A.E. Staley Manufacturing Company- Houlton - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES We at A.E. Staley Manufacturing Company-Houlton are strongly committed to employee, public, and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. THE STATIONARY SOURCE AND THE REGULATED SUBSTANCES HANDLED Our facility's primary activities encompass the manufacture of modified starches for industrial use. We have one regulated substance at our facility. This substance is Propylene Oxide [oxirane,methly-]. Propylene Oxide is used for starch product substitution. The maximum inventory of Propylene Oxide at our facility is 180,000 lb. A railcar containing a maximum of 170,000 lb. is staged into the facili ty when the Propylene Oxide bulk tank level is at or under 10,000 lb. THE WORST CASE RELEASE SCENARIO AND THE ALTERNATE RELEASE SCENARIOS We used EPA's RMP Guidance for Offsite Consequence Analysis, RMP Comp* and RMP Submit* to evaluate the Worst Case and Alternate Release Scenario for Propylene Oxide. The following paragraphs provide details of the chosen scenarios. The PROPYLENE OXIDE WORST CASE RELEASE SCENARIO submitted involves a catastrophic release from the Propylene Oxide railcar outside of the sump area under the car. A Propylene Oxide railcar may contain more than the maximum inventory of the facility Propylene Oxide bulk tank. At class F atmospheric stability, 1.5 m/s windspeed, and rural topography the distance of 6.8miles is obtained corresponding to a toxic endpoint of 0.59 mg/L. THE PROPYLENE OXIDE ALTERNATE RELEASE SCENARIO involves a break of a transfer line between a full rail car pressurized to 3 psig with a nitrogen blanket and the Propylene Oxide bulk tank. T he scenario involves the release of 10,300 lb of Propylene Oxide. The operator would immediately shut off the nitrogen pressurizing the car. The Propylene Oxide release would continue for 11 minutes until the pressure falls to atmospheric. The toxic liquid released is assumed to form a pool on the ground within the containment area that directs any spills back to the diked area around the bulk tank. Assuming neutral weather conditions of class D atmospheric stability and 3 m/s wind speed and an urban topography the maximum distance to the toxic endpoint of 0.59mg/L of Propylene Oxide is less than 0.1 miles. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE CHEMICAL-SPECIFIC PREVENTION STEPS Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-30 Standard, 1957 edition, applicable ANSI and ASME standards and per chemical supplier recommendations. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. PROCESS SAFETY INFORMATION-A.E. Staley Manufacturing Company-Houlton maintains a record of safety information that describes the chemical hazards, operating parameters, and equipment design associated with all processes. PROCESS HAZARD ANALYSIS-Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is the What If Scenarios. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at regular intervals. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA review for the Propylene Oxide system was performed in March 1999. OPERATING PROCEDURES-For the purposes of s afely conducting activities within our covered processes, A.E. Staley Manufacturing Company-Houlton maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operation, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup after a maintenance shutdown. The information is regularly reviewed and is readily accessible to operators involved in the processes. TRAINING-A.E. Staley Manufacturing-Houlton has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided as needed. MECHANICAL INTEGRITY-A.E. Staley Manufacturing Company-Houlton carries out documented maintenance checks on process equipment to insure proper operations. Process equipment examined by these checks includes: pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Qualified personnel carry out maintenance operations with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. MANAGEMENT OF CHANGE-Written procedures are in place at A.E. Staley Manufacturing-Houlton to manage changes in process chemicals, technology, equipment, and procedures. The most recent review/revision of maintenance procedures was performed in March, 1999. Process operators, maintenance personnel, or any other employee whose job task are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. PRE-START UP REVIEW-Pre-start up safety review related to new processes and to modifications is established processes are conducted as a regular practice at A.E. Staley Manufacturing Com pany-Houlton. These reviews are conducted to confirm that construction, equipment, operating, and maintenance procedures are suitable for safe startup prior to placing equipment in operation. COMPLIANCE AUDITS-A.E. Staley Manufacturing Company-Houlton receives corporate audits on a regular basis to determine compliance with applicable environmental and safety regulations. The chemical supplier also performs regular audits of the propylene oxide storage and handling facilities at the plant. Any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. INCIDENT INVESTIGATION-A.E. Staley Manufacturing Company-Houlton promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a mi nimum of 5 years. EMPLOYEE PARTICIPATION-A.E. Staley Manufacturing Company-Houlton truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analysis. CONTRACTORS-Our company hires contractors to conduct specialized and routine maintenance and construction activities. Long term relationships have been established with the contractors that work on a routine basis. All contract personnel are required to have site specific training. This contractor training must be documented before a contract worker is allowed on the job site. The contractor safety representative meets with an A.E. Staley Manufacturing Company-Houlton representative regularly. T he contractor notifies A. E. Staley Manufacturing-Houlton about any incident involving a near miss, accident, or injury of contract personnel. A.E. Staley Manufacturing-Houlton keeps copies of the entire meeting notes and incident investigation reports to document past safety performance. A.E. Staley Manufacturing Company-Houlton has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. FIVE YEAR ACCIDENT HISTORY A.E. Staley Manufacturing Company-Houlton has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. EMERGENCY RESPONSE PLAN A.E. Staley Manufacturing Company-Houlton carries a written emergency response plan to deal with accidental relea ses of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan in promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Aroostook County Emergency Planning Committee is the Local Emergency Planning Committee with which our emergency plan has been coordinated and verified. |