High Plains Ethanol Inc., Portales Facility - Executive Summary

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Executive Summary: 
The major objective of this Risk Management Plan (RMP) is to prevent unwanted releases of hazardous chemicals especially into locations that could expose employees and the surrounding communities to serious hazards. 
This RMP pertains to the High Plains Corporation's Ethanol Facility located in Roosevelt County, Portales, New Mexico.  The Facility processes Milo grain to produce fuel grade ethanol alcohol and high protein cattle feed.  Anhydrous Ammonia is used in the process to adjust and control pH during the initial breakdown of starch to sugar.  Ammonia also provides essential nutrients to the yeast that process sugar to alcohol.  Anhydrous Ammonia is stored at the facility in quantities no greater than 46,000 lbs. 
The process design, process technology, process changes, operational and maintenance activities and procedures, non-routine activities and procedures, emergency plans and procedures, training programs, and other elements that effect the process are a 
ll considered in this plan.  Through this plan we intend to prevent or minimize the consequences of catastrophic releases of toxic chemicals as these releases could result in toxic hazards and cause harm to persons or the environment. 
Chemical Safety Statement 
High Plains Corporation owns and operates a manufacturing plant converting Milo grain into fuel grade ethanol alcohol.  At the Portales Ethanol Facility, safety is a way of life both on and off the job.  Personal injuries can be prevented and no job is so important that it should be performed in an unsafe manner.  Safety at this plant is the responsibility of all employees. 
Managers and Supervisors are responsible for the safety of all persons who report to or are assigned to them.  This responsibility is carried out by assuring that a sound Safety Program is in place including designing, maintaining, and operating equipment in a safe manner, assuring training and education is completed for safe work methods, and establishing  
and enforcing safe operating and maintenance practices and rules. 
All employees have a responsibility to safety by learning and observing all safe work rules, methods, practices and procedures and by wearing the appropriate Personal Protective Equipment (PPE). 
High Plains Corporation is intent on being a responsible steward to our neighbors and the environment.  The facility is committed to recycling or recovery of all possible process streams and the mitigation of releases and emissions using best business practices. 
Systems, procedures, and methods are in place to prevent the spill or release of any chemical to the environment and to respond and contain any inadvertent or accidental release.  These policies are explained in detail in the Emergency Action Plan and the Stormwater Pollution Prevention Plan, including Spill Containment and Countermeasures.  Additional safe work methods and chemical specific data are outlined in the Hazardous Communication Program and the Process Safet 
y Training Manuals. 
Information Pertaining to the Technology of the Process: The below listed information is the minimum amount of information we have acquired: 
7 A block flow diagram or simplified process flow diagram 
7 Process chemistry 
7 Maximum intended inventory 
7 An evaluation of the consequences of deviations, including those affecting the safety and health of employees, and the affect on the surrounding communities. 
Information Pertaining to the Equipment in the Process: The below listed information is the minimum amount of information we have acquired: 
7 Materials of construction 
7 Piping and instrument diagrams (P&ID) 
7 Relief system design and design basis 
7 Design codes and standards employed 
7 Material and energy balances 
Training program: 
Each employee presently involved in operating the process and all employees before being involved in operating a newly assigned process, is trained in an overview of the process and in the operating procedures as mentioned earlier  
in this policy.  Our training includes emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks.  Hazard communication training is the beginning of our training program for all employees.  We continue with training programs that inform employees of standard operating procedures, safe work practices, emergency evacuation, safety procedures, routine and non-routine work authorization activities, confined space entry, lockout/tagout, and many other areas as necessary to protect the employee and process.  
Our training uses many aspects of current training techniques: these include hands-on, classroom, on-the-job, video programs, written materials and any other technique necessary to provide clear and effective training to our employees.  Employees are fully informed as to the goals and objectives of the training and what is considered acceptable performance for duties they are to perform.  A 
ll employees are tested or quizzed to assure their competence and knowledge in each area of training. 
Specific training in the operating procedures, control, precautions, pre-startup, mechanical integrity, inspection, testing, quality assurance, hot work permits, management of change, and emergency planning and response is provided for all employees working and involved with highly hazardous chemicals at our facility.   
Refresher training shall be provided as determined.  We shall assure that the employee involved understands and adheres to the current operating procedures of the process.  Once training has been completed and the employee is "on the job" there will be an evaluation of the employee's performance. If this evaluation is below acceptable performance levels we will further train the employee to provide the described results and resolve any deficiency.  This training shall be provided as often as necessary but in no case will it be less than once every three years. 
High P 
lains is keeping records of all training to ascertain that each employee involved in operating a process has received and understood the training.  This record contains the identity of the employee, the dates of training, and the means used to verify that the employee understood the training. 
