JR Simplot Company Helm Plant - Executive Summary

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40 CFR 68.155 states that the owner or operator of a regulated source shall provide in the RMP an executive summary that includes a brief description of the following elements: 
a) Accidental release prevention and emergency response policies:  
"It is the policy of the J. R. Simplot Company to manufacture, handle, transport, store and dispose of all substances safely and in compliance with the requirements of federal, state and local environmental laws while reducing the risks to human health, safety and the environment."  
The J.R. Simplot Company, Helm, California, is committed to being a responsible community partner. Training in emergency procedures is current and ongoing.  Every effort is made to prevent accidental releases and, in the very unlikely event of a release, to be prepared to keep offsite consequences to a minimum.  The Mid-Valley Fire District and the Fresno County Health Department are informed of all substances manufactured, stored, and handled at this facility and  
we fully cooperate with all inspections and requests for information from the regulatory community.  
b) The stationary source and regulated substances handled: 
The J. R. Simplot Company, Helm facility produces fertilizer and industrial chemicals. Three of the chemicals listed in 40 CFR 68.130, anhydrous ammonia, 98 % nitric acid and butane, are processed, stored, and handled in quantities exceeding threshold limits for this report. 
c) The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario: 
Two dispersion scenarios were modeled for all three chemicals under the regulation: one to show the EPA-required scenario called the "worst-case," and one "alternate-case" scenario that depicts a more credible possible incident and how it could affect the surrounding area.   
The "worst-case" scenario for anhydrous ammonia is based on a 10-minute gas release of 85 tons  
from the largest vessel and allows for no active mitigation. This EPA-required scenario is comparable to an airplane falling out of the sky and landing directly on an ammonia storage tank.  Administrative controls limit storage to 85 % of maximum capacity.  Air dispersion modeling suggests off-site consequences for this scenario.   
A more credible release could occur if a hose ruptured or came uncoupled while unloading a truck of anhydrous ammonia.  This scenario is used for the "alternate scenario" for anhydrous ammonia as required by section 112(r).  Administrative controls are in place to prevent this occurrence.  In addition, active mitigation measures consisting of check valves, excess flow valves, and emergency shut-off valves are in place to mitigate consequences.  Air dispersion modeling suggests that this scenario could potentially release 35,000 lbs of anhydrous ammonia if active mitigation measures fail.  An unmitigated release has the potential for off-site consequences.   
With the wind coming from the north-west which is common for the area, the vapor would disperse over an empty field before reaching a populated area. 
The "worst-case" scenario for 98 % nitric acid assumes that 100 tons (the entire contents of one rail car) are spilled forming a pool 1 cm deep.  No passive mitigation systems are in place.  Air dispersion modeling indicates that 67,000 lbs could be released to the air over 40 minutes.  The "worst-case" scenario has off-site consequences. 
The "alternate-case" for 98 % nitric acid considers a scenario where an operator tries to pull the 98 % rail car from the loadout rack while it is being unloaded.  Although administrative controls are in place to prevent such an occurrence, it is the most probable scenario for a large scale 98 % nitric acid release.  Air dispersion modeling indicates 3,100 lbs of nitric acid could be released to the air (if active mitigation measures fail) over 34 minutes resulting in no off-site consequences. 
The "wo 
rst-case" scenario for butane assumes that 65 tons (the entire contents of the largest tank of butane) are involved in a vapor cloud explosion with a 10 % yield factor as required by law.  An event that could cause this type of incident would be on the order of a meteor falling directly onto the tank.  Administrative controls limit the storage to 90 % of maximum capacity.  No passive mitigation systems are in place. The "worst-case" scenario has no off-site receptors as a result of the vapor cloud explosion.  However, a release similar to that of the worst case for 98 % nitric acid could occur since the 98 % nitric acid rail car is unloaded in the vulnerable zone for this type of vapor cloud explosion. 
The "alternate case" for butane considers a scenario where a truck driver pulls away from the unloading rack while the hoses are still connected.  Although administrative controls, check valves, excess flow valves, and break-away nipples are in place to prevent and mitigate this kind of 
occurrence, it is still the most likely scenario that a large scale release could occur.  No passive mitigation systems are in place.  Modeling results show that if active mitigation measures fail, 35,000 lbs of butane could be released resulting in a potential fireball.  This scenario has no off-site receptors. 
d) The general accidental release prevention program and chemical-specific prevention steps: 
All employees assigned to work in the areas where ammonia, 98 % nitric acid, and butane are handled are trained in the safe handling of these materials. Employees receive initial training appropriate to the job when hired or when re-assigned.  Periodic training is conducted for such things as operating procedures, emergency procedures, chemical hazards, lock-out/tag-out, mechanical integrity, methods to avoid accidental releases, etc.  
In addition to training, the following precautions are taken in areas where butane, ammonia, and 98 % nitric acid are handled: 
7 Pipes carrying regu 
lated chemicals are clearly labeled and have pressure relief valves.   
7 All tanks containing regulated chemicals are blocked to prevent vehicles from striking them.   
7 Material specification policy is in place to prevent replacing parts with inadequate materials of construction. 
7 Preventative maintenance tools ensure storage and conveyance integrity. 
7 Written design review procedures are used whenever changes are made to applicable equipment or piping to prevent failure due to improper engineering of modifications. 
7 Line-blanking, confined space entry, and hot work permits are required before starting work. 
7 A hazard analysis is performed before operating any new process that handles a regulated chemical. Analysis covers all possible scenarios and potential emission points. 
e) The five-year accident history: 
In the specified time period, the Helm plant has had no accidental releases of anhydrous ammonia, butane, or 98 % nitric acid with offsite consequences as defined by CFR 68 
f) The emergency procedures: 
Training is conducted at least once each calendar year and in accordance with CAL_OSHA regulations.  The team uses a written Emergency Action Plan to mitigate the consequences of possible chemical spills and releases at the Helm facility.  The plan contains instructions for evacuation of plant personnel, contacting outside emergency response authorities and potential off-site receptors, shut-down/startup, fire and explosion, and emergency first aid.  Evacuation drills are conducted once a year.  Any significant chemical release would be reported as required by law and emergency response coordinated with local authorities to ensure the safety of the community. 
g) Planned changes to improve safety: 
To improve our overall safety program, safety rules and training will be updated on a regular basis to assure that they continue to meet new applicable regulations and that they ensure an adequate level of safety for employees, visitors, contractors, and o 
ff-site populations.  Safety training is mandatory for all employees.  Overall safety improvements will be realized though continual process hazards assessments, safety meetings and inspections. 
The J. R. Simplot Company, Helm plant, will continue to be vigilant in environmental compliance and safety in all processes, plants, and equipment.
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