Siemer Milling Company - Executive Summary |
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Accident Release Prevention Program and Emergency Response Policy It is the policy of facility management to implement the requirements of this Risk Management Program (RPM) in accordance with the USEPA regulations under 40 CFR Part 68 and with the corresponding regulations under OSHA's Process Safety Management (PSM) Program. The objective is to minimize the risk of a release of a hazardous material and if a release occurs, to minimize the potential to employees, the public and the environment. This objective will be accomplished by utilizing general good operating procedures, providing appropriate training to all employees, and coordinating response activities, as necessary, with the local emergency response providers. Management is committed to providing the resources necessary to implement this policy. Employee participation in the release prevention program is incouraged and supported by management. Key perssonnel are responsible for conducting and implementing the findings f rom the Process Hazard Analysis (PHA) for the chlorine system. Employees are also members of the facility emergency response team. The policy is to construct all new equipment, systems, and facilities in accordance with the most current building and safety codes. This ensures the appropriate safety and release prevention systems are included from the beginning of each project. We are committed to providing appropriate training to all employees regarding safety procedures. Each new employee is provided comprehensive safety training during his or her initial orientation for the facility. In addition, we conduct regularly scheduled safety training for all employees each year. Additional training is provided to maintenance personnel for the systems they are responsible for. Members of the plant emergency response team recieve annual training to ensure that response actions are promptly and saely completed. Facility Description This facility utilizes flour mills to produce flour. T he raw materials used in the processes are wheat and chlorine gas. Support operations include a chlorine system, a quality control laboratory, and administrative offices. One chemical is utilized at this facility, in sufficient quantities to be subject to the requirements of 40 CFR Part 68, RMP. The chemical is chlorine and is used to bleach or age the flour. Worst-Case and Alternative-Release Scenarios The worst-case release scenario for chlorine included a release of all the contents of one of the 2000 pound chlorine cylinders in a 10 minute period (per EPA guidelines), translating to a release of 200 lbs/min. Other assumptions included are: the cylinder is not diked; the release is mitigated by enclosure which reduces the release by 55%; the nearfield dispersion environment is urban; the wind speed is 1.5 m/sec. and the atmospheric stability is classified as F (stable); the plume must travel 3.5 miles before dispersing to the endpoint concentration of 3.0 PPM. The selected alte rnative-release scenario for the chlorine system is a release resulting from damage or rupture of the chlorine vapor line (pigtail) from the ton chlorine cyulinder to the chlorine manifold. The pigtail has an inside diameter of 3/8 inch. The alternative-release rate was derived by an equation including puncture area, tank pressure, tank temperature, and Gas Factor (EPA guidance document Appendix B, Exhibit B-1). From Reference table 17: Dense Gas Distances to Toxic Endpoint - 60 Minute Release, Urban Conditions, D Stability, Wind Speed 3.0 m/sec., resulted in the distance to the endpoint concentration of 0.0087 mg/l being 0.27 miles. Passive mitigation measure (enclosure) is in place and reduces the release by 55%. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The facility is goverened by a set of OSHA and USEPA regulations that require planning and facility activities intended to prevent a release of hazardous material, or if a release occu rs, to minimize the consquences of a release to the employees of the facility, the public, and to the environment. These regulations include: 40 CFR Part 68, Accidential Release Prevention 40 CFR Part 112, Spill Prevention, Control and Countermeasure 40 CFR Part 264, Hazardous Waste Contingency Plan 29 CFR Part 119, Process Safety Management The key concepts in our release prevention program are employee participation, appropriate design and maintenacne of equipment, and appropraite training of all employees. Five Year Accident History We have not had a release of chlorine that has affected the public or the environment. Emergency Response Program We have personnel trained in emergency response at the facility 24 hours per day, seven days per week. These personnel recieve annual training on emergency procedures and response techniques. Planned Changes to Improve Safety American Ingredients and Siemer Milling Company complete a thorough review of the chlorine systems each time a design change is implemented. The system is also evaluated each time the PHA is revised. We are committed to using these methjods to identify and implement ways to improve the safety of these systems. |