Diversified Energy Co., LLC (DENCO) - Executive Summary

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Accidental Release Prevention and Emergency Response Policies 
 
Diversified Energy Company, LLC (DENCO) is committed to the protection of its employees, the greater community and the environment from hazardous substances used in the ethanol fuel production process, specifically the natural gasoline used as the ethanol denaturant. The natural gasoline is added to the ethanol to make the ethanol unfit for human consumption. It is the policy of DENCO to comply with all applicable federal, state and local laws. 
 
Facility Description and Regulated Substance Handled 
 
DENCO operates an ethanol fuel production plant located near Morris, in Stevens County, Minnesota. The facility produces fuel grade ethanol from corn and a process by-product known as dry distillers' grain with soluables, which is used as a livestock feed. The fuel ethanol production process requires use of a denaturant (natural gasoline) which is reported to contain 30 to 40 percent pentane, an RMP regulated substance. The maxim 
um amount of natural gasoline on-site is estimated to be 63,900 pounds. The natural gasoline is stored in a tank as a liquid and is introduced to the fuel ethanol in the final stage of production. The denaturant tank is located in the facility's tank farm area which is designed to contain stored materials within the tank farm area. 
 
Off-Site Consequence Analysis 
 
In addition to identifying and reporting regulated materials at the DENCO facility, the U.S. Environmental Protection Agency's (EPA's) Risk Management Plan (RMP) program guidance requires companies to share with their communities a look at the worst possible accident that could happen at a facility (as unlikely as that might be) and an alternative, more realistic accident scenario. 
 
RMP*Comp, a software tool developed by the U.S. National Oceanic and Atmospheric Administration was used to perform an off-site consequence analysis for the DENCO facility. The worst case scenario defined by RMP Guidance is a failure of the natura 
l gasoline storage tank resulting in a vapor cloud explosion. The software modeling program considered release of the entire contents of the denaturant tank, a wind speed of 3.4 miles per hour and an air temperature of 77 degrees F. The analysis projected an off-site endpoint for the release. The alternate case analysis also used RMP*Comp and considered failure of the tank with a release rate of 1080 pounds per minute and a subsequent vapor cloud fire. Atmospheric conditions included a wind speed of 6.7 miles per hour, an air temperature of 77 degrees F and the modeling assumed the release occurred within the tank farm's containment basin. The resulting endpoint was off-site from the facility. 
 
General Accidental Release Prevention Program 
 
Through completion of this RMP, DENCO has complied with the EPA requirements under 40 CFR Part 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 
 
DENCO or the previous owner have not had a natural gasoline accident causing death, injuries, environmental or property damage, evacuations or in-place sheltering in the last five years at the fuel production facility. The facility began operation in April of 1994. The facility was shutdown for expansion on February 26, 1999, and denaturant below the 10,000 pound threshold has been stored since that date.  Expansion of the facility will require storage of the denaturant in quantities above the RMP threshold of 10,000 pounds for pentane once the facility starts up again after October 15, 1999.   
 
The Emergency Response Program 
 
In the event of an emergency, it is the policy of DENCO to notify the City of Morris Fire Department and evacuate all employees from the facility.
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