Sutherland Associates, L.L.C. - Executive Summary |
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RISK MANAGEMENT PLAN EXECUTIVE SUMMARY SUTHERLAND ETHANOL PLANT AND RESEARCH & DEVELOPMENT FACILITY SUTHERLAND ASSOCIATES, LLC, SUTHERLAND, NE Accidental Release Prevention and Response Policies Sutherland Associates, LLC has a commitment to worker and public safety. This commitment is demonstrated in the resources invested in accident prevention, such as training personnel as well as considering safety in the design, installation, operation, and maintenance of the facility. Sutherland's policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, plant personnel will respond to contain and control the release, as necessary. Description of the Stationary Source and Regulated Substances The Sutherland Ethanol Plant is located approximately 2 miles east of the Town of Sutherland, Nebraska. The facility operates 24 hours per day, 7 days per week for the purpose of manufacturing fuel grade ethanol from corn. The only substance regulated under the RMP Program is denaturant, which contains regulated flammable chemicals such as propane, isopentane, and butane. Sutherland has evaluated denaturants from several suppliers with the RMP Comp program and determined that the radius of impact from a worst-case release remains the same. This is due primarily to the fact that available denaturants are fairly similar in composition. As such, this RMP is submitted to cover any denaturant stored at the facility, regardless of the supplier. Off-site Consequence Analysis Results The worst-case scenario at the facility is the release of denaturant stored in an 18,500 gallon aboveground storage tank followed by ignition of the resulting vapor cloud. The worst-case scenario is based on the release of a full tank (18,500 gallons). The worst-case vapor cloud explosion generates a 1 psig over-pressure endpoint approximately 0.3 miles from the center of the plant. There are no pu blic receptors, environmental receptors, or population centers within this distance. Although Sutherland has numerous controls in place to prevent such a release and to manage potential consequences, no credit for administrative controls or passive mitigation measures were taken into account in evaluating this scenario. Since the facility qualifies as a Program Level 1, no Alternative Release Scenario (ARS) was required. Five Year Accident History Sutherland Associates, LLC started operations at the site on November 20, 1999. There have been no onsite or offsite accidents, as defined by EPA's General Guidance on Risk Management Programs during Sutherland's ownership. Emergency Response Program Information The Sutherland Ethanol Plant and Research & Development Facility has several safety programs in place at the facility that incorporate emergency response, including the Health & Safety Plan and the Spill Prevention Countermeasure and Control Plan (SPCC) , wh ich are updated as necessary. The SPCC includes spill prevention and response specifically related to the denaturant tank. The facility also conducts employee training as part of facility activities. Sutherland's corporate policy places the utmost importance on worker, public and environmental safety, which is reflected in facility plans and training activities. |