Don Siding Complex, South of Highway 30 - Executive Summary

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Executive Summary of the 
To comply with EPA Standards in 
40 CFR 68.112 (r) (7) 
J. R. Simplot Company 
Don Plant 
1150 West Highway 30 
Pocatello, ID  83201 
May 1999 
As required by Title 40, Code of Federal Regulations, Part 68, Section 115 (40 CFR 68.115), the owner or operator of a regulated source shall provide a Risk Management Plan (RMP), the Executive Summary of which includes brief descriptions as follows: 
Accidental release prevention and emergency response policies 
The J. R. Simplot Company Don Plant, Don Siding, Idaho is committed to being a responsible community partner.  Emergency response planning and training of all employees is current and ongoing.  Every reasonable effort is made to prevent a "significant accidental release" to the air. The Chubbuck Fire Department and local emergency agencies receive the annual Sara Title III reports on materials manufactured, stored, and handled at the Don Plant. Simplot's policy is to fully c 
ooperate with all inspections and requests for information from the regulatory agencies. 
The stationary source and regulated substances manufactured, processed, stored, or handled 
The J. R. Simplot Company, Don Plant facility manufactures fertilizer, industrial chemicals, and animal feed supplements. The Don Plant manufactures, processes, stores and handles anhydrous ammonia in quantities exceeding the threshold limits requiring an RMP. 
The worst-case release scenario and the alternative release scenarios 
These scenarios include administrative controls and mitigation measures to limit the distances for each potential scenario. 
Six dispersion models were done for release of ammonia from the Simplot Don plant 
A worst case scenario and five alternative release scenarios were modeled. 
The worst case scenario assumed  the rupture of one high-pressure storage "bullet"  
In this scenario the bullet would release its entire 79 tons of ammonia in 10 minutes.  Concrete barriers around the bullets 
, preventing vehicle contact, has reduced the potential for this scenario.  The recent replacement of both bullets has reduced the potential for mechanical failure. 
The first alternative release scenario assumed that a pressure relief valve opened and stayed open for ten minutes 
The relief valve was assumed to open at 200 psig and stay stuck open for ten minutes.  The pressure relief valves vent vertically directly above the tank. The implementation of maintenance procedures to regularly verify proper operation of  pressure relief valves has reduced the potential for this scenario. 
The second alternative release scenario assumed that a standard loading hose broke 
This hose would be transferring ammonia from the high-pressure bullet tank at the loading dock.  The bullets were assumed to be at normal pressures of 110 psig.  The assumption was made that the release would continue for ten minutes before flow could be shut off.  The potential for this release has been virtually eliminated b 
y high flow shut off valves on each bullet. 
The third alternative release scenario assumed that the entire 6500 tons of ammonia in  the low-pressure storage vessel was released 
Guidelines in 40 CFR 68 dictate that the release be modeled as an instantaneous 1cm deep pool.  It is unrealistic to assume that liquid ammonia could spread over this large an area at a uniform thickness without evaporating as it covers the area.  The secondary containment berm would mitigate a release from the low-pressure storage vessel.  Pressure relief valves prevent the vessel from being over-pressurized. 
The fourth alternative release scenario also assumed that the entire 6500 tons of ammonia in  the low-pressure storage vessel was released over ten  minutes 
This scenario was modeled with the more realistic assumption of continuous evaporation as the pool expanded.  As with the third scenario, the secondary containment berm would mitigate a release from the low-pressure storage vessel, and pressure relief  
valves prevent the vessel from being over-pressurized. 
The fifth alternative release scenario assumed a release from a leak below the liquid level in the low-pressure storage tank, filling only the secondary containment berm 
This scenario represented the most probable type of release from the low-pressure storage tank.  As with the third and fourth scenarios, the secondary containment berm would mitigate a release from the low-pressure storage vessel, and pressure relief valves prevent the vessel from being over-pressurized. 
The general accidental release prevention program and chemical-specific prevention steps 
Pipes and equipment handling anhydrous ammonia have pressure relief valves 
Vehicles access is restricted, , in areas where ammonia is present 
Process Safety Management has been implemented in all areas where anhydrous ammonia is present 
The following elements of the Process Safety Management program reduce the probability of an accidental significant release 
Process Safety Inf 
Process Hazard Analyses 
Standard Operating Procedures 
Mechanical Integrity 
Management of Change 
Pre-Startup Safety Reviews 
Compliance Audit Program 
Incident Investigations 
Employee Participation 
Hot Work Permits 
Contractor Safety 
The five-year accident history 
The J. R. Simplot Company Don Plant has had no significant accidental releases of ammonia with offsite consequences within the last five years. 
The emergency response program 
The Simplot Tactical Area Response Team (STAR Team) 
The STAR Team is a Simplot emergency response team comprised of trained employees.  These employees are trained to respond to fires (in their incipient stages); chemical; medical; and evacuation/rescue emergencies at the Don Plant. 
In-plant emergency response: The Emergency Response Plan 
In-plant emergency response is governed by the OSHA PSM:  Emergency Response Plan.  The plan includes instructions to employees on incident command and employee evacuation.  The plan also requires regular  
evacuation drills. 
The Hazardous Waste Management Contingency Plan and Emergency Procedures for Spills and Releases of Hazardous Materials 
The plan and emergency procedures cover spills/releases of hazardous materials at the Don Plant.  This plan is an appendix to the PSM:  Emergency Response Plan.  The plan contains the following elements 
Reporting Procedures and Incident Identification 
Spill Containment and Cleanup 
Don Plant Emergency Response Training 
Training Plan 
External Emergency Response 
The Chubbuck City Volunteer Fire Department will respond to a fire emergency at the Don Plant.  The Pocatello Fire Department is the designated backup for Chubbuck.  The Southeast Idaho HAZMAT Team is a division of the Pocatello Fire Department and is a support unit for the State of Idaho Bureau of Disaster Services.  Power County Sheriff' Department has a mutual-aid agreement with the Bannock County Sheriff's Department.  The Idaho State Police would respond to any incident involv 
ing the state highways near the plant, Highways 30 and I-86. 
Commitment to Safety 
Employee emphasis on "Safety First", to achieve a "Zero-injury" workplace 
The results of the major emphasis on "Safety First" at the Don Plant are reflected in the recent achievement of over 500,000 manhours worked without a lost-time-away injury.  Achieving a "Zero-injury" workplace is the goal of every employee at the Don Plant 
Employee commitment to becoming an OSHA Star Facility 
The Don Plant employees are committed to becoming a "Star Facility" under the OSHA Voluntary Protection Program (VPP).  The plant has had an OSHA VPP inspection.  Plant employees and contractors are now developing a list of improvement ideas.  The plant has a goal to resubmit a VPP application with OSHA and request a final VPP inspection in late 1999. 
Management commitment to becoming an OSHA Star Facility 
An independent contractor will audit the plant in preparation for the final OSHA VPP inspection.  This will include reeval 
uating all PSM programs and suggesting improvements as necessary.
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