Penford Products Co. - Executive Summary
PENFORD PRODUCT CO. |
Risk Management Plan
Penford Products Co. (Penford) is committed to operating its business in a manner that is safe for its workers, the public, and the environment. As part of this commitment, Penford has established a comprehensive safety, health, and environmental management process to help ensure safe operation of the processes at this facility. One part of this process is a Risk Management Program (RMP) that helps manage the risks at Penford and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at Penford. This document is intended to satisfy the RMPlan requirements of the RMP rule and to provide the public with a description of the program.
Accidental Release Preventio
n and Emergency Response Policies
Penford is committed to the safety of its workers and the public, the preservation of the environment, and the prevention of accidental releases of hazardous substances. Penford has made significant investments in process equipment, safety systems, and personnel to ensure the safety of its operations, minimize its impact on the environment, and prevent releases from occurring. This commitment is clearly stated in Penford's Environmental, Health, & Safety Policy, and reinforced as a critical element in employee performance appraisals and the profit sharing plan. Evidence of that commitment include improved safety performance, reductions in wastewater discharges, and a 50% reduction in emissions over the past 5-years; all during a period when production has increased dramatically. A well-qualified Environmental, Health, & Safety (EHS) staff, a highly competent in-house engineering group, and a committed senior management team ensure process safety i
s given the highest priority.
Penford is also well prepared to respond to and contain a release if one should occur. Penford maintains trained emergency response coordinators on-site at all times, with additional resources on-call. Active participation on the Local Emergency Planning Committee (LEPC) and regular interface with the fire department and other response agencies ensure a large team of experts is ready to respond should they be needed. Familiarity with Penford's processes and chemicals, established response plans, and extensive training ensure local emergency agencies can provide the community support if needed.
Chemical Processes and Regulated Substances
Penford is a corn wet milling industry whose primary business is the manufacture of specialty carbohydrate based products for the paper and textile industries. Penford Products is headquartered in Cedar Rapids, Iowa, and is a full-line, value added supplier - from research and development to commercial products for t
he wet end, size press and coater in papermaking applications. Penford has been in this location for over 100 years and today is considered an innovative leader in carbohydrate technology by the papermaking industry both in the United Stated States and throughout the world.
In the manufacture of its specialty carbohydrate based products, Penford uses several chemicals listed by the RMP rule as regulated substances which are stored on site above the EPA threshold quantities. These substances are sulfur dioxide, ethylene oxide, 1,3-butadiene, and chlorine.
Sulfur dioxide is stored for use in the Corn Wet Milling Process. In this process a small quantity of sulfur dioxide in a water medium is added to large tanks containing shelled corn. The corn kernels are steeped or soaked in this slightly acidic medium for 30-40 hours. This steeping or soaking helps to soften the corn kernel and make it easier to separate the kernel into a number of useful components. This separation process i
s called "corn wet milling". The most important component of the kernel for Penford is the starch. The starch is the raw material from which all of Penford's specialty starches are manufactured. Other components, referred to as "coproducts", include corn germ (contains the corn oil used to produce margarine), corn gluten meal, corn gluten feed, and steepwater.
Ethylene oxide is stored for use in the Hydroxyethhyl Starch Process. In this process a small quantity of ethylene oxide is reacted with starch to structurally modify or alter the basic natural starch polymer. The resulting hydroxyethylated starch is used in sizing and coating paper and paper products for the purpose of improving the printing and writing surface characteristics, adding strength or tear resistance, increasing base weight, improving overall appearance, imparting better water resistance, and increasing the manufacturing efficiencies of the papermaking process.
Chlorine is delivered to the facility in a bulk r
ailcar. The railcar is the storage vessel for the chlorine that is used in the Sodium Hypochlorite Process. In this process chlorine is reacted with sodium hydroxide (caustic) to produce sodium hypochlorite, also referred to as "hypo" or "bleach". Sodium hypochlorite is reacted with starch to whiten or bleach the starch and or to structurally modify or alter the chemical properties of the natural starch polymer. The finished products are used primarily in the papermaking industry.
1,3-butadiene is stored for use in the Starch-Copolymer Process. In this process 1,3-butadiene and styrene are reacted with starch to produce a combination of synthetic and natural starch based polymers. Starch-copolymer products are unique in that they are out-of-the-container-ready-to-use versions of Penford's sizing and coating starches that are used in papermaking and textile manufacturing.
