The Amalgamated Sugar Company, LLC - Executive Summary |
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7 elements of the RMP as noted in 40 CFR Part 68.155 have been briefly described below. 1.) Accidental release prevention and emergency response policies at the Nyssa facility: a. As per 29 CFR 1910, a "Process Safety Management Plan" (PSM) has been developed and implemented to prevent & minimize the release of specified chemicals including sulfur dioxide. This plan protects both onsite workers and the public. b. Technical review of RMP by "Local Emergency Planning Committee" (LEPC) & Fire Dept. c. Accidental releases to be reported as per "Emergency Planning Community Right to Know Act" (EPCRA 302 & 355). d. Incidental minor leaks (ex: leaking fitting) will be addressed by facility operators following the Nyssa facility's Emergency Action Plan for SO2. e. Nyssa Fire Department and if necessary Ontario HAZMAT Response Team to be notified on reportable releases. 2.) Stationary source & hazardous m aterial handled. a. Stationary source is a rail car. b. Material is anhydrous sulfur dioxide (SO2), liquidified under pressure. 3.) Off site consequence analysis - worse & alternate case scenarios, including administrative controls and mitigation measures. a. Both worse & alternate case scenarios were modeled using the EPA's RMP*COMP Model. The RMP*COMP predictive computer model used in this analysis is considered by the EPA to be a conservative modeling tool and the modeled results may not be representative of an actual release. Additionally, the EPA does not consider the distances to toxic endpoints to be a "public danger zone". b. Worse case scenario predicts the distance to endpoint to be 16 miles. This scenario involves the total structural failure of an SO2 rail car. These rail cars are built to D.O.T. specifications and are routinely inspected under D.O.T. guidelines. Additionally, each rail car is leak checked both prior to and after every loading. A total structural failure of a railcar is a highly improbable scenario. To further minimize the possibility of this scenario, a "Process Safety Management Plan" (PSM) has been implemented as outlined in 29CFR1910. SO2 storage rail cars meet D.O.T. specifications and are securely chocked in place on a dedicated track during storage & unloading. Additionally, SO2 rail cars are only on site during beet processing campaigns which last ~5 months per year (~Oct. through Feb.). Once the beet processing campaign is over, the SO2 rail cars are returned to the chemical vender. c. Alternate scenario modeling which is more likely to occur than the worse case scenario predicted the endpoint distance to be 0.20 miles. This scenario involves a tubing break with a 5 minute duration. Building walls act as passive mitigation a nd remote control solenoid isolation valves act as active mitigation. This 0.20 mile distance is contained within the factory site on all sides with the exception of the north side of the factory where the endpoint extends ~ 700 feet from the north factory fence line. 4. The general accidental release prevention program & chemical-specific prevention steps. a. A PSM has been implemented as outlined in 29CFR1910. b. An emergency rail car capping kit is on site to securely isolate any leaking rail car fittings or valves. c. Remote control solenoid valves have been installed at several locations on SO2 transfer lines. In event of a leak, these valves can be triggered to isolate both the rail car and sections of the transfer piping. d. To minimize the possibility of leaks, the main 3/4'' transfer line is constructed of stainless steel pipe with socket weld joints. Thus minimizing the p ossibility of fitting leaks. e. Depending on ambient temperatures, liquid spills forming puddles may be neutralized using calcuim carbonate which is present on site. f. Accidental release prevention program has been discussed with local fire depts. & LEPCs. g. In addition to a remote controlled solenoid isolation valve on the rail car, each rail car is equipped with an excess flow check valve which is designed to automatically close in excessive flow situations. This is additional protection in the event of a major line break. h. SO2 rail cars are only stored on site during beet processing campaigns which last ~ 5 months per year. Following each beet processing campaign the rail cars are returned to the chemical vender. 5. Five year accident history. a. There have been no recorded SO2 accidents (releases) in the last 5 years at the Nyssa facility. 6. The emergency response program. a. Ac cidental releases to be reported as per EPCRA 302 & 355. b. Incidental releases will be addressed by facility operators following the Nyssa facility's Emergency Action Plan for SO2. c. Nyssa Fire Department and if necessary Ontario HAZMAT Response Team to be notified on reportable releases. 7. Planned changes to improve safety. a. Alternative disinfection techniques are currently being evaluated. New & improved technology may allow for the reduction or elimination of SO2 in the future. |