Cargill, Inc - Executive Summary

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Cargill Inc. owns and operates a wet corn milling facility in Dayton, Ohio which is subject to U.S. EPA regulations governing Accidental Release Prevention Requirements: Risk Management Programs (RMP) under Section 112(r) of the Clean Air Act (40 CFR Part 68).  This Risk Management Plan has been developed in accordance with the requirements specified under 40 CFR Part 68, Subpart G.  The Risk Management Plan certifies that Cargill Corn Milling Division has instituted a Risk Management Program at the Dayton, Ohio facility that is in compliance with U.S. EPA RMP requirements.  
The Risk Management Plan follows the format provided by the RMP Data Elements published by U.S. EPA.  In addition to identifying the applicable corporate policies and risk management systems, including comprehensive accident prevention and emergency response programs, the Risk Management Plan identifies a set of worst case and  
alternative release scenarios and the facility's five year accidental release history.  The Risk Management Plan also verifies that prevention, mitigation, and emergency response plans are appropriately designed to minimize risks to workers and the potentially affected public.   RMP Data Elements are included as part of this Risk Management Plan. 
1.1 Corporate Statement 
Cargill's policy is to conduct all business activities in a manner that protects the environment and the health and safety of our employees, contractors, customers and the public. 
Environment.  Cargill will comply with all applicable laws and regulations; promote waste reduction, resource and property conservation and environmental protection; and train employees to be knowledgeable about all environmental matters relevant to their work. 
Health and Safety.  Cargill will design, construct, maintain and operate facilities to protect human and physical resources; provide and require use of adequate protective equipment 
and measures, and insist that all work, however urgent, be done safely. 
Food and Product Safety.  Cargill will provide safe food, feed, and materials for people and animals by using production, storage and transportation facilities that ensure the safety of products; choose suppliers that meet our requirements for safe raw materials and ingredients; and provide employees the training and resources they need to meet their individual responsibilities. 
The Cargill Foods Corn Milling Division plant in Dayton is designed, maintained and operated so as to minimize adverse impacts to its employees, local communities and the environment.  In order to insure the safe and effective response to an unlikely emergency in the workplace, the Dayton plant coordinates its safety and emergency response program with the local community's emergency response personnel.  Plant management makes information available to the local community regarding the hazards and risks in operating the facilities and the 
prevention techniques in place.  This includes insuring that all regulatory reporting requirements are met. 
Plant personnel are fully informed as to the materials which are stored or used on-site and aware of the possible risk associated with their handling, storage, use, disposal or accidental release.  Material Safety Data Sheets (MSDS) for all materials utilized at the plant are maintained on-site and updated as new materials are brought onsite.  MSDS are also filed electronically with an outside vendor and can be accessed 24 hours a day via a toll-free number.  The plant maintains up-to-date procedures to insure the proper control of hazardous materials. Procedures and systems are devised which include provisions for the periodic testing, review, and update of the emergency response programs.  
Employees are trained and periodically retrained in the methods of detection of hazardous material releases, the potential physical and health risks associated with the materials, and meth 
ods for protecting themselves, co-workers, and the public.  The plant investigates, corrects, and reports in writing all incidents involving hazardous materials having caused, or having the potential for causing, injury or loss. 
Strict adherence to this policy is essential in reducing the risk of accidental releases of hazardous materials and in decreasing the likelihood of adverse impacts to Cargill's employees, the local communities and the environment. 
1.2 Risk Management System 
Cargill Food's Corn Milling Division's Dayton plant has developed a management system to oversee the implementation of the Risk Management Program in accordance with the requirements of 40 CFR Part 68, Subpart G.  The management system (shown in Figure 1-1) identifies job functions by responsibility level. 