Offsite Consequence Analysis
Penford has performed offsite consequence analyses (OCA) to estimate the potent
ial for an accidental release of a regulated substance to affect the public or the environment. The OCA consists of evaluating both worst-case scenarios (WCSs) and alternate release scenarios (ARSs). Regulated substances are characterized as being either flammable or toxic. Computerized models are utilized to determine the distance (endpoint) to which certain effects might occur to the public as a result of an accidental release of a regulated substance. Worst-case and alternate-case scenarios provide the input data for these computer models. The endpoint distance for flammables is the distance from the epicenter of an explosion to the point where the overpressure is reduced to 1 pound per square inch (typically causing no more serious effects than window breakage). The endpoint for toxics is that distance from the release where the maximum airborne concentration of the regulated substance is below the concentration that nearly all individuals could be exposed for up to one hour
without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action.
The RMP rule requires Penford to include data on one worst-case release scenario for flammables and one worst-case release scenario for toxics. In addition, Penford must include one alternate release scenario representing a flammable and one alternate release scenario for each toxic. Penford has one regulated flammable substance and three regulated toxic substances at this facility. Penford does not expect a worst-case release scenario to ever occur. Although an ARS represents a more likely release than the worst-case scenario, Penford has established a comprehensive process safety program to ensure these scenarios also do not occur. ARSs help the Linn County Local Emergency Planning Committee and the various emergency response agencies improve the community-wide emergency response plan. Penford has shared this informat
ion with the LEPC and with local emergency response agencies.
Worst-Case Release Scenarios
The worst-case release scenario for a flammable substance would involve the failure of the 45,000-gallon 1,3-butadiene storage tank in the Starch-Copolymer Process, resulting in the release of the entire contents of that vessel or approximately 35,000 gallons of 1,3-butadiene over a 10-minute period. The affects of the resulting vapor cloud explosion would impact individuals and property within a 0.5-mile radius of the epicenter of the explosion. This endpoint is beyond the boundary of the facility and includes an estimated residential population of 500 people and several public receptors, i.e., a park, a county jail, and several office buildings and commercial institutions.
The worst-case release scenario for a toxic substance would involve the failure of the 28,000 gallon sulfur dioxide storage tank in the Corn Wet Milling Process, resulting in the release of the entire contents of that v
essel or approximately 22,250 gallons of sulfur dioxide over a 10-minute period. The affects of the resulting toxic vapor cloud could potentially impact individuals and property within 18 miles of the release point. This endpoint is beyond the boundary of the facility and includes an estimated residential population of 169,000 people and many public and environmental receptors, i.e., schools, hospitals, state and local parks, a county jail, and numerous office buildings and commercial institutions.
Alternate Release Scenarios - Flammable
The alternate release scenario for a flammable substance would involve a penetration of the 45,000-gallon 1,3-butadiene storage tank in the Starch-Copolymer Process, resulting in the release of approximately 2,920 gallons of 1,3-butadiene over a 5-minute period. The affects of the resulting vapor cloud explosion would impact individuals and property within a 0.1-mile radius of the epicenter of the explosion. This endpoint is just beyond the bound
ary of the facility and includes only one public receptor, a park.
Alternate Release Scenarios - Toxics
The alternate release scenario for ethylene oxide involves the failure of the 1.5-inch diameter overhead piping system transporting ethylene oxide from the storage tank to the starch-ethylene oxide reactors in the Hydroxyethyl Starch Process, resulting in the release of the entire contents of that line or approximately 375 pounds of ethylene oxide over a 5-minute period. Modeling predicts a circle of potential exposure to a distance of 0.25 miles from the release point. The endpoint predicted is just beyond the boundary of the facility and includes an estimated residential population of 61 people and several public receptors, i.e., a park and an office building. During typical meteorological conditions, only individuals and property downwind from the source will be affected, limiting the number of exposed receptors.
The alternate release scenario
for sulfur dioxide involves the failure of the 2-inch diameter overhead piping system transporting sulfur dioxide from the storage tank to the use area in the Corn Wet Milling Process. The failure would result in the continuous release of the contents of the connected storage tank at a rate of 64.7 pounds per minute for a 1-hour period. Modeling predicts a circle of potential exposure to a distance of 0.85 miles from the release point. The endpoint predicted is beyond the boundary of the facility and includes an estimated residential population of 1098 people and a number of public and environmental receptors, i.e., two schools, several parks, a hospital, a county jail, and a number of office buildings and commercial institutions. During typical meteorological conditions, only individuals and property downwind from the source will be affected, limiting the number of exposed receptors.
