ConAgra Flour Milling Company - Executive Summary

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Risk Management Plan (Subpart G) 
Executive Summary (' 68.155) 
Accident Release Prevention Program and Emergency Response Policy 
It is the policy of 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  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. 
Stationary Source and Regulated Substance 
This facility utilizes processes raw wheat to produce flour. The 
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 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 as well as reducing the microbial impact of the water used in tempering the wheat prior to milling. 
Worst-Case and Alternative-Release Scenarios 
The worst-case release scenario for a chlorine release is 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 characterized 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 1.3 miles before dispersing to the endpoint concentration of 3.0 parts per million (PPM). 
The selected alternative-release scenario for the chlorine system is a release resulting from damage or rupture of the chlorine vapor line (pigtail) from the ton cylinder to the chlorine manifold. The pigtail has an inside diameter of 3/8 inch. The operating pressure of the cylinder is 150 psig. The alternative-release rate was determined to be 30.5 pounds per minute for 60 minutes. The results of the alternative assessment show that the chlorine will travel 0.1 miles before dispersing to the endpoint concentration of 3.0 ppm. 
Accidental Release Prevention Program and Chemical Specific Prevention Steps 
Employee participation in the release prevention program is encouraged and supported 
by management. Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the chlorine system. Only trained and authorized employees or contractors are allowed to perform work on or adjacent to the chlorine system.  
The policy is to construct all new equipment, systems, and facilities in accordance with the most current building and safety codes, as well as conforming to the recommendations of the Chlorine Institute. 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 the safety and health consideration of chlorine. Also, each new employee is provided comprehensive safety training during his or her initial orientation for the facility. In addition, we conduct annual safety training for maintenance and system operators specific to the handling and maintenance of the chlorine system.  
Five Year Accident History 
We have not had a release of chlorine that has affected the public or the environment. 
Emergency Response Program 
Due to the proximity of local responders, we have instituted a "No Response" program. That is, direct contact with appropriate responders is available 24 hours a day, seven days a week. System reviews and emergency action plans have been discussed and reviewed with the local responders and will be reviewed annually for the life of the process.  
Planned Changes to Improve Safety 
ConAgra Flour Milling Company and the American Ingredients Company (supplier) 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 methods to identify and implement ways to improve the safety of these systems.
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