Minnesota Corn Processors - Columbus Facility - Executive Summary |
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Executive Summary 1.0 Introduction This Risk Management Plan (RMPlan) was prepared to meet the requirements of the U.S. Environmental Protection Agency (EPA) Risk Management Program (RMP) Rule (40 Code of Federal Regulation (CFR) 68). Minnesota Corn Processors (MCP) is a covered facility under the rule because processes contain more than a threshold quantity of a regulated substance. The MCP process meets Program Level 3 criteria. The actual components of the required RMP include: ( Conduct a hazard assessment (release scenarios) ( Develop and implement a accident prevention program ( Develop and implement an emergency response program ( Development and implementation of a management system organizational structure ( Submittal of a RMP Plan The purpose of the RMP is to prevent the accidental release and to minimize the consequences of any such release of hazardous substances. At MCP, we are committed to operating and maintaining our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: ( A description of our facility and use of substances regulated by EPA's RMP regulation ( A summary of results from our hazard assessment of the potential off-site consequences from accidental chemical releases ( A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule ( An overview of our accident prevention program ( An overview of our emergency response program ( An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment ( The certifications that EPA's RMP rule requires us to provide ( The detailed information (called data elements) about our risk management program 2.0 Stationary Source and Regulated Substances MCP operates a wet corn milling facility in Columbus, Nebraska. Operations at the site include raw material receiving and storage, corn processing and co-product separation, product storage and shipping. The primary products are corn sweeteners, cornstarch, and ethanol. In our processes, we use three toxic chemicals stored in quantities greater than the EPA RMP Threshold Quantity limit. The three chemicals and quantities are identified below. Toxics Quantity Threshold Quantity 1. Sulfur Dioxide 15,230 gal. AST (153,000 lbs. at 84% Admin. Control) 5,000 lbs. 2. Chlorine 8,000 lbs. (4 - 2,000 lb. Cylinders) 2,500 lbs. 3. Aqueous Ammonia (30%) 12,287 gal. AST (80,000 lbs. at 85% Admin. Control) 20,000 lbs. MCP does not use listed flammable substances in quantities exceeding EPA RMP Threshold Quantity li mits. Sulfur dioxide is used in the steeping process. Liquid sulfur dioxide is vaporized and introduced into the process water line. The vaporized sulfur dioxide is dissolved into the process water and produces a sulfurous acid solution. The sulfurous acid solution minimizes bacterial growth and prepares corn for further processing. The process water is recovered and added back into the process in a continuous loop. Chlorine is used as a water additive at the cooling towers and water reclaim tank. Chlorine is drawn into the water stream from storage cylinders to keep a bacteria-free system. Aqueous ammonia is used in the fermentors for ethanol production. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the potential hazards related to our use of these chemicals. Administrative controls, mitigation systems, and preventive measures used at MCP include: ( Chemical permit system for sulfur dioxide storage to limit the qu antity in the tank to 84 percent capacity ( Chemical permit system for ammonia (aqua) storage to limit the quantity in the tank to 85 percent capacity. ( High level tank alarm for filling operations ( Release sensors and alarms ( Excess flow valve/regulator (system shutdown) ( Pressure Relief Valves and Rupture Disks ( On-site emergency response team (HAZMAT) ( Monitoring of unloading operations ( A preventative maintenance program to ensure equipment integrity and proper operation ( Standard operating procedures ( Chlorine tanks designed and operated according to Chlorine Institute Standards. ( Pressurized vacuum flow system (system shutdown) ( Chlorine container response kit ( Scrubbers (Water fog) 3.0 Key Off-Site Consequence Analysis Scenarios EPA's RMP rule requires that we conduct a hazard assessment and provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. This information identifies the potential hazards and the po tential risks they pose. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit exposure distances for each scenario. Worst-Case Release Scenario The worst-case scenario (WCS) is an evaluation of the impact of a release of a hazardous substance from a complete failure (catastrophe) of the largest vessel, releasing the entire contents over a ten-minute period under the most stable weather conditions. The probability of a release meeting these conditions is extremely small. The worst-case toxic release scenario at MCP's Columbus Facility is the rupture of the sulfur dioxide outdoor, aboveground storage tank and release of the entire contents (153,000). The worst-case release would occur over a 10-minute period and the distance to the toxic endpoint (3 ppm) is 25 miles. The exposure distance was obtained using EPA Risk Management Program Guidance (EPA 550-B-98-010). There are no mitigation measures included in this scenario. Public and environmental receptors in this WCS include: residences, schools, hospitals, public recreational areas, commercial / industrial areas, national or state parks / forests and officially designated wildlife refuges. The population was estimated and public receptors were identified using Landview III mapping software and U.S. Census Data. Environmental receptors were identified using U.S. Geological Survey Quad Maps. Additional information regarding the WCS is included in the RMP Registration Data Elements. Alternate Release Scenarios An Alternate Release Scenario (ARS) is the evaluation of the impact of a release of smaller quantities of material. The causes and the amount in these scenarios were determined based on site-specific data. The probability of this scenario is higher than worst-case scenarios and therefore is the primary focus for on- and off-site emergency planning. Nonetheless, this scenario remains a low probability ev ent. Alternate toxic release scenarios have been prepared and selected for sulfur dioxide, chlorine and aqueous ammonia. The selected sulfur dioxide scenario involves a release when a valve on the sulfur dioxide transfer line is inadvertently opened due to human error. Sulfur dioxide is released at a rate of 60 lbs. per minute for 15 minutes (900 lb. release). The distance to the toxic endpoint (3 ppm) is 0.4 miles. The exposure distance was obtained using EPA Risk Management Program Guidance (EPA 550-B-98-010). Detection equipment, alarm system, excess flow valves, and an on-site HAZMAT response team help limit release duration. Public receptors include a school and residences. There are no environmental receptors within the sulfur dioxide ARS exposure distance. The selected ARS for chlorine is described below. Chlorine could be released at the facility if a one-ton chlorine cylinder valve is sheared off. The entire contents of the cylinder (2,000 lbs.) could be released a t a rate of 346 lbs/min. The release would occur inside the chlorine building. Liquid chlorine is released, which flashes immediately to vapor. Upon detection the building is ventilated to the outside. The distance to the toxic endpoint (3 ppm) is 0.8 miles. Active mitigation in this scenario includes release sensors and alarms, the presence of unloading personnel, and on-site HAZMAT personnel and equipment. The exposure distance was obtained using EPA Risk Management Program Guidance (EPA 550-B-98-010). Public receptors include a school, residences and commercial/ industrial areas. There are no environmental receptors within the exposure distance. The selected ARS for aqueous ammonia is described below. Aqueous ammonia is spilled by overfilling the storage tank during a transfer operation. The high level alarm fails and approximately 650 gallons of aqueous ammonia (30% solution) was spilled into the secondary containment. The release forms a pool approximately 2 inches dee p in the secondary containment with surface area of 528 sq. ft. The ammonia evaporates off at a rate of 24 lb/min. The distance to the toxic endpoint (200 ppm) is 0.1 miles. Active mitigation in this scenario includes the presence of unloading personnel, on-site HazMat personnel and equipment. The exposure distance was obtained using EPA Risk Management Program Guidance (EPA 550-B-98-010). There are no public or environmental receptors within the exposure distance. We are using this information to help us to ensure that our emergency response plan and the community emergency response plan address all reasonable contingency scenarios. 4.0 General Accidental Release Prevention Program MCP takes a systematic, proactive approach to evaluating chemical processes. Using this approach, the design, technology, operation and maintenance activities, emergency preparedness plans, training, process changes, and other elements that affect processes are all considered. Through evaluation, the consequences of catastrophic releases can be prevented or minimized. MCP processes are currently in compliance with OSHA Process Safety Management (PSM) Standard (29 CFR 1910.119). The PSM Program addresses chemical accident prevention in a way that protects employees as well as the public, and the environment. The purpose of the PSM