The alternate release scenario for chlorine involves the failure of the 1.0-inch diame
ter overhead piping system transporting chlorine from a railcar to the bleach manufacturing equipment in Sodium Hypochlorite Process, resulting in the release of the contents of that line or approximately 260 pounds of chlorine over a 5-minute period. Modeling predicts a circle of potential exposure to a distance of 0.71 miles from the release point. The endpoint predicted is just beyond the boundary of the facility and includes an estimated residential population of 488 people and several public receptors, i.e., a school, a park, a county jail, and a number of office buildings and commercial institutions. During typical meteorological conditions, only individuals and property downwind from the source will be affected, limiting the number of exposed receptors.
Accidental Release Prevention Program and Chemical-specific Prevention Steps
The following is a summary of the general accident prevention program in place at the Penford Products Co. facility in Cedar Rapids, Iowa. Because
processes at Penford that are regulated by the EPA RMP regulation are also subject to the Occupational Safety and Health Administration (OSHA) process safety management (PSM) standard, this summary and the subsequent section on emergency response address each of the OSHA PSM elements and describes the management system in place to implement the accidental prevention program.
1. Employee Participation
It is Penford's policy to utilize the most knowledgeable and experienced resources available in the execution of its process safety and accident prevention programs. To accomplish this, Penford encourages (and at times requires) contractors and employees at all levels of the organization to participate. Operating unit personnel participate in hazard studies, incident investigations, periodic audits, and management of change reviews. Several committees with operator and contractor participation are responsible for the development of related programs and procedures. Written policies r
einforce the importance of employee participation and ensure process-related information is made available to those involved. All employees (including field personnel) actively participate in Penford's safety process.
2. Process Safety Information/Trade Secrets
Recognizing the importance of developing and maintaining technical documentation, Penford has established documentation standards and developed a computer-based document control system. When new or modified processes are developed, they are designed to meet or exceed all accepted trade and design standards. Chemical suppliers, engineering and trade associations, regulatory agencies, and equipment suppliers are contacted to provide pertinent design information used by the process engineers. Materials of construction, design specifications, safe operating limits, operating and maintenance procedures, chemical safety information, and other key information are collected or developed to ensure the process operates safely. Mai
ntenance, operating, emergency shutdown, and emergency response procedures are developed and maintained. Penford ensures that its processes are maintained within their process limits by using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown and safety systems).
Penford is ISO 9002 certified and process-related information is managed using ISO-compliant practices to ensure it is readily available and properly updated. A process information index helps direct personnel to the appropriate documents. Penford's access to information policy ensures process safety information is available to all personnel working in or affected by the process.
3. Process Hazard Analysis
Penford utilizes team-based hazard analysis techniques to ensure all potential hazards are identified and multiple levels of protection are in place to prevent an incident. Teams with engineers, operators, mechanics and safety professionals
spend weeks evaluating each component and procedure of each process. If new processes are developed, hazard evaluations are conducted at each phase of the design and construction. Multiple hazard evaluation techniques including hazard and operability (HAZOP) analysis, fault tree analysis, failure mode and effects analysis, are utilized. HAZOP, recognized as one of the most systematic and thorough hazard evaluation techniques is used for all reviews.
Trained study leaders, computerized hazard analysis software, and written hazard study protocol ensure each study is effective. Every change to a process is similarly evaluated, and each process is comprehensively re-evaluated at least every five years. Penford has established a system to ensure timely response to findings and recommendations. The computer-based system ensures recommendations are documented, actions prioritized, and responsibilities assigned; a written schedule for completing action is developed; action is taken and
documented; and action is communicated to affected personnel.
4. Management of Change
To ensure proposed changes to processes are properly evaluated before they are implemented, Penford has developed an effective management of change program. All proposed changes are carefully evaluated by engineers, operators, safety professionals, and site management to ensure a change does not introduce an unforeseen hazard. Changes to process equipment, chemicals, technology (including process-operating conditions), procedures, and other process changes are subject to the management of change review. When changes are implemented, operating and maintenance procedures are updated, employees and mechanics are trained, documentation is updated, and stores/inventory systems are updated. To ensure this occurs and the installation is completed as designed, a pre-startup safety review is conducted.
