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 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 plant has also developed a Process Safety Management (PSM) program to comply with OSHA PSM requirements. 2. Stationary Source Activities The plant 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 to cool and freeze the finished products. 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 lost 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 12,000 pounds of ammonia. Ammo nia 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 4,400 pounds (87.5% at 70F) 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 wo uld 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 mentioned in the Ammonia Model RMP, the alternate ammonia scenario would be representative of a gasket or valve packing. 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. Recommendations made by the PHA team to improve safety are 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. 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 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 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 ammon ia system. Hot Work Permit - A hot work permit program has been developed and implemented. 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 During normal workday operation, the facility emergency response plan consists of employee notification (alarm) and evacuation, followed by notification of the Atlanta Fire Department (closest station to Pillsbury is Station 34 located at 3671 Southside Industrial Pkwy.) by dialing "9-1-1". A facility emergency evacuation plan has been prepared and disseminated to facility personnel. The Pillsbury Company does not have HAZMAT trained personnel on site, instead, Unitemp's HAZMAT team would respond by calling (770) 242-9812 if an ammonia release were to occur. The Atlanta HAZMAT is also available for response, however, they do not provide incident commanders nor do they provide cleanup services. Reference: Levon, McCord, Atlanta Emergency Management Agency, (404) 730-5600. 6.2 Red Cross shelter resources in the Atlanta area consist of pre-arranged service agreements with local schools and some local churches. Schools and churches that would serve as a Red Cross shelter would have food, cots, and first aid supplies on site and reserve supplies could be shipped in. An emergency management official (HAZMAT Team, Fire Department, Police Department, etc.) would decide if sheltering in place or evacuation and sheltering is required in a given emergency and would then direct the Red Cross to activate the shelter(s) determined to be located at a safe distance from the hot area, if needed. Those in need of medical attention would be taken to a nearby hospital. Reference: American Red Cross Office of Metropolit an Atlanta Website: www.redcross.org/atlanta/. 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 of the ammonia system 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. |