Figure 1-1   Management Organization for Risk Management Plan 
                    Facility Manager 
                   Plant Superintendent     
Plant Emergency               Department           EHS Managers 
Organization Team               Sup 
                    Shift Managers  
Responsibilities of Plant Emergency Organization Team: 
- Development of facility Emergency Response Plan  
- Planning and execution of emergency drills  
Responsibilities of Facility Manager: 
- Oversight of facility Operation 
- Review and approve facility safety policies/programs 
- Facility spokesperson 
Responsibilities of Plant/Department Superintendents: 
- Implementation of Process Safety Management Program 
- Completion of incident investigations 
- Monitor compliance 
- Oversee and document maintenance 
- Management of change and pre-startup review 
- Department specific employee/contractor safety training 
- Compliance with facility safety policies/programs 
- Development of operating procedures 
Responsibilities of Shift Manager: 
- Incident Commander for emergency response 
- Management of various response teams (First Responders, 
  HAZMAT, Confined Space Rescue) 
Responsibilities of EHS Managers: 
- Develop/review facility safety policies 
- Oversee implementation of RMP 
- Develop/review facility PSM program/procedures 
- Oversee contractor safety program 
- Track new regulations 
- Monitor compliance 
- Oversee facility safety training programs 
The Cargill Foods Corn Milling Division plant in Dayton produces corn syrup, high fructose corn syrup, and other coproducts, such as gluten feed and meal, from the corn milling process.  The raw materials and process chemicals utilized by the plant are delivered via truck and rail from external sources. Access to the site by vendors, employees, and visitors is controlled by fencing and security checkpoints.  One of the chemicals utilized in the corn milling process at the Dayton facility is regulated under 40 CFR Part 68.   The Process department stores and maintains sulfur dioxide (SO2) that is present at or above threshold amounts for regulated substances. This department contains the only processes at the faci 
lity that are subject to the above regulation, which addresses the potential off-site hazards of accidental releases.   
The EPA Risk Management Regulation identifies three levels of requirements for industrial processes.  Program 1 can be applied to any process which has not had a "significant" release of a regulated substance over the five year period prior to the June 1999 compliance date and for which the worst-case release does not affect "public receptors" (e.g., residences, parks and recreation areas, commercial/industrial facility, hospitals).  Program 2 applies to any process that is ineligible for Program 1 and is not subject to Program 3.  Program 3 applies to all processes, such as those present at the Cargill Corn Milling Division facility, that are subject to the Occupational Safety and Health Administration (OSHA) Process Safety Management Standard (PSM). The Cargill Accident Prevention Program elements are adopted directly from the compliance program for the PSM standar 
d, consistent with the Level 3 RMP Program requirements for this Cargill facility under 40 CFR Part 68.  Program 3 related information for the Process department is included in the Data Elements section of the Risk Management Plan. 
2.1 Process Department 
The corn milling process at the Cargill Dayton facility is designed to extract useable starch and sugars from corn kernels in order to produce various end-products. The first step in the corn milling process involves steeping the corn kernels in water tanks, into which vaporized SO2 is injected. The SO2 and water form a dilute solution of sulfurous acid that helps to soften the kernel, breakdown proteins and remove soluble constituents. The steeped corn then travels through degerminating mills and separation processes designed to remove the germ and separate out the starch.  The starch slurry is then rinsed in water into which additional vaporized SO2 is injected.  This starch slurry is utilized in the production of corn syrup, high  
fructose corn syrup, and industrial grade starches.   
The Process department is responsible for the storage and transfer of sulfur dioxide (SO2) that is utilized in the corn milling process. The SO2 is stored in an exterior storage tank as a pure liquefied gas at ambient temperatures. The nominal capacity of the storage tank is approximately 174,000 lbs (14250 gal).  The maximum amount stored at any time is limited by operating procedures to 122,000 lbs (10,000 gal).  The storage tank is filled approximately 2-3 times/week via 42,700 lbs (3,500 gal) truck.  Access to the unloading area is limited by a chain barricade. 
For the purposes of developing and maintaining adequate Risk Management Plans, the EPA has defined in its governing rules and guidance a series of modeling methods and assumptions which are to be used as administrative guides for planning purposes.  In order to standardize and simplify the many factors that can potentially occur in an accident 
al release situation, some of these assumptions may not take into account the available preventive measures or mitigation methods that could diminish or even eliminate the implied risks that are suggested by "worst-case" analyses. For that reason, both the results for the standardized "worst-cases" defined by the EPA methods and a set of alternative cases which are believed by Cargill to more realistically represent situations that may possibly, but rarely, occur within the lifetime of the facility are also presented. The sections of the Risk Management Plan which discuss both worst-case, and alternative cases, are meant to provide the data necessary to develop and evaluate possible improvements in the overall safety programs of the Cargill RMP program.  
