Agri-Energy, LLC - Executive Summary |
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Accidental Release Prevention and Emergency Response Policies Agri-Energy, LLC is committed to the protection of its employees, the greater community and the environment from hazardous substances used in the ethanol fuel production process, specifically the natural gasoline used as the ethanol denaturant. The natural gasoline is added to the ethanol to make the ethanol unfit for human consumption. It is the policy of Agri-Energy, LLC to comply with all applicable federal, state and local laws. Facility Description and Regulated Substance Handled Agri-Energy, LLC operates an ethanol fuel production plant located near Luverne, in Rock County, Minnesota. The facility produces fuel grade ethanol from corn and a process by-product known as dry distillers' grain with soluables, which is used as a livestock feed. The fuel ethanol production process requires use of a denaturant (natural gasoline) which is reported to contain 30 to 40 percent pentane, an RMP regulated substance. The maximum amount of natural gasoline on-site is estimated to be 120,000 pounds. The natural gasoline is stored in an above ground tank as a liquid and is introduced to the fuel ethanol in the final stage of production. The denaturant tank is located in the facility's tank farm area which includes secondary containment. Worst Case Scenario The worst case scenario defined by RMP Guidance is a failure of the natural gasoline storage tank resulting in a vapor cloud explosion. According to RMP*Comp, a software tool developed by the U.S. National Oceanic and Atmospheric Administration for use in performing offsite consequence analysis, the maximum estimated distance from the facility's center to a one pound per square inch overpressure is 0.4 miles. The estimated number of human receptors within a 0.4 mile radius of the plant is 220 persons. The analysis assumed a release of 120,000 pounds of denaturant (the entire contents of the tank), a wind speed of 3.4 miles per hour and an air temperature of 77 degrees F. Alternate Case Scenario The alternative case scenario evaluated using RMP Guidance was a failure of the largest natural gasoline storage tank resulting in a vapor cloud fire. According to RMP*Comp, , the maximum estimated distance from the facility's center to the Lower Flammability Limit for pentane (1.5%) is 0.1 miles. The estimated number of human receptors within a 0.1 mile radius of the plant is 110 persons. The analysis assumed a release rate of 2000 pounds of pentane per minute, a wind speed of 6.7 miles per hour and an air temperature of 77 degrees F. The analysis also assumed the release occurs in a diked area since the Agri-Energy, LLC tank farm is located in a diked secondary containment area. General Accidental Release Prevention Program Through completion of this RMP, Agri-Energy, LLC has complied with the EPA requirements under 40 CFR Part 68. Process safety information and operations/maintenance procedures are documented on-site. Periodic functions s uch as process hazard analysis, training, change management and incident investigation are conducted on a regular basis. Audits of the overall RMP will be conducted on a regular basis to assure compliance with EPA regulations. Five Year Accident History Agri-Energy, LLC has not had a natural gasoline accident causing death, injuries, environmental of property damage, evacuations or in-place sheltering in the last five years at the fuel production facility. The facility began operation in August of 1998. The Emergency Response Program In the event of an emergency, it is the policy of Agri-Energy, LLC to notify the City of Luverne Fire Department and evacuate all employees from the facility. |