ADM Corn Processing - Executive Summary |
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ADM - Clinton RMP Executive Summary a. Accidental Release Prevention and Emergency Response Policies This facility is a corn wet milling processing plant. Plant activities include grain storage and handling, wet milling and separation processes, by-product processing, and several finishing steps that convert corn starch into alcohol, sweeteners and dry specialty starch products. There are two regulated substances at this facility: anhydrous sulfur dioxide and ethylene oxide. Sulfur dioxide is used as a processing aid for starch and gluten. Ethylene oxide is used in the production of specialty starches. This facility observes safety precautions in handling sulfur dioxide and ethylene oxide to reduce the threat to workers, members of the community, and the environment, and adheres to applicable Federal and state rules and regulations. Safety depends upon the manner in which the facility handles sulfur dioxide and ethylene oxide, the safety devices inherent in the design of the facility, the safe handling procedures that are used, and the training of personnel. Emergency response for this facility is coordinated with the Clinton County Emergency Management Agency which is the Local Emergency Planning Committee (LEPC), and the Clinton Fire Department which is the local emergency response provider. Emergency response procedures at this facility include notification of the LEPC in the event of an accident involving sulfur dioxide or ethylene oxide. b. The Stationary Source and the Regulated Substances Handled This facility is a corn wet milling processing plant. There are two regulated substances at this facility: anhydrous sulfur dioxide and ethylene oxide. Sulfur dioxide is used as a processing aid for starch and gluten. Ethylene oxide is used in the production of specialty starches. c. Off-Site Consequence Analysis Worst-Case Scenario: As a worst-case scenario, it is assumed that the entire contents of a single tank of anhydrous sulfur dioxide i s released over a ten minute period in liquid form and quickly vaporizes. Assumed worst case weather conditions include 1.5 m/s wind speed and class F atmospheric stability. EPA's RMP*Comp(TM) was used as a screening tool to determine which chemical would be responsible for the worst case scenario for this facility. A more refined model, DEGADIS, was then used to perform the required offsite consequences analysis (OCA). The worst case release scenario assumes: the affected tank is filled to maximum intended inventory, the release continues for ten (10) minutes, the material is released as a gas, worst case weather conditions. Alternative Scenario #1: A more realistic release scenario involving accidental release of anhydrous sulfur dioxide is a slow release from a 1/4 inch hole resulting from a piping failure at a flange, joint, weld or seal. The release is in liquid form which quickly vaporizes and continues for one (1) hour. Assumed worst case weather conditions include 3 m/s wind speed and class D atmospheric stability. EPA's RMP*Comp(TM) was used to perform the required OCA for this facility. The alternative release scenarios assume: the affected tank is filled to maximum intended inventory, a <-inch diameter (0.049 square inch) hole in the bottom of the affected tank, the release continues for one (1) hour, the material is released as a gas, worst case weather conditions. Alternative Scenario #2: Accidental release of ethylene oxide might occur due to a slow release from a 1/4 inch hole resulting from a piping failure at a flange, joint, weld or seal. The release is in liquid form which quickly vaporizes and continues for one (1) hour. Assumed worst case weather conditions include 3 m/s wind speed and class D atmospheric stability. EPA's RMP*Comp(TM) was used to perform the required OCA for this facility. The alternative release scenarios assume: the affected tank is filled to maximum intended inventory, a <-i nch diameter (0.049 square inch) hole in the bottom of the affected tank, the release continues for one (1) hour, the material is released in liquid form which quickly vaporizes, worst case weather conditions. d. Accidental Release Prevention The key concepts in this facility's prevention program are elements of OSHA's PSM Program which include process safety information, process hazard analysis, operating procedures, training, mechanical integrity, management of change, compliance audits, incident investigation, employee participation, and contractors. e. Five-Year Accident History This facility has not had any accidents involving anhydrous sulfur dioxide or ethylene oxide that require reporting under EPA's Risk Management Rule. f. Emergency Response Program This facility has an Emergency Response Program and Emergency Response Plan for responding to accidental releases of hazardous substances. As part of this program, ADM has personnel trained to the First Respon der Awareness Level who can identify the released material and activate the Plant Emergency Operations Plan and the Emergency Response Plan by notifying the Shift Superintendent. ADM also has personnel trained to the First Responder Operations Level who can isolate the spill area, control access to the area, and initiate containment activities under the direction of the Operations Officer. Hazardous Waste cleanup activities are handled primarily by spill contractors. Clinton County has a Local Emergency Planning Committee (LEPC) which has developed a county wide emergency response plan that involves local industry, the fire departments, police departments, ambulance services, hospitals, the health department, the county highway department, local streets and sanitation department, and other local government agencies. The plan organizes county wide response to emergencies including hazardous material incidents. It also provides for coordination with the State Emergency Response P lan. The facility Emergency Response Plan is coordinated with facility personnel, the Clinton Fire Department, the Clinton Police Department, and the Coordinator of the Clinton County Emergency Management Agency such that in the event of an accident, immediate emergency response measures can be implemented. ADM is working cooperatively with the surrounding community and the Clinton Fire Department to improve response capabilities. g. Planned Changes to Improve Safety As a result of a safety review of this facility's anhydrous sulfur dioxide and ethylene oxide systems, it has been determined that no changes need to be made to the systems at this time. However, ADM is continually evaluating options for improving processes and efficiencies in order to reduce the quantities of hazardous materials used and stored at its facilities. In addition, ADM continually evaluates options at its facilities for replacing hazardous materials with less hazardous or non-hazardous substitutes. |