Cerestar USA, Inc. - Hammond Plant - Executive Summary

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Cerestar USA, Inc. 
Hammond, Indiana Plant 
Risk Management Plan 
Executive Summary 
1. Accidental Release and Response Policies 
The Cerestar USA, Inc. - Hammond Plant (Cerestar) is strongly committed to employee and public safety.  A comprehensive accidental release prevention program that includes training of personnel and consideration of safety in the design, installation, operation and maintenance of our processes demonstrates this commitment.  It is our policy to implement appropriate controls to prevent releases of regulated substances. 
2. Description of Stationary Source and Regulated Substances 
Cerestar produces corn syrup and starches for food and non-food industries at our Hammond Plant.  The processes at the plant include a variety of storage tanks, process vessels, and product storage.  The storage and process areas were evaluated to determine regulated flammable or toxic substances could exceed the EPA published threshold quantities.  The site uses two regulated substance 
s in three separate processes.  In our wastewater treatment plant, aqueous ammonia is used as a nutrient for our biological treatment process.  The storage tank is sized to contain 67,000 pounds of ammonia solution.  Propylene Oxide is used as a reactant to create more water soluble products in our starch modification and cyclodextrin production areas.  The storage tank in the starch area has a capacity of 207,000 pounds.  In the cyclodextrin production area, storage is a maximum of 45,000 pounds. 
Using the EPA worst case analysis format, the distances to endpoint (i.e., Emergency Response Planning Guideline - Level 2, (ERPG-2)) for ammonia and propylene oxide exceed the distances to public receptors (i.e., public parks, residences and industrial offices).  Cerestar is subject to the Occupational Safety & Health Administration (OSHA) Process Safety Management (PSM) rule.  The three Cerestar processes are classified as Program 3 processes under the Risk Management Program. 
3. Off-Site 
Consequence Analysis Report 
3.1. Worst Case Release Scenario 
To perform the required off-site consequence analysis for our facility, we have used the look-up tables and equations provided by the EPA in their RMP guidance documents and the EPA's RMP-Comp program. 
The worst case release scenario involves a catastrophic release from our starch area Propylene Oxide storage tank.  The scenario involves the instantaneous release of the entire contents of the tank (207,000 pounds) and subsequent evaporation from the diked area.  Under the guidance, this release scenario occurs at the worst case weather conditions of Class F atmospheric stability and 1.5 m/s wind speed.  At the given conditions the worst case scenario reaches a maximum distance of 0.5 miles. 
3.2. Alternate Release Scenario 
An alternative release scenario is a more likely release incident and is considered by EPA to be more valuable for response planning purposes.  Alternative scenarios are presented for each of the process 
es.   EPA requires that an alternative release scenario be presented that leads to off-site concentrations above the ERPG-2 endpoint.   
The alternative release scenario for both Propylene Oxide systems is the failure of a transfer hose or connection.  At the starch area, the scenario results in a release of 2750 pounds and a distance to endpoint of 0.2 miles.  This distance reaches off-site receptors but no residential population.  The alternative release scenario for the cyclodextrin process results in the release of 2,100 pounds and also reaches a distance to endpoint of 0.2 miles, which includes off-site receptors.   
The alternative release scenario for Aqueous Ammonia is the failure of a distribution pipe in the treatment area.  The scenario results in a release of 1495 pounds of ammonia solution and a distance to endpoint of <0.1 miles, which could reach off-site receptors, but not residences. 
4. General Accidental Release Prevention Program 
Cerestar has taken all the necessar 
y steps to comply with the accidental release prevention requirements under 40 CFR part 68.  The following is a summary of the elements of the accidental release prevention program in place at Cerestar.  
4.1. Process Safety Information 
Cerestar maintains technical documents that are used to assist in our accident prevention efforts.  This written safety information includes chemical properties, process descriptions and diagrams, equipment design information, and operational parameters. 
4.2. Process Hazard Analysis 
Cerestar conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled effectively.  We primarily use the Hazard an Operability (Hazop) analysis technique to carry out these studies.  The Hazop analysis is considered one of the most systematic and thorough hazard evaluation techniques.  A team of qualified personnel undertakes the studies with expertise in engineering, process operations, safety and maintenance. The team f 
indings are presented to on-site management for resolution.  Implementation of mitigation alternatives is based on a relative risk ranking system completed by the team.  The team findings are tracked until they are completed and appropriately documented.  The Hazop studies are revalidated at least once every 5 years. 
