Danisco Cultor America, Inc. - Executive Summary |
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Introduction and General Information Danisco Cultor America, Inc. (Danisco) owns and operates a hydrogenation facility located three miles north of Thomson, IL. It produces hydrogenated sugars (Xylitol) for commercial and industrial uses. The facility stores two chemicals in excess of the threshold quantities listed in the US EPA Accidental Release Protection Regulations in the Clean Air Act Section 112(r) (RMP). The facility is located at latitude N42:00.14650 and longitude W90:06.65139, in a rural setting in Carrol County, Illinois. The terrain in the local vicinity is flat to gently rolling land surface in a rural agricultural setting. The Mississippi River is located approximately one mile west of the facility, and the land use in that direction is agricultural. To the east, the land use is also agricultural, and the land to the south immediately abutting the facility is also agricultural, but approximately three miles south of the facility is the village of Thomson, IL. The land t o the north of the facility is also agricultural lands, and the city of Savanna, IL is approximately seven miles north. According to the 1992 data for the Quad Cities Airport in Moline, IL, (nearest data source), the prevailing wind in the vicinity comes out of the south to northwest (approximately 180o to 330o). The average wind speed is 7.21 Knots (8.29 miles per hour). The stronger winds come out of 300o to 330o with velocities of as much as 17 to 21 Knots, and on limited occasions (<1%) the wind velocities exceed 21 Knots. The quadrant from 180o to 270o provides the majority of the winds. They are less intense (11 to 16 Knots maximum) but represent approximately 35% of the windy days. Winds are calm approximately 12.3% of the time. This data is based on 24 hours a day, 365 days per year for the year 1992. In computing and modeling the worst case scenarios the atmospheric stability class was set to "F" and the wind speed was set at 1.5 meters per second in accordance with the US EPA guidance. For the alternative scenarios, a wind speed of 1.5 meters per second and an atmospheric stability class of "D" was used in accordance with the US EPA guidance. This was necessary due to the lack of the most recent three-year meteorological data. Accident History Danisco operates a modern facility with state of the art safety policies, practices and systems. There were no accidental releases of regulated chemicals, but five "incidents" that involve the hydrogenation process occurred during the preceding five years. These include the following: Date Process Description 8/22/97 Hydrogenation Small fire occurred during maintenance of the agitator. There were no injuries or property damage. The fire self-extinguished and no response was necessary. 10/1/97 Hydrogenation All gas alarms activated, emergency shutdown for gas leak on the catalyst tank sight glass gasket. No injuries or property damage. 5/28/98 Hydrogenation Storm and wind damage to hydrogenation building. No injuries , and property damage limited to act of God, not involving regulated chemicals. 4/3/99 Hydrogenation Leak on valve packing caused the gas detection system to alarm. The packing was repaired and there were no injuries and no property damage. 4/14/99 Hydrogenation Small fire occurred at the catalyst line where it enters the reactor. Fire self extinguished and response was not required. There were no injuries or property damage. There have been no off-site consequences involving regulated processes, or regulated chemicals, at the facility. There is no five-year accident history involving either regulated processes or chemicals that involve personnel injury, death or significant property damage. Hydrogen Storage System Danisco's facility includes a hydrogen tank that contains 20,000 gallons of liquid hydrogen. Hydrogen in that quantity requires that the system comply with RMP Program Level III regulations. At 4.423 lbs per ft3, the capacity of the tank in pounds is calculated using the fol lowing formula: Cubic Feet of Hydrogen in Tank=20,000 gallons x .1337 gal/ft3 Cubic Feet of Hydrogen=2,674 Pounds of Hydrogen=2,674 x 4.423 lbs/ft3 Pounds of Hydrogen=11,827.1 According to US EPA's RMP*Comp? Version 1.06 (RMPComp), that quantity of hydrogen results in a 0.3-mile radius to the one pound per square inch (p.s.i.) overpressure endpoint. The catastrophic failure of the hydrogen tank is very unlikely. The tank has safety devices and systems to prevent or minimize the effect of any accidental release of hydrogen. A more realistic scenario (alternative scenario) would be the accidental release of the contents of a delivery trailer. These trailers have internal safety devices, as does the tank system itself, to help prevent such releases, and the drivers and plant operators are fully trained in the handling of hydrogen and the associated emergencies. A typical delivery truck carries between 12,000 and 13,000 gallons. The accidental release of that quantity results in a maxim um of 7,687.6 pounds of hydrogen entering the atmosphere. In addition, if the safety systems failed, there could be an additional release from the hydrogen tank of a portion of its contents. It was assumed that the time to react and isolate the tank using the remote operated valves would result in the release of 25% of its contents, or 2,956.78 pounds, for a total release 10,644.38 pounds. According to RMPComp, the distance to the one p.s.i. overpressure endpoint is 0.2 miles, based on a one minute release time and a resulting vapor cloud explosion. The off-site consequence analysis indicates that there are public or environmental receptors within the 0.3-mile radius of the hydrogen tank (worst case). There are public receptors within the 0.2-mile radius of the alternative case scenario. The demographic data indicate that there are approximately nine persons located in four households within the radius of the worst case scenario, and four persons located in two households within the r adius of