3.1 Worst-Case Release for Toxic Substances 
The worst-case release scenario, as defined by 40 CFR Part 68, is a sudden release of the maximum amount of a stored regulated substance from a single vessel, regardless of whether several  
vessels are interconnected.  For materials such as SO2 stored at ambient temperatures it is assumed that the release occurs over a 10-minute period.  The regulated substance with the most extensive zone of influence, defined as the distance to specified "toxic endpoints", is considered the worst-case release for each facility. Only passive mitigation (e.g., dikes, enclosures) and administrative controls may be accounted for in the evaluation. 
EPA has established "toxic endpoints" for various chemicals based on the American Industrial Hygiene Association (ACGIH) Emergency Response Planning Guideline, Level 2 (ERPG-2), which protects individuals from health-threatening or escape-impairing injury.  The ERPG-2 is defined as: 
"the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to 1 hr without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take p 
rotective action." 
Given that the worst-case is a 10-minute release duration with a 10-minute averaging time, the actual hazard zone is typically overestimated by the ERPG-2. Within such a time period there are a number of emergency measures that can reduce or eliminate exposures to levels this high for an interval much shorter than an hour. 
The EPA's RMP Off-site Consequence Analysis Guidance (1999 Revised OCAG) lists a number of refined dispersion models that are available for off-site hazard assessment applications for risk management programs.  Sulfur dioxide has a molecular weight that is substantially greater than the ambient air.  Therefore, concentrated plumes of this substance resulting from accidental releases often display heavy-gas behavior.  In such cases, near-field dispersion is dominated by gravitational slumping of the plume and entrainment of air at the plume-air interface.  The Dense Gas DISpersion (DEGADIS) Model (Version 2.1) was developed by the U.S. Coast Guard 
and the Gas Research Institute to model dense gas releases and its use has been approved by the U.S. EPA.  The model is used to predict the dispersion of dense gases from ground level releases over flat, level terrain.  For these reasons, DEGADIS was used to model the worst-case release scenario. 
The 1999 Revised OCAG provides a basic approach to estimating endpoint distances based on an ambient air temperature of 770F.  However, the RMP rule requires that if dispersion techniques other than the OCAG are applied, the maximum daily temperature over the last three years be used.  A review of National Climatic Data Center (NCDC) climatological data for the National Weather Service reporting station at Dayton, OH,  indicated a recorded high temperature over the last three years of 960F.   
Under Section 68.22 (e), the RMP rule identifies "surface roughness" as a parameter to be specified in the hazard assessment. The surface roughness affects the amount of dispersion that occurs within a 
released plume and influences the distance to "toxic endpoint". The surface roughness used in determining the distance to "toxic endpoint" should be characteristic of the transport path of the plume from the release point to the endpoint distance.  'Urban' surface roughness indicates areas where there are many obstacles, such as industrial buildings or trees.  'Rural' indicates that there are no buildings in the immediate vicinity of a facility and that the terrain is generally flat and unobstructed.  In the vicinity of the Cargill Corn Milling facility, the aerodynamic surface roughness is clearly 'urban' in nature.  Therefore, an urban surface roughness of 100 cm was used in the dispersion modeling. 
In accordance with 40 CFR Part 68, the worst-case modeling is conducted assuming a very stable atmosphere with limited dispersion (F stability and 1.5 m/sec wind speed).  Analysis of three years of meteorological data from the National Weather Service at Dayton, OH indicates that these  
dispersion conditions occur approximately 7% of the time (or about 1.7 hours per day, on average).  The most predominant directions of transport are to the east and northeast.  
The "toxic endpoint" for SO2 is 0.0078 mg/L.  Since the resulting planning zone predicted for the "worst-case" SO2 toxic release potentially affects public receptors, regulated processes at the Cargill Corn Milling Division facility are subject to Program 3 requirements.  
