General Mills, Inc. - Executive Summary |
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EXECUTIVE SUMMARY Accident Release Prevention Program and Emergency Response Policy It is the policy of the General Mills Operations, Inc. (GMOI), Johnson City, Tennessee, facility management to implement the requirements of this Risk Management Program (RMP) 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 impact to GMOI 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. GMOI management is committed to providing the resources necessary to implement this policy. Facility Description The GMOI facility utilizes flourmills to produce flou r. The raw materials used in the processes are wheat and chlorine gas. Support operations include a grain elevator system, a quality assurance/control laboratory, and administrative offices. Figure 1-1 shows the site location. Figure 1-2 shows the site plan. One chemical is utilized at the 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 Chlorine The worst-case release scenario for a chlorine release included a release of all the contents of one of the 2,000-pound chlorine cylinders in a 10-minute period (per EPA guidelines). This release translates to a release of 2,000 pounds of chlorine in 10 minutes or 200 pounds/min. Other assumptions included in the worst-case assessment are: the chlorine is a liquefied gas; the cylinder is not diked; the release does not take place indoors; the nearfield dispersion environment is character ized as urban; 10-minute averaging period; the wind speed is 1.5 meters/sec, and the atmospheric stability is classified as F (stable). The results of the worst-case assessment for chlorine show that the plume must travel 3.23 miles before dispersing to the endpoint concentration of 3.0 parts per million (ppm). Figure 1-3 shows the worst-case release radius. The selected alternative-release scenario for the chlorine system is a release resulting from a flour plug on the inlet side of the flour agitator. The plug prevents flour from entering the agitator which results in the loss of the flour seal on the discharge side of the agitator. The chlorine is released on the fifth floor of the mill building as a vapor. The release rate is a maximum of 21.9 lb/hour (0.365 lb/min). The release radius is calculated using the log-log equation for urban conditions. D = 0.878 (QR)0.5134 D = Distance in miles QR = Release rate in lb/min Therefore: D = 0.878 (0.365)0.5134 = 0.52 miles The di stance to the endpoint concentration of 0.0087 mg/l is 0.52 miles. Figure 1-4 shows the alternate case release scenario radii. No active or passive mitigation measures are currently in place. The meteorological data used for this alternative release scenario was a wind speed of 3 meter/sec, an atmospheric stability classification of D (neutral stability), and an urban dispersion environment in the nearfield. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The Johnson City facility is governed 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 inadvertently occurs, to minimize the consequences of a release to the employees of the facility, the public, and to the environment. These regulations include: * 40 CFR Part 68, Accidental Release Prevention * 29 CFR Part 119, Process Safety Management The key concepts in GMOI release prevention program are employee participation, appropriate design and maintenance of equipment, and appropriate training of all employees. Employee participation in the release prevention program is encouraged and supported by GMOI management. Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the chlorine system. GMOI employees are also members of the facility emergency response team. GMOI 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. GMOI is committed to providing appropriate training to all employees regarding safety procedures. New employees are provided comprehensive safety training during their initial orientation for the facility. In addition, GMOI conducts regularly scheduled safety training for all employees each year. Additional t raining is provided to maintenance personnel for the systems they are responsible for. Five Year Accident History GMOI has not had a release of chlorine from Johnson City that has affected their employees, the public or the environment. Emergency Response Program GMOI does not have emergency response capability at this facility. GMOI has 24-hour security staff that monitors the alarm system and notifies the local HazMat team (911) in the event of an emergency. Planned Changes to Improve Safety GMOI and American Ingredients, Inc. completes 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. GMOI is committed to using these methods to identify and implement ways to improve the safety of these systems. GMOI will reroute the overpressure vent line to the roof of the chlorine building, and will mark all chlorine lines inside the plant as required. Management Systems Figure 1-5 shows the organi zation at the Johnson City facility that is responsible for implementation of the PSM Plan and the Risk Management Plan. |