Toledo Flour Mill - Executive Summary

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ATTACHMENT A 
EXECUTIVE SUMMARY 
NABISCO, INC. - TOLEDO, OH FACILITY 
 
1.0 INTRODUCTION 
 
A Risk Management Program (RMP) has been implemented at Nabisco for the reduction of accidental releases of hazardous materials. The RMP summarizes the management, administrative, procedural, and technological controls that work together to minimize the risk to the community of hazardous chemical releases. The Risk Management Plan is organized to correspond with specific U.S. Environmental Protection Agency (EPA) RMP definitions and requirements, including: 
 
7 Introduction; 
7 Nabisco policies to protect health, environment, and safety; 
7 Facility identification and regulated substances covered processes; 
7 Hazard Assessment; 
7 Prevention Program; 
7 Five-Year Accident History; 
7 Emergency Response Plan; and 
7 Planned changes to improve safety. 
 
2.0 NABISCO POLICIES TO PROTECT HEALTH, ENVIRONMENT, AND SAFETY 
 
Risk management and safety are important concerns at Nabisco; this RMP formalizes and documents 
these activities. Nabisco is committed to conducting its operations in a safe and responsible manner and to reducing risks to human health and to the environment. 
 
3.0 FACILITY IDENTIFICATION 
 
The Nabisco facility is located at 2221 Front Street in Toledo, Ohio. The facility is a flour mill and uses chlorine in its bleaching system and wheat temper water chlorination system.  Chlorine use at the flour mill is regulated under 40 CFR Part 68, the EPA RMP Rule. The amount of chlorine present at the mill is approximately 16,000 pounds, which is above the minimum threshold quantity of 2,500 pounds.   
 
4.0 HAZARD ASSESSMENT - WORST CASE SCENARIOS (WCS) 
 
The worst-case toxic accidental release scenario is a catastrophic failure of the single largest vessel containing chlorine.  This vessel is capable of storing the 2,000 pounds of chlorine.  EPA's RMP*Comp computer model estimates that, under the worst-case weather conditions and a 10-minute release period, the worst-case release could trave 
l 1.3 miles downwind until the toxic endpoint of 3 parts per million (ppm) is reached.  
 
5.0 HAZARD ASSESSMENT - ALTERNATIVE RELEASE SCENARIOS (ARS) 
 
An ARS was modeled for chlorine in the hazard assessment. The ARS for chlorine assumes the failure of a fusible plug (safety relief valve) resulting in the release of the contents of the tank over a period of 3.3 minutes through a =-inch hole in the tank.  The release is estimated to go 0.3 miles until the toxic endpoint of 3 ppm is reached.  
 
6.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM 
 
A prevention program is in place to minimize the risk of hazardous chemical releases in accordance with the OSHA Process Safety Management (PSM) standard (29 CFR 1910.119) and the EPA Risk Management Program. This prevention program covers those processes that handle chlorine above the threshold quantity for either PSM or RMP rules.  
 
The prevention program provides a structured approach to preventing accidents. Some of the specific activities in th 
e prevention program include: 
 
7 Process safety information is provided to all employees upon hire and is accessible at all times. 
7 In-depth process hazard analyses are completed every five years by qualified personnel using techniques approved under the PSM standard. 
7 Written operating procedures (kept up-to-date) are used for training and guiding the work of operators. 
7 Training is provided to all employees upon hire, and refresher training is given annually or upon request. 
7 Operators, mechanics, and contractor personnel are qualified, trained in the general hazards in the facility, and informed of any temporary situations affecting safety. 
7 Pre-startup safety reviews are conducted to insure that conditions for safe operation have been satisfied prior to starting new or modified equipment. 
7 A program is in place to maintain the mechanical integrity of the process, which includes written procedures, training requirements, equipment deficiency requests for employees, work orders 
, scheduled maintenance, and computerized documentation. 
7 A hot work permit system assures that work is done safely and properly. 
7 A management of change system is in place to ensure that changes are managed safely. 
7 Incidents are investigated and actions are taken as part of a continuous improvement effort. 
7 Routine audits are conducted to assure that safe practices are being followed. 
 
This systematic approach to process safety at Nabisco involves employees and strives for continuing improvements in overall safety. The training, qualifications, and safety awareness of our operations, maintenance, and management personnel are a key element in reducing and mitigating accidents. 
 
7.0 FIVE-YEAR ACCIDENT HISTORY 
 
There has been no accidents/releases of chlorine at Nabisco that meet specific EPA criteria for the Five-Year Accident History.  
 
8.0 EMERGENCY RESPONSE PLAN 
 
Nabisco has an emergency response plan to ensure that in the event of an emergency the personnel are aware of the app 
ropriate actions to take and authorities to contact in order to mitigate the effects of a release.  Response activities are coordinated with the Lucas County Emergency Management Agency. 
 
9.0 PLANNED CHANGES TO IMPROVE SAFETY 
 
Chemical safety is an important part of Nabisco operations.  Nabisco recently conducted an audit of their Process Safety Management program and will be dutifully implementing the recommendations from that audit.  Continuous improvement in safety is an important goal for Nabisco.
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