activities 
The plant is located in the City of Hillsdale, in Hillsdale County, Michigan.  The plant was acquired by Pillsbury in 2000.  The plant is a prepared bakery mix plant and flour mill.  Chlorine is used in the flour milling process.  The reaction of raw flour and chlorine is complete within normal application rates.  No chlorine is discharged and there are no byproducts or waste products created under normal conditions. 
3.  Regulated Substances Handled 
The chlorine for the  
flour milling process at the Hillsdale Plant is a regulated substance under the EPA's Risk Management Program rule.  The chlorine storage and gas delivery system is a closed system and delivers gaseous chlorine to the flour chlorinators under vacuum.  The chlorinating system consists of containers, piping, valves, pumps, flowmeters, and controls.  Full chlorine containers are delivered  and empty containers picked up approximately 9 times per year by an outside service.  The maximum intended inventory is 8-one ton containers (or 16,000 pounds) of chlorine. 
A chlorine detector is located in the chlorine container storage room.  A visual alarm for the detector is located on the alarm panel on the 3rd floor control room.  Associated with the visual alarm is an audio alarm that sounds throughout the milling facility.  An audio and visual alarm is also located on the exterior of the building. 
The clorination system reduces the gas pressure from the storage container to near zero, allowing 
the system to operate in a vacuum.  If a release does occur in the chlorine piping to the chlorinators the flow of chlorine is automatically shut off. 
4.  Worst-Case and Alternative Release Scenarios 
For the worst case and alternative release scenarios, the EPA OCA Guidance Reference Tables and The Chlorine Institute guidance were used to derive the hazard distances for worst-case and alternative release scenarios. 
Releasing the contents of a full ton container (up to 2,000 pounds) of chlorine represents the worst-case scenario.  It is assumed that the entire contents are released as a vapor, which is heavier than air.  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 rupture of a 3/8" flexible delivery pipe on a ton container, initiating the maximum possible release rate from an open container.  The resulting distance to the endpoint also extends offsite, and pub 
lic receptors immediately adjacent to the facility are within the distance to the endpoint. 
The results included in this analysis indicate that the worst-case release for the chlorine 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.  The alternate chlorine scenario would be representative of pipe, gasket, or valve packing leak in the chlorine storage room.  A chlorine detector is located within the room to automatically start exhaust fans and sound an alarm.  Employees are trained to respond to the alarm and isolate the containers before the entire contents are released. 

.  Prevention Programs 
For the Hillsdale Plant chlorine 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 chlorine 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 chlorine 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 1998 and updated in 2000.  Recommendations made by the PHA team to further improve safety are currently being addressed. 
Operating Procedures - Equipment Operating and Maintenance Manuals, in addition to plant specific procedures, provide written guidance for chlorine system o 
perations, including safe unloading and handling of ton containers. 
Training - Training is provided for all personnel involved with mill plant (clorinating) operations.  Annual training includes the safe unloading and handling of chlorine, chlorine system operation, and emergency response. 
Maintenance (Mechanical Integrity) - Equipment inspections, testing, and preventative maintenance activities are scheduled according to manufacturers' recommendations and/or The Chlorine Institute.  The inspections, testing , and preventative maintenance are conducted per contract with a qualified chlorine equipment service company. 
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. 
Compliance Audits - A PSM audit was performed in 2000.  Findin 
gs from the audit are being addressed. 
Incident Investigation - An incident investigation policy and procedure has been developed to help 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 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 chlorine system. 
Hot Work Permit - A hot work permit program has been developed and implemented for hot work conducted in and around the chlorine 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 chlorine that meet the RMP accident criteria in the last five years. 
7.  Emergency Response Program 
The Hillsd 
ale plant has an emergency response program which is described in the site Emergency Response Plan (ERP).  This plan includes procedures for evacuations, notifying response agencies and adjacent businesses and neighbors, emergency equipment list, and procedures for responding to any release that may occur.  The plan also includes first aid procedures for toxic exposures to chlorine.  The ERP is coordinated with the Hillsdale City Fire Department and the Hillsdale County LEPC.  Members of the city Fire Department have visited and toured the facility. 
The facility has developed an employee hazardous materials response team.  Hazardous materials response training with flour mill operators and members of the city Fire Department has been completed. 
The facility previously conducted risk management plan communication meetings with employees and held a public communications meeting on January 5, 2000.  Pillsbury will be notifying immediate offsite receptors and intends to conduct another p 
ublic communication meeting in cooperation with the Hillsdale City Fire Department and the Hillsdale County LEPC. 
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 updated PHA and compliance audit are being addressed.  A new chlorine detector and monitor with multiple points of detection is being considered for the chlorine process areas.  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 chlorine system according to The Chlorine Institute standards and guid 
elines, 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 chlorine 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 the information in this Risk Management Plan is communicated to the local community.
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