A.E. Staley Manufacturing Company-Lafayette South - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES We at A.E. Staley Manufacturing Company-Lafayette South are strongly committed to employee, public, and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. THE STATIONARY SOURCE AND THE REGULATED SUBSTANCES HANDLED Our facility's primary activities encompass the manufacture of sweeteners and corn syrups utilizing the corn wet milling process. We have two regulated substances at our facility. These substances include Chlorine and Sulfur Dioxide (anhydrous). Chlorine is used in two different processes: chlorine controls microbial growth in a cooling tower and chlorine disinfects well water for potable use. Sulfur Dioxide (anhydrous) is used to control microbial growth during the corn steeping process and also weakens the starch-gluten bonds so the separation process following steeping is more efficient. The maximum inventory of Sulfur Dioxide at our facility is 89,000 lb. The maximum inventory of Chlorine at our facility is 8,000 lb in the well-field and 8,000 lb at the cooling tower. THE WORST CASE RELEASE SCENARIO AND THE ALTERNATE RELEASE SCENARIOS To evaluate the worst case scenario and the alternate release scenarios we have used EPA's RMP Guidance for Waste Water Treatment Plants, "Pamphlet 162: Generic Risk Management Plan for Chlorine Packaging Plants and Sodium Hypochlorite Production Facilities" prepared by the Chlorine Institute and EPA's RMPComp computer software. The following paragraphs provide details of the chosen scenarios. The WORST CASE RELEASE SCENARIO submitted involves a catastrophic release from the Sulfur Dioxide tank. In this scenario 89,000 lb. of Sulfur Dioxide (anhydrous) is released as a gas liquefied by pressure that evaporates completely over 10 minutes. At class F atmospheric stability, 1.5 m/s windspeed, and urban topography the maximum distance of 10 miles is obtained corresponding to a toxic endpoint of 0.0078mg/L. THE SULFUR DIOXIDE ALTERNATE RELEASE SCENARIO involves the break of the 1-1/2" transfer line between a Sulfur Dioxide truck and the bulk Sulfur Dioxide tank. The scenario involves the release of 11,250 lbs. of Sulfur Dioxide as a gas liquefied by pressure. The existing controls prevent bulk tank losses. The operator and the truck driver monitoring the truck unloading will require 30 minutes to stop the release. The toxic gas liquefied by pressure will be released to the atmosphere with no passive mitigation to control the release rate. Under neutral weather conditions of class D atmospheric stability and 3 m/s wind speed and assuming urban topography the maximum distance to the toxic endpoint of 0.0078 mg/L of Sulfur Dioxide is 0.4 miles. BOTH CHLORINE ALTERNATE RELEASE SCENARIOS involve a failure of the 5/16 inch liquid valve on the Chlorine cylinder. The scenarios involve the release of the entire 2,000-lb contents of the cylinder over 16 minutes. The toxic gas liquefied by pressure will be release to the atmosphere with no controls to minimize the release. Under neutral weather conditions of class D atmospheric stability and 3 m/s wind speed and assuming urban topography the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.2 miles. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE CHEMICAL-SPECIFIC PREVENTION STEPS Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-30 Standard, 1957 edition. Non-combustable chemical storage systems were designed and are maintained in conformance with ap plicable ASME standards, ANSI standards and chemical supplier recommendations. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. PROCESS SAFETY INFORMATION-A.E. Staley Manufacturing Company-Lafayette South maintains a record of safety information that describes the chemical hazards, operating parameters, and equipment design associated with all processes. PROCESS HAZARD ANALYSIS-Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is the What If Scenarios. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at regular intervals. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA review for the Sulfur Dioxide system was performed February 1 4, 1997. The most recent PHA review for the Chlorine system was performed on October 25, 1994. OPERATING PROCEDURES-For the purposes of safely conducting activities within our covered processed, A.E. Staley Manufacturing Company-Lafayette South maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operation, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup after a maintenance shutdown. The information is regularly reviewed and is readily accessible to operators involved in the processes. TRAINING-A.E. Staley Manufacturing-Lafayette South has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided as needed. MECHANICAL INTEGRITY-A.E. Staley Manufacturing Company-Lafayette South carries out documented maintenance checks on pro cess equipment to insure proper operations. Process equipment examined by these checks includes: pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Qualified personnel carry out maintenance operations with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. MANAGEMENT OF CHANGE-Written procedures are in place at A.E. Staley Manufacturing-Lafayette South to manage changes in process chemicals, technology, equipment, and procedures. The most recent review/revision of maintenance procedures was performed December 15, 1998. Process operators, maintenance personnel, or any other employee whose job task are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. PRE-START UP REVIEW-Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at A.E. Staley Manufacturing Company-Lafayette South. These reviews are conducted to confirm that construction, equipment, operating, and maintenance procedures are suitable for safe startup prior to placing equipment in operation. COMPLIANCE AUDITS-A.E. Staley Manufacturing Company-Lafayette receives corporate audits on a regular basis to determine whether the provisions set out under the PSM rule and RMP rule are being implemented. The most recent compliance audit was conducted December 9, 1997. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. INCIDENT INVESTIGATION-A.E. Staley Manufacturing Company-Lafayette South promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a r egulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. EMPLOYEE PARTICIPATION-A.E. Staley Manufacturing Company-Lafayette South truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analysis. CONTRACTORS-Our company hires contractors to conduct specialized and routine maintenance and construction activities. Long term relationships have been established with the contractors that work on a routine basis. All contract personnel are required to have site specific trainin g. This contractor training must be documented before a contractor worker is allowed on the job site. The contractor safety representative meets with an A.E. Staley Manufacturing Company-Lafayette South representative regularly. The contractor notifies A. E. Staley Manufacturing-Lafayette South about any incident involving a near miss, accident, or injury of contract personnel. A.E. Staley Manufacturing-Lafayette South keeps copies of the entire meeting notes and incident investigation reports to document past safety performance. A.E. Staley Manufacturing Company-Lafayette South has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. FIVE YEAR ACCIDENT HISTORY A.E. Staley Manufacturing Company-Lafayette South has had an excellent record of preventing accidental releases ove r the last 5 years. Due to our stringent release prevention policies, there have been no accidental releases during this period. EMERGENCY RESPONSE PLAN A.E. Staley Manufacturing Company-Lafayette South carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan in promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Tippecanoe County Emergency Planning Committee is the Local Emergency Planning Committee with which our emergency plan has been coordinated and verified. |