ADM Corn Processing - Cedar Rapids - Executive Summary |
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EXECUTIVE SUMMARY A. It is the policy of the Archer Daniels Midland Company (ADM) Corn Processing Facility, Cedar Rapids, Iowa to implement the requirements of the Risk Management Program (RMP) in accordance with the USEPA regulations under 40 CFR Part 68. The objective is to prevent a release of anhydrous ammonia, chlorine, or anhydrous sulfur dioxide and in the unlikely event of a release to minimize the potential impact to ADMs employees, the public, and the environment. This objective will be accomplished by utilizing good operating procedures, maintaining a preventative maintenance program, providing appropriate training to employees, and coordinating response activities, as necessary with the Cedar Rapids Fire Department. B. Stationary Source and Regulated Substances Handled This facility consists of a Corn Wet Milling plant which processes corn into value added products such as corn sweeteners, fuel ethanol, and dry specialty products along with a Cogeneration plant that supplies the facilitys energy requirements. The regulated substances used at this facility are anhydrous ammonia, chlorine and anhydrous sulfur dioxide. Anhydrous ammonia is used at the Corn plant for regeneration of ion exchange resin and at the Cogeneration plant as a reagent to reduce oxides of nitrogen air emissions. Chlorine is used as a bacterial inhibitor in process cooling water. Anhydrous sulfur dioxide is used as a processing aid as well as a bacterial inhibitor. C. Off-Site Consequence Analysis To perform the required offsite consequence analysis, ADM used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance - revised April 1999, the Risk Management Program Guidance for Wastewater Treatment Plants - October 1998, and the DEnse GAs DISpersion (DEGADIS) Model Version 2.1. DEGADIS was utilized for the worst-case scenario and the EPA guidance documents were utilized for the alternative scenarios. Wo rst-Case Scenario: For multiple toxic substances subject to Program 3 requirements, the EPA requires that a worst-case scenario be evaluated for the toxic substance estimated to create the greatest distance in any direction to an endpoint. The worst-case scenario for substances that are normally gases at ambient temperatures but are liquefied by pressure assumes that the single largest container fails catastrophically and the entire contents are released as a gas over a ten-minute period resulting in offsite impacts. The worst case scenario for this facility involves a catastrophic release from an anhydrous sulfur dioxide railcar stored on site. Safe handling procedures, work practices and the safety devices inherent in the design of the containers make this scenario extremely unlikely. Alternative Scenario: EPA requires that one alternative scenario, or more realistic scenario, be evaluated for each toxic substance. EPA also requires that each alternative scenario resul t in off-site impacts, if such a scenario exists. A more realistic release scenario involving anhydrous ammonia would be a break in the line supplying ammonia from the storage tank to the process. Excess flow valves on the lines were considered as active mitigation in this analysis since they function to close when maximum allowable flow conditions exist. A more realistic release scenario involving anhydrous sulfur dioxide would also be a break in the line supplying liquid sulfur dioxide from the storage tank to the process. No active or passive mitigation measures were considered for this scenario. A more realistic release scenario for chlorine involves the rupture of the flexible connections (pigtails) connected to a one-ton container. No active or passive mitigation measures were considered for this scenario. D. Accidental Release Prevention The key concepts in this facility's prevention programs are the elements of OSHAs Process Safety Management Program under 29 CFR 1910.119, which all of this facilitys RMP processes are subject to. These concepts include: employee participation, analysis of hazards, operating procedures and safe work practices, personnel training, maintenance and mechanical integrity programs, and contractor programs. E. Five-Year Accident History This facility has not had any accidents involving anhydrous ammonia, chlorine or anhydrous sulfur dioxide that require reporting under EPAs Risk Management Rule. F. Emergency Response Program Emergency response at this facility is coordinated with ADM personnel and the City of Cedar Rapids Fire Department so that in the event of an accident, immediate emergency response measures will be implemented. The facility maintains a written Environmental/Emergency Response Plan to deal with prevention of and response to accidental releases of hazardous materials. The facility is also an active member of the Linn County Local Emergency Planning Committee. G. Planned Chan ges to Improve Safety As a result of a safety review of this facility's anhydrous ammonia, chlorine, and anhydrous sulfur dioxide systems the following change is planned to improve safety. Excess flow valves are being added to all process lines connected to the anhydrous sulfur dioxide tanks to minimize a release if a process line is broken. There were also several recommended actions that were completed as a result of the process hazard analyses. ADM will continue to evaluate and implement changes when necessary to improve safety at the Cedar Rapids facility. |