5. Operating Procedures
Penford maintains detailed written procedures that address various modes of
process operations, including unit startup, normal operations, temporary operations, emergency shutdown, normal shutdown, and initial startup of a new process. These procedures are used as reference by experienced operators and provide the basis for consistent training of new operators. Procedures are periodically reviewed and annually certified as current and accurate. When process changes are made, the management of change process ensures affected procedures are updated and operators are re-trained. Penford is ISO 9002 certified and operating procedures are managed using ISO-compliant practices to ensure they are readily available and properly updated. In addition, process control equipment and software have been programmed to require compliance with operating procedures. Multiple redundant safety interlocks have been programmed in to provide yet another layer of protection.
To complement the written procedures, Penford has developed a comprehensive training pr
ogram for all of its employees and contractors. New employees are required to complete a new hire orientation prior to assignment in the facility. After successfully completing the new hire orientation, a new operator is paired with a senior operator to learn process-specific duties and tasks. The new operator must demonstrate (through tests and skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner prior to working independently. In addition, all operators must successfully complete periodic refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years.
Prior to working at Penford, contractors are required to certify that their employees have successfully completed required safety training. Penford then provides additional training to every contractor employee prior to his or her assignment within the plant.
A computer-based training management package helps keep track of training for employees and contractors and makes sure refresher training is completed as required. Employees and contractors are issued photo training cards, and are required to present them when performing certain activities in the plant. Significant investments in training resources, including three fully-equipped training centers, a computer interactive training system, hands-on training facilities, and a full-time trainer help ensure the training is effective.
Contractors play a key role in Penford's operation, and as such, Penford maintains an extensive contractor program. Prior to working at the facility, potential contractors must pre-qualify, describing their management structure, insurance coverage, training process, historical safety performance, and a wide range of other pertinent information. If the contractor meets Penford's stringent requirements, each contractor employee must attend Pe
nford's contractor safety training. This training includes a process overview, information about safety and health hazards, emergency response plan requirements, and safe work practices. If completed successfully, the contractor employee is issued a training card valid for one year, and can be qualified for other activities (such as hot work or line breaking) if they successfully complete that training. A committee, with Penford and contractor representatives, periodically audits each contractor's safety performance and their overall safety process.
8. Pre-startup Safety Review (PSSR)
Penford conducts a Pre-startup Safety Review (PSSR) for any new process or significant process modification. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifica
tions and that all support systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.
9. Mechanical Integrity
Penford has well-established practices and procedures to maintain process equipment in a safe operating condition. Written maintenance procedures have been established for key equipment to help ensure that the work is performed in a consistent manner and provide a basis for training. Mechanics and contractors working on the equipment are trained in the procedures, the process itself, potential safety and health issues, emergency response procedures, and the site's safe work practices.
A Computerized Maintenance Management System (CMMS) is utilized to ensure all required preventive maintenance and testing is performed at recommended
intervals. Only trained and qualified mechanics or contractors perform maintenance on the system.
Quality assurance procedures have been established to ensure only specified repair parts are ordered and installed on the processes. Plant design standards (meeting or exceeding recommended industry practices), tight purchasing specifications, and incoming material inspections ensure the correct part is ordered and received. A parts identification system and a secured stockroom help ensure the proper parts are issued to a job. Documented maintenance procedures and contractor/mechanic training ensure the part is properly installed.
10. Safe Work Practices
Penford has effective safe work practices in place to help ensure worker and process safety. A sophisticated card access security system, video surveillance, and 24-hour security guards help ensure only authorized personnel have access to the site. Penford's Energy Isolation and Line Breaking procedures ensure process equipment is
safe prior to performing repairs. Confined Space Entry and Hot Work Programs require careful review prior to issuance of permits allowing the performance of these activities. Penford works with local emergency response agencies to ensure they are familiar with its safe work practices and to ensure that a well-trained second line of defense is readily available. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely.
11. Incident Investigation
Penford promptly investigates all incidents and near misses at its facility. A team-based approach is typically utilized to ensure an in-depth, unbiased investigation is conducted. The goal of each investigation is to determine the facts, identify the root causes, and develop corrective actions to prevent a recurrence of a similar incident. The investigation team documents its findings, develops recommendations to prevent a rec
urrence, prioritizes recommendations, and assigns responsibilities. An action item database is maintained to ensure corrective actions are completed on a timely basis and appropriate documentation is maintained. All incidents/near misses and corrective actions are shared with all affected personnel to help minimize the potential for recurrence. The well-managed incident investigation process serves as a valuable input for the period hazard analyses.