Incident Investigation: 
The intent of the High Plains Corp. incident investigation is to identify the underlying causes of these incidents and implement steps to prevent similar events from occurring.  We perform these incident investigations to learn from past experiences and thus avoid repeating past mistakes.  Incidents are events that are sometimes referred to as "near misses," meaning that a serious consequence did not occur, but could have.  For this reason we intend to investigate all incidents and especially those which resulted in, or could have resulted in a catastrophic release of a highly hazardous chemical in the workplace. 
All incident investigations will be promptly documented an 
d shall never be initiated later than 24 hours following the incident.  Time is of the essence when performing an incident investigation so that facts do not become confused with the passage of time. 
Initiation of the incident report is the responsibility of the supervisor in charge. 
Employees in the process area where the incident occurs will be consulted and interviewed.  Their knowledge of the events represents a significant set of facts about the incident that occurred.  The cooperation of employees is essential to an investigation.  The focus of our investigation is to obtain facts, and not to place blame.  The investigation process will clearly deal with all involved individuals in a fair, open, and consistent manner. 
The report prepared at the conclusion of the investigation will include the following at a minimum: Date of incident, time and date of investigation began, a complete description of the incident, all factors that contributed to the incident, and all recommendatio 
ns resulting from the investigation. 
All resolutions and corrective actions will be documented along with the report findings and recommendations. 
The complete report will be reviewed with all affected personnel whose job tasks are relevant to the incident findings and include contract employees where applicable. 
All incident investigation reports and data will be retained for five years and used when performing process hazard analysis, process hazard analysis updates and management of change reviews. 
Emergency Planning and Response: 
High Plains has developed an emergency action plan for the Portales, NM facility. These plans include emergency evacuation as per current OSHA guidelines (29 CFR 1910.38) and notification of local emergency response agencies. High Plains is included in the local emergency response plan. All employees are trained regarding their responsibility in this plan when hired and annually thereafter.  Full details of the emergency action plan are maintained in  
the company safety plans manual, copies of which are accessible to all employees and contractors. The Sara Title III, Tier II report was filed with the local Emergency Coordinator and the Portales Fire Department. The Portales Fire Department toured the facility in December, 1998 to familiarize themselves with all hazards. 
Compliance Audits: 
High Plains Corp. will use compliance audits as a technique to gather sufficient facts and information, to verify compliance with current standards.  A team will be used to perform audits of the process safety management system and risk management program.  These audits will be conducted at least every three years to verify that the procedures and practices developed under this program are adequate and are being followed. 
Audit team members will be selected on the basis of their experience, knowledge, and training and are familiar with the processes and auditing techniques, practices, and procedures.  Team members will have expertise in process  
engineering and design; process chemistry; instrumentation and computer controls; electrical hazards and classifications; safety and health disciplines; maintenance; emergency preparedness;  and process safety auditing. The team will compare what is actually done or followed with the written PSM/RMP program. 
The audit will include a review of the relevant documentation and process safety information, inspection of the physical facilities, and interviews with plant personnel.  The review will evaluate the written training program for adequacy of content, frequency of training, effectiveness of training in terms of its goals and objectives as well as how it fits into meeting the programs requirements.  Through interviews, the team will determine employee's knowledge and awareness of the safety procedures, duties, rules, and emergency response assignments.  During the inspection, the team will observe actual practices such as safety and health policies, procedures and work authorization  
The audit team, through systematic analysis, will document areas that require corrective action as well as where the process safety management and risk management program system is effective.  This will provide a record of the audit procedures and findings and serves as a baseline of operational data for future audits. 
Corrective action includes identifying deficiencies, and planning follow-up, and documenting the corrections.  Corrective action will begin with a management review of the audit Findings.  The purpose of the management review is to determine what actions are appropriate, and to establish priorities, timetables, resource allocations and requirements, and responsibilities.  In some cases, corrective action may involve only a simple change in procedures or a minor maintenance effort to remedy the problem.  Management of change procedures will be used, as appropriate.  While many of these changes may be minor, some may require engineering studies or more detaile 
d review of actual procedures and practices.  All actions taken, including an explanation when no action is taken on a finding will be documented. 
Incident History: 
High Plains Corporation, York NE, Ethanol Facility has had 2 uncontrolled releases.  As a result of theses similar facility incidents, operating procedures have been revised and an operator training program has been instituted.  Excess flow valves and an emergency shut off valve have been installed to reduce the duration of a release if an incident was to happen at the Portales facility.  These changes, along with compliance with Process Safety Management and Risk Management Plans, give us great confidence that the risk of release is low. 
Release Scenarios 
High Plains Corporation analyzed the impact of a worst case scenario and an alternative in compliance with the Risk Management Plan. The SLAB model used. 
The results of the worst-case model indicated a toxic endpoint of 4.84 miles.  This worst case scenario indicates 
that a catastrophic release could impact the City of Portales, New Mexico.  There are no environmental receptors within the 4.85 mile radius. 
The results of the alternative scenario indicated a toxic endpoint was .39 miles.  The estimated population within this distance was 6 people.  The primary use of the land in the vicinity is agricultural.  There are no environmental receptors within the 0.39 mile radius.
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