3.1.1 Worst-Case Release: Sulfur Dioxide 
The 40 CFR, Part 68 prescribed worst-case scenario for the Dayton facility consists of a 10-minute gaseous ground-level release of 122,000 lbs of stored SO2, dispersed under atmospheric conditions of F stability and 1.5 m/sec wind speed.  The modeling results indicated the worst-case SO2 release would result in a distance to "toxic endpoint" of 7 miles.  The worst-case impact zone encompasses a resident population of approximately 340,000, based on the 1990 Federal Census, and estimated by applying EP 
A's Landview III program.  Public receptors were identified using 1:24,000 scale U.S.G.S maps, supplemented with comprehensive maps of the local Dayton area (Rand McNally, 1990, and DeLorme Street Atlas USA, Version 5).   The potential worst-case hazard zone includes schools, hospitals, prisons, public recreation areas, and industrial/commercial areas. No environmental receptors (defined as National or State parks, forests, officially designated wildlife sanctuaries, preserves, refuges, and federal wilderness areas) would be affected. 
Cargill notes that it is impossible to release 122,000 lbs of SO2 in 10 minutes because the amount of heat energy required to so rapidly vaporize the liquid SO2 would not be available.  If the storage tank were to breach, liquid SO2 would spill to the ground in a boiling pool.  If a hole were to form in the vapor space of the storage tank, the flashing vapor in the tank would cause the tank to auto-refrigerate, thereby gradually reducing the release rate 
with time.  However, Cargill evaluated this 10-minute release to comply with the noted regulation. 
3.2 Alternative Releases of Toxic Substances 
Alternative releases are intended to represent release scenarios that have a greater likelihood of occurrence than a worst-case release.  Alternative releases do not necessarily represent the types of releases that the PSM hazards analysis and/or accident history indicate would be most frequent, but rather a release that is somewhat more likely than the worst-case release and that generally still has the potential to affect off-site receptors. In accordance with the EPA's OCAG, a single alternative release scenario is reported for each regulated substance.  
Cargill performed a thorough review of the Process department, utilizing engineering plans, operational experience, and maintenance records, in order to determine alternative release scenarios that could potentially result in off-site impacts. Each scenario was evaluated and the scenario 
s most likely to occur and to result in off-site impacts were selected for modeling. In order to determine the most conservative off-site consequence estimates, Cargill has chosen to include in the Risk Management Plan the alternative release scenario that resulted in the greatest "toxic endpoint" distance for each regulated substance. 
In accordance with the RMP rule, alternative releases are modeled under typical (rather than worst-case) dispersion conditions.  The EPA OCAG default dispersion conditions are neutral atmosphere, with dispersion neither enhanced nor limited (D stability and 3 m/sec wind speed). A review of climatological data for Dayton, OH, confirmed that conditions of D stability and wind speeds of 3 m/sec and greater are typical of the area and therefore are suitable for the evaluation of alternative releases. Unlike the worst-case release (for which an instantaneous spill or 10-minute ground-level gas release is assumed), alternative scenarios can account for the ac 
tual release configuration, and account for both active and passive mitigation.  The alternative dispersion modeling was conducted using EPA's RMP Off-site Consequence Analysis Guidance (1999 Revised OCAG).   
3.2.1 Sulfur Dioxide 
The alternative SO2 release scenario that would result in the greatest off-site impact involves a break in the SO2 unloading assembly at the delivery truck. A break of this type would result in a hole in the unloading assembly of approximately 1.0 inches in diameter.  The pressurized release of SO2 through a hole of this size would result in two-phase flow (vapor and liquid) as the pressurized SO2 flashed to the vapor state.  The modeling showed that SO2 would be released at a rate of 1600 lbs/min.  It is conservatively assumed that the sulfur dioxide would then be dispersed as a heavy gas and the excess flow valve on the railcar would not engage.  Cargill has estimated that it would take an operator approximately 30 minutes to respond and shutdown the flow  
of SO2, resulting in a total release of 48,000 lbs.  This alternative SO2 release scenario is expected to be more representative of the maximum anticipated release at the facility than the "worst-case".   