12. Compliance Audits
To help ensure that the process safety and accident prevention program is functioning properly, Penford periodically conducts comprehensive audits. To ensure the audits provide adequate coverage, the OSHA Program Quality Verification (PQV) guidelines are used to establish minimum audit requirements. Additional areas of focus are included based on an evaluation of previous audit results, previous incidents, changes to the process, and additional OSHA/EPA guidance or clarifications. To ensure the audits accuratel
y reflect the program effectiveness, employee interviews, written documentation reviews, and process observations are included. The audit team documents its findings, develops recommendations for improving the program, prioritizes recommendations, and assigns responsibilities. An action item database is maintained to ensure corrective actions are completed on a timely basis and appropriate documentation is maintained. Corrective action taken in response to the audit team's recommendations is documented and the two most recent audit reports are retained.
Chemical-specific Prevention Steps
The processes at Penford have hazards that must be managed to ensure continued safe operation. The prevention program summarized previously is applied to all Program 3 EPA RMP-covered processes at Penford. Collectively, these prevention programs help prevent potential accident scenarios that could be caused by equipment failures or human errors.
In addition to the accident prevention program a
ctivities, Penford has installed safety features on many process units to help quickly detect a release, contain/control a release, and reduce the consequences of (mitigate) a release. The safety features listed below are in use in various processes:
Hydrocarbon detectors with alarms and process interlocks
Chlorine and other chemical-specific detectors with alarms and process interlocks
Video monitors and 24-hour security
Release Containment and Control
Process relief valves that discharge to scrubbers or contained locations
Scrubbers to neutralize releases
Automatic and manual valves to permit isolation of process components
Automated shutdown systems for specific process parameters (e.g., high level, high temperature)
Curbing or diking to contain releases
Redundant equipment and instrumentation (e.g., backup power supply, backup pumps, etc.)
Atmospheric release devices
Fire suppression and extinguishing systems
ncy response personnel
Personal protective equipment
Five-Year Accident History
Penford has an excellent safety record. All incidents, including those with the potential to cause any injury or damage, are investigated. The RMP Program regulations require the reporting of accident histories involving regulated substances that result in deaths, injuries, or significant property damage on site or known deaths, injuries, evacuations, shelter-in-place, property damage, or environmental damage off site. There have been no accidents involving ethylene oxide, sulfur dioxide, 1,3-butadiene or chlorine that have resulted in injury or property damage onsite or offsite in the last five years at this facility.
Emergency Response Program
Penford maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of any hazardous substance, including the possibility of
a fire or explosion if a flammable substance is accidentally released. These procedures address all aspects of emergency response, including proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements. In addition Penford has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties including sheltering-in-place and evacuation. Penford employees that may be involved in a threatened or actual chemical spill response are required to complete a certified 24-hour course in Industrial Chemical Spill Response. These personnel must recertify annually with an 8-hou
r refresher course at an approved training center. Penford workers will respond to minor events that do not have the potential for significant effects (e.g., small fires or small leaks). In the event of a larger fire or release, workers evacuate the area and contact the Cedar Rapids Fire Department.
Penford's emergency response program is updated when necessary based on modifications made to Penford plant processes or other Penford plant facilities. The emergency response program is included in the management of change process, which includes informing and/or training effected personnel in the changes. The emergency response program is managed using ISO-compliant practices to ensure that all changes to the program are readily available and properly updated.
The overall emergency response program for Penford is coordinated with the Cedar Rapids Fire Department and the Linn County Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings with the comm
ittee, which includes local emergency response officials, local government officials, and industry representatives. Penford has been an active member of the committee and has worked with the Linn County Emergency Management Agency (EMA) in developing and exercising the county-wide Hazardous Materials Emergency Response Plan (Annex P). Penford has around the clock communications capability with appropriate emergency response organizations (e.g., fire department) and LEPC officials. This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, Penford conducts periodic emergency drills for all facility personnel and has worked with both the LEPC and emergency response organizations on county-wide chemical emergency response training. Penford involves local responders in refresher training on the hazards of regulated substances in the Penford facility.
Planned Changes to Im
Penford constantly strives to improve its safety performance and minimize potential impact on the environment. Active safety and environmental teams and committees, routine audits and inspections, an effective incident investigation procedure, routine PHA's, and community involvement all provide input on improvement opportunities. Some of the improvements currently planned include:
Upgrades to several fire protection systems
Upgrades to chemical detection systems
Use of computer-based-training (CBT) to facilitate the operator training process
Complete Y2K control system upgrades
Install additional controls on several systems
Upgrade several piping systems
Upgrade perimeter security system
Improve utilization of Computerized Maintenance Management System (CMMS) in Mechanical Integrity Program