the alternative case scenario. There is an environmental receptor that is indicated in the demographics reports. This is the Sandridge School, but further investigation indicates that the school has been closed for several years. Emergency Assistance Emergency assistance is provided by the Thomson, IL Fire Protection District with mutual aid assistance agreements with Savanna, IL, and Mount Carrol, IL, Fire Departments. Savanna is located approximately 7.0 miles north of the facility, and Mount Carrol is located approximately 9.0 miles east of Savanna, for a total response distance of 16.0 miles. There is a Local Emergency Planning Commission (LEPC) for Carrol County, IL. Mutual aid response times are approximately 30 minutes from the initiation of the notice. The Carrol County LEPC is located in Mount Carrol, IL. Although this organization is formed, it is not active and does not provide emergency response or coordination services at this time. Danisco has trained its personn el in emergency response and emergency operations. Each supervisor is trained to provide the immediate response with the personnel assigned to work in the area. Additional support is provided through coordination of the emergency with outside agencies through use of the plant emergency notification system. Process Safety Information Danisco maintains all of the safety information required by RMP. This includes Material Safety Data Sheets (MSDS), maximum intended inventories of regulated chemicals, safe upper and lower temperatures, pressures and flows, and equipment specifications and manufacturing codes. The facility has been designed by industry-accepted standards and good engineering practices. Updates to the safety information will be made through the management of change procedures. Hazard Reviews and Process Hazard Analyses Danisco performs hazard reviews or process hazard analyses (as appropriate) on all systems and has a program to address any deficiencies noted during the rev iew. These reviews are performed by facility personnel that are thoroughly familiar with the processes, using generally accepted procedures. Reviews are repeated at least every five years. Operating Procedures All operations at the facility are conducted using standard operating procedures by operations personnel that are thoroughly trained on system operations. The operating procedures cover steps for each operation, initial startup, normal operations, temporary operations, emergency shutdown, emergency operations and startup after turn-around or emergency shutdown. Training Cultor provides all personnel with the appropriate training. This includes initial and annual refresher training for all facility personnel. Mechanical Integrity Maintenance is assured by a Work Order System that is computer monitored to assure that preventative and corrective maintenance is performed by the required dates. All maintenance personnel are trained to perform the various functions required by the Wor k Orders. All process equipment is inspected in accordance with generally accepted engineering practice consistent with the industry standards. There is a program to address the maintenance deficiencies noted. Management of Change The facility has a management of change policy that requires a review of all proposed changes except for replacement in kind. Management of change requires that those employees affected by the change be informed of, and receive training in, the change prior to its startup. Pre-Startup Review The facility performs pre-startup reviews and provides employees training in the new or modified process prior to its startup. Compliance Audits The facility has a policy requiring an audit by a person familiar with the processes at least every three years. There is also a policy to address the audit findings on a timely basis. Incident Investigations The facility has an incident investigation policy. All investigations are documented and reviewed to determine the appropr iate preventative measures. These investigations occur within forty-eight hours of the incident and involve an incident investigation team that consists of representatives of the facility operations staff, management and any contractors that might be involved in the incident. Any recommendations made by the investigation team are acted upon by the facility as soon as possible. All incident investigation reports are maintained for at least five years. Employee Participation The facility has a written Employee Participation Plan, and employees are customarily consulted on all changes and the development of process hazard analyses. Hot Work Permits The facility has a Work Permit Policy (S-31, revised 4/2000) that includes a hot work permitting procedure. This policy complies with the requirements of the RMP. Contractors The facility has a Contractor Safety Policy (S-14, revised 3/11/2000). This policy complies with all of the requirements of the RMP. Emergency Response The facility has an Emergency Response Plan (S-10 revised 6/28/99) intended to protect human health and the environment. There is a procedure for the notification of local emergency response agencies and the public. Training is provided to all employees on the Emergency Response Plan and the emergency equipment available at the facility. This Emergency Response Plan is updated as often as necessary, but not less than once every three years. The facility conducts coordinated drills with local emergency response agencies to ensure that in the event of an emergency, all response personnel are familiar with the requisite tasks. Conclusions Danisco operates a modern, well-managed facility with ample maintenance, training and emergency planning to minimize to, the extent possible, the possibility of adverse effects on human health and the environment. Should an accident occur, the Facility is fully capable of responding in a manner that will minimize the possibilities of off-site consequences. Management is co mmitted to proper and safe operations and has the full support and cooperation of the operation and maintenance staffs. |