The Pillsbury Company - Hazelwood - 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 Hazelwood in St. Louis County, Missouri. The plant was built in 1996, and acquired by Pillsbury in 1999. The plant produces baked goods and frozen dough for retail sale. The ammonia refrigeration process is used to cool and freeze the finished goods.  
3.  Regulated Substances Handled 
The ammonia for the refrigeration system at the Hazelwood 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 inventor 
y of 10,500 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 6,500 pounds (83.5% at 80F) 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 cho 
sen 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. 
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 Hazelwood Plant ammonia 
system, Pillsbury followed the ANSI/IIAR 2-1992 Standard for Equipment, Design, and Installation of Ammonia Mechanical Refrigeration Systems and 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, the equipment and the technology of the process. 
Process Hazards Analysis (PHA)- A PHA was conducted to satisfy the PSM requirements in 1998. Recommendations made by the PHA team to improve the safety of the systems have been addressed. 
Operating Procedures - There are detailed written operating procedures for the ammonia system and for safe work practic 
Training - There is a five-tier training program that all employees who are involved with the ammonia system must attend and demonstrate understanding of before they are certified to operate the system.  
Maintenance - All of the covered ammonia equipment is included in the preventive maintenance program. Equipment inspections, testing and preventive maintenance activities are performed following a structured schedule. 
Management of Change (MOC) - An MOC procedure has been developed and is implemented for all changes made to the ammonia system, including the safety systems.  
Pre-startup Review (PSR)- Pre-startup reviews are conducted whenever a change results in a change to the PSI.  
Compliance Audits - A compliance audit was conducted in 1997. All findings from the audit have been addressed. 
Incident Investigation - The Pillsbury Company routinely investigates any ammonia related incident or accident. An Incident Investigation procedure has been developed to help the investi 
gation team determine the root cause of an incident and to help them develop measures to prevent recurrence.  
Employee Participation - Employee involvement and feedback have been used to formulate the process safety management program. 
Hot Work Permit Program - A hot work permit program is being used at the Hazelwood Plant whenever hot work is conducted in and around the ammonia systems.  
Contractor Safety - A contractor qualification program is in place and includes reviews of contractor performance and the inclusion of safety performance and programs in selecting contractors for work on or adjacent to the ammonia process. 
6.  Five-Year Accident History 
There have been no releases of ammonia that meet the RMP accident criteria since the plant was started-up in 1996.   
7.  Emergency Response Program 
Pillsbury Bakery has an emergency response program in place which includes a chain of command, a emergency response decision tree, and a notification plan.  Efforts are coordinated  
with the Hazelwood Fire Department and their notification is assured in the event of an emergency.  Emergency response teams have been assembled and emergency response coordinators have been named with members of each having specific responsibilities.  Included in the program is protocol for informing all necessary emergency response teams.  Notification and communication can be made via intercom, telephone, or two way radio.  Evacuation plans and procedures have been put in place as well.  In addition, periodic reviews of the emergency response plan are made in order to assure that the plan best suits the needs of the plant. 
8.  Planned Changes to Improve Safety 
All recommendations from previous PHAs, MOCs, and PSRs have been addressed. However, 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 du 
ring 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.
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