Kerry Inc. DCA Bakery Division - Hillsdale - Executive Summary |
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Kerry Inc. DCA Bakery Division is a manufacturing facility of food and feed products. The facility handles chlorine, which is considered hazardous by the EPA. It is necessary to observe certain safety precautions when using and handling chlorine, to reduce the threat to the health of our employees and nearby members of the community. It is our policy to adhere to all applicable Federal and state rules and regulations. Our emergency response program has been coordinated with local emergency services and includes standard operating procedures in the event of a release. Kerry Inc. DCA Bakery Division is a prepared bakery mix plant and flour mill located at 101 East Bacon Street. Chlorine is used in the flour milling process: - To treat the finished flour to enhance color and baking performance. The reaction of raw flour and chlorine is complete within normal application rates. There are no byproducts or waste products created in the reaction. The end product is flour for human consumption. - To reduce the bacteria and spore flora on the whole wheat kernel to acceptable levels through the use of water chlorinators. There is no excess solution discharged or waste products given off under normal conditions. A maximum total inventory of chlorine on site is 24,000 pounds. This situation is very unusual with 16,000 pounds of chlorine being the norm. The worst case scenario would be the rupture of a 2,000 pound storage vessel (one (1) ton container) of chlorine. It is assumed that the entire contents are released as a vapor, which is heavier than air. The distance to the endpoint of 0.0087 mg/L (3 ppm) is 0.9 mile. The release occures inside the facility building. Chlorine containers are offloaded from the transportation vehicle directly to the inside of the building. The alternate release scenario involves the rupture of a 3/8" flexible metal pipe. It would take 95 minutes to empty the 2000 pound container from this rupture. The distance to the end point of 0.0087 mg/L (3 ppm) is 0.1 mile. The release would occur inside the facility building, inside the vessel storage room. A chlorine detector is located within this room and would monitor the release and sound an alarm. Mock scenarios of this type of release during normal working hours have mitigated the release in 15 minutes. This facility is in compliance with the OSHA PSM rule (Process Safety Management) and the EPA RMP rule (Risk Management Program). The facility is operated in accordance with the recommendations from the Chlorine Institute. A chlorine detector is located in the chlorine vessel storag area. The detector monitors for low levels of chlorine, so that mitigation can occur before a major release. A visual alarm for this detector is located on the alarm panel in the 3rd floor control room. Associated with the visual alarm is an audio alarm that can be heard throughout the milling facility. An audio alarm is also located on the exterior of the building. The chlorination system in place reduces the gas pressure from the storage vessel to near zero (0). This allows the system to operate in a vacuum situation. If a release does occur in the chlorine piping the flow of chlorine is shut off. This action reduces the amount of the release. There have been no accidental releases of chlorine in the last five (5) years. An emergency response program with standard operating procedurs has been coordinated with local emergency services. Members of the City Fire Department have visited and toured the facility. The facility is continually looking for ways to improve the safe handling of chlorine. Annual training is provided to employees in the safe handling of chlorine, the chlorine system, and emergency response. |