4.3. Operating Procedures 
Cerestar maintains written operating procedures for our covered processes that addresses various modes of operation.  The operation modes include startup, normal operation, temporary operation, emergency shutdown, normal shutdown and initial startup of a new process.  These procedures are referenced by experienced operators and are used as the basis for training new employees.  These procedures are regularly reviewed and updated as necessary. 
4.4. Training 
Cerestar has a comprehensive training program in place to ensure that employees operating processes are competent in the operating procedures associated with these processes.  New employees re 
ceive initial training on the process basics and are then given on-the-job supervision until they demonstrate the ability to work independently.  Refresher training is provided periodically to ensure operator skill and knowledge is retained.   
4.5. Mechanical Integrity 
Cerestar carries out highly documented maintenance checks on pressure vessels, piping systems, relief and vent systems, controls, pumps and emergency shutdown systems to ensure safe operating condition.  Maintenance operations are carried out by qualified personnel with training in proper maintenance practices.  These personnel are offered specialized training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.   
4.6. Management of Change 
Cerestar maintains written procedures to manage changes in process chemicals, technology, equipment, and procedures.  Process operators, maintenance personnel and other employees whose jobs are affected by a modificati 
on are informed of the changes and offered training to deal with the modification. 
4.7. Pre-startup Reviews 
Cerestar has written procedures that address the start-up of new or modified processes.  The reviews are conducted to ensure that construction, equipment, procedures, and personnel are appropriately prepared for startup before operation begins. 
4.8. Safe Work Practices 
Cerestar has a number of safe work practice procedures in place to protect personnel and process equipment.  Procedures include sign-in and out of maintenance and construction employees, as well as confined space entry, hot work, and lockout/tagout procedures.  These procedures are designed to ensure that proper precautions are taken and communication has occurred regarding the work and potential hazards.   
4.9. Employee Participation 
Cerestar encourages employees to participate in all aspects of process safety management and accident prevention.  Employees are encouraged to express their views concerning accide 
nt prevention and recommend facility improvements.  Our employees have access to all the information created as part of our facility's implementation of this accident prevention program and are invited to assist in the on-going update of this information. 
4.10. Contractors 
Cerestar uses contractors to conduct specialized maintenance and construction activities and to supplement our regular workforce during peak maintenance periods.  Prior to selecting a contractor an evaluation of safety performance is carried out.  Contractors are informed of any potential hazards around their work area and are instructed to report all incidents to their Cerestar contact.  Contractors are also instructed in appropriate emergency response procedures. 
4.11. Incident Investigation 
Cerestar promptly investigates any incident that resulted in, or could have reasonably resulted in a significant release of a regulated substance.  The investigations are undertaken to identify the parameters leading to the i 
ncident as well as any corrective actions to prevent a similar incident from recurring.  The reports are maintained for at least 5 years so they can be reviewed in future hazard analysis studies. 
4.12. Compliance Audits 
Cerestar conducts audits of this program to determine the extent to which the procedures and practices that have been developed are being followed.  The audits are conducted at least once every 3 years.  Any findings are forwarded to on-site management so that prompt corrective action can take place.  Any corrective actions identified during the audit are tracked until completed.  
5. Chemical Specific Prevention 
Within each chemical system, there are safety features designed specifically for the process and chemical.  Examples of such process specific controls include: Isolation valves, curbing and diking to contain releases, continuous process area monitoring, pressure relief devices, condensers and scrubbers for emission control, fire extinguishing systems, and pe 
rsonal protective equipment and trained emergency response personnel. 
6. Five-Year Accidental Release History 
Cerestar has had an excellent record of preventing accidental releases.  Due to our stringent release prevention policies, there have been no reportable accidental releases from any of the three covered processes during the last 5 years. 
7. Emergency Response Plan 
Cerestar maintains a written emergency response plan to deal with accidental releases of hazardous materials.  The plan includes procedures for responding to the release of a regulated substance.  The procedures address all aspects of emergency response including proper first aid, and medical treatment, evacuation, accounting for personnel, notification of local emergency response agencies and the public, and post-incident cleanup and decontamination.   
Emergency response equipment is regularly inspected and serviced.  The plan is updated, as necessary to reflect any changes that would impact our response to an em 
8. Planned Changes to Improve Safety 
Cerestar plans to maintain our program of continuous improvement that is currently in place.  Ongoing parts of the program previously presented include Process Hazard Analysis, Management of Change, and Compliance Audits.  
In addition Cerestar will continue to explore chemical substitution, process modifications and additional safety equipment that can reduce the potential for on and off site impact of potential releases and make our processes even safer.
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