A.E. Staley Manufacturing Company-Sagamore - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES We at A. E. Staley Manufacturing Company-Sagamore 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 modified starches for food and industrial use. We have two regulated substances at our facility. These substances include Propylene Oxide [oxirane,-methyl] and Sulfur Dioxide (anhydrous). Propylene Oxide is used for starch product substitution in the manufacture of modified starches for industrial and food applications. Sulfur Dioxide (an hydrous) 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 Propylene Oxide at our facility is 380,000 lb which is the sum of the maximum bulk tank capacity of 210,000 lb and the railcar capacity of 170,000 lb. The maximum inventory of Sulfur Dioxide at our facility is 61,500 lb. THE WORST CASE RELEASE SCENARIO AND THE ALTERNATE RELEASE SCENARIOS We used EPA's RMP Guidance for Offsite Consequence Analysis and EPA's RMPComp software to evaluate the Worst Case and Alternate Release Scenario for Propylene Oxide. EPA's RMP Guidance for Waste Water Treatment Plants and EPA's RMPComp software was used to evaluate the Worst Case and Alternate Release Scenarios for Sulfur Dioxide. 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 61,500 lb. of Sulfur Dioxide (anhydrous) is released as a gas liquefied under pressure with volatilization to the gaseous form over 10 minutes. The enclosure around the Sulfur Dioxide tank was considered passive mitigation and had the effect of mitigating the release rate to 55% of the maximum. At class F atmospheric stability, 1.5 m/s windspeed, and urban topography the maximum distance of 5.6 miles is obtained corresponding to a toxic endpoint of 0.0078mg/L. THE PROPYLENE OXIDE ALTERNATE RELEASE SCENARIO involves a break of a flexible transfer line between a full rail car pressurized to 3 psig with a nitrogen blanket and the Propylene Oxide bulk tank. The scenario involves the release of 10,000 lb of Propylene Oxide. Since the transfer pipe connects to the suction side of the unloading pump, pumping would cease after transfer pipe break due to loss of prime. The operator, who is present during the entire unloading process, would immediately shut off the ni trogen pressurizing the car. Propylene Oxide release would continue for 9.5 minutes until the pressure falls to atmospheric and the car head pressure is reduced below that necessary to lift Propylene Oxide out of the rail car. The toxic liquid released is assumed to form a pool on the ground within the earthen bermed area around the unloading area. The pool is assumed to evaporate within 5.53 minutes. Under neutral weather conditions of class D atmospheric stability and 3 m/s wind speed and an urban topography the maximum distance to the toxic endpoint of 0.59mg/L of Propylene Oxide is 0.4 miles. THE SULFUR DIOXIDE ALTERNATE RELEASE SCENARIO involves a 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. 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 t oxic gas 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. 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 the NFPA-30 Standard, applicable ANSI standards and ASME standards for pressure vessels. All chemical storage systems were designed and are maintained in conformance with 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 Manufac turing Company-Sagamore 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 on May 2, 1995. The most recent PHA review for the Propylene Oxide system was performed on April 5, 1994. OPERATING PROCEDURES-For the purposes of safely conducting activities within our covered processed, A. E. Staley Manufacturing Company-Sagamore maintains written oper ating 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-Sagamore 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-Sagamore carries out documented maintenance checks on process 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 pr evious 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-Sagamore to manage changes in process chemicals, technology, equipment, and procedures. The most recent review/revision of maintenance procedures was performed May 18, 1999. 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 review related to new processes and to modifications is established processes are conducted as a regular practice at A. E. Staley Manufacturing Company-Sagamore. These reviews are conducted to confirm that construction, equipment, operating, and maintenance pro cedures are suitable for safe startup prior to placing equipment in operation. COMPLIANCE AUDITS-A. E. Staley Manufacturing Company-Sagamore 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 April 16, 1998. 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-Sagamore promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated 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-Sagamore 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 additions, 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 training. 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-Sagamore representative regularly. The contractor notifies A. E. Staley Manufacturing-Sagamore about any incident involv ing a near miss, accident, or injury of contract personnel. A. E. Staley Manufacturing-Sagamore keeps copies of the entire meeting notes and incident investigation reports to document past safety performance. A. E. Staley Manufacturing Company-Sagamore 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-Sagamore has had an excellent record of preventing accidental releases over 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-Sagamore carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency res ponse 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 is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response plan. Tippecanoe County Emergency Planning Committee is the Local Emergency Planning Committee with which our emergency plan has been coordinated and verified. |