Southern Minnesota Beet Sugar Cooperative - Executive Summary |
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Accidental Release Prevention and Emergency Response Policies The Southern Minnesota Beet Sugar Cooperative (SMBSC) is committed to the protection of its employees, the greater community and the environment from any hazardous substances used in the sugar beet processing and refining operation, specifically the sulfur dioxide used in the process. It is the policy of SMBSC to comply with all Federal, State and Local laws. Facility Description and Regulated Substance Handled The SMBSC operates a beet sugar processing and refining facility in Renville, Renville County, Minnesota. The facility's principal products are beet sugar, beet pulp pellets and molasses by-products. The sugar beet refining process requires the use of sulfur dioxide to control pH and color. The maximum amount of sulfur dioxide stored on-site is estimated to be 146,000 pounds. The sulfur dioxide is stored as a liquid and is vaporized via an evaporator for process usage. Worst Case Scenario The EPA definition of the worst-case release scenario is the release of the entire contents of the largest storage vessel in a 10-minute period. The purpose of analyzing the worst case release is to determine the facility's RMP program level eligibility, and to provide for a consistent yardstick from facility to facility to "level the playing field". The worst case scenario for the sulfur dioxide system is the loss of the entire tank content of 146,000 pounds in 10 minutes. For a number of reasons, including the thermodynamic properties of liquid sulfur dioxide, this is an extremely improbable and technically infeasable scenario. The conditions of the worst case scenario are prescribed by EPA requirements. It is important to remember that this type of release scenario would require the occurance of a catastrophic event, or series of events, which have a very low likelihood of ever happening. The EPA look-up table, Exhibit 4-6, in Section 4.1 of the Risk Management Program Guidance for Wastewater Tr eatment Plants document indicates the maximum distance to toxic endpoint is 25 miles for a release rate of 14,600 pounds per minute. According to the Environmental Data Resources, Inc. receptor report 0374193.1r dated May 26, 1999, the estimated population within the 25 mile radius is 55,000 people. Alternate Case Scenario The alternate case scenario is defined by the EPA as a release that is significantly more likely to occur than the worse case scenario. For the SMBSC facility the alternate release was modeled as a one-inch diameter hole on the liquid side of the sulfur dioxide system. The EPA look-up table, Exhibit 4-16, in Section 4.2 of the Risk Management Program Guidance for Wastewater Treatment Plant document indicates a 1,600 pounds per minute release rate and a distance to toxic endpoint of 1.9 miles. According to the Environmental Data Resourses, Inc. receptor report 0374098.1r dated May 26, 1999, the estimated population within the 1.9 mile radius is 160 people. Gen eral Accident Release Prevention Program Through completion of this RMP, SMBSC has complied with the EPA requirements under 40 CFR 68. Process safety information and operations/maintenance procedures are documented on site. Periodic functions such as process hazard analysis, training, change management and incident investigation are conducted on a regular basis. Audits of the overall RMP will be conducted on a regular basis to assure compliance with EPA regulations. Five-Year Accident History SMBSC has not had a sulfur dioxide accident causing deaths, injuries, environmental or property damage, evacuations, or in-place sheltering in the last five years at the sugar beet processing facility. The Emergency Response Program In the event of an emergency, it is the policy of SMBSC to notify the local (City of Renville) Fire Department and evacuate all employees from the facility. |