The 1999 Revised OCAG indicates that under 'urban' conditions, the distance to "toxic endpoint" would be 0.6 miles.  The hazard impact zone encompasses an estimated residential population of approximately 260 persons, based on the 1990 Federal Census, and estimated in conjunction with EPA's Landview III database program.  Public receptors in the alternative impact zone include industrial/commercial areas.  No environmental receptors would be affected. 
Some processes subject to the Risk Management Regulation are also subject to Occupational Safety and Health Administration (OSHA) Process Safety Management Standard (PSM).  PSM governs the same processes and regulated substances at the site that are subject to 40 CFR Part 68.  Cargill has a PSM prog 
ram at the Dayton plant that includes the following elements: 
- Employee Training and Participation  
- Process Safety Information  
- Process Hazards Analysis  
- Operating Procedures  
- Training 
- Contractors 
- Pre-Startup Safety Review 
- Mechanical Integrity 
- Hot Work Permit 
- Management of Change  
- Incident Investigation 
- Emergency Planning and Response 
- Compliance Audits 
- Trade Secrets 
In conjunction with the current RMP and PSM programs in place at the Dayton plant, there is a standard management practice that requires internal reporting of unusual events, including those in which any abnormal emission of regulated chemicals is observed or suspected.  The incident information is reviewed and a determination is made as to whether a reportable quantity on any chemical listed as requiring reports to regulatory authorities is involved.  If so, the appropriate authorities are notified. 
During the past 5 years (June 1994 to June 199 
9), there has been no accident involving any RMP regulated substance that qualifies for reporting under 40 CFR Part 68.  This means that no accident has resulted in reportable on-site injury, off-site injury, emergency response, or damage to property or the environment. 
Cargill's Dayton plant has established an Emergency Action Plan that is designed to address foreseeable emergency situations at the facility and provide appropriate hazard and emergency preparedness information to employees, contractors, emergency response personnel, and the community.  Emergency situations can include fire, explosion, chemical release or spill, bomb threat, weather emergencies and other natural emergencies.  Due to the ongoing risks that are presented by weather emergencies like tornadoes, the plant has in place an emergency plan to protect both the plant operational integrity and the safety of its workers and neighbors from weather emergencies.  In regards to chemica 
l releases, Cargill has developed a command structure and specific procedures that must be adhered to in the unlikely event of a chemical emergency.  These procedures define the criteria for identifying, classifying, and notifying the appropriate emergency response staff of potential emergency events. If a chemical release is detected on-site, the emergency response team is notified and the most appropriate mode of response is determined by the Incident Commander with support from available local emergency response (HAZ-MAT) teams and technical advisory staff.  Each Department in the facility must also follow a specific Spill Prevention Countermeasure and Control Plan in the event of a chemical release.  
Plant operations at the Dayton facility can present various types of potential hazards and Cargill recognizes the need to have a well trained and prepared work force to safely and effectively deal with any emergency situation.  The Cargill Dayton facility provides training of responsi 
ble staff and the exercise of important communication links with the community, in order to maintain an appropriate state of readiness for emergency situations.  Cargill Dayton plant staff attend monthly safety meetings and have participated in emergency response training exercises.  Cargill "First Response" staff have the capability to administer basic first aid and CPR.  Cargill and local emergency response planning officials also rely on the Miami Valley Hospital to offer paramedical assistance and transportation to the hospital.  
Cargill's Dayton plant, under the recent RMP program, as well as its existing PSM and earlier SARA Title III Community Right-to-Know Act compliance programs has organized its management system to effectively address hazards and potential risks.  Both the advanced planning aspects of process design, operating procedures, and emergency preparedness, and the operational elements of system maintenance, safe operating 
practices and ongoing personnel training are necessary to support a continual improvement in facility safety.  These programs are documented so that information about the safe handling of chemicals present at the facility is available to all employees, and can be interpreted by emergency response team staff and the Incident Commander. This is especially important when questions arise from public safety officials regarding potential risks to the community.  All of these features of the RMP and the integrated risk management program at the Dayton plant lead to operations that are safe today, but will be even safer tomorrow. 
Cargill Dayton safety program incorporates continuous improvement through use of employee involvement and on-going evaluations of in-plant safety and program effectiveness.   
Risk Management Plan Executive Summary    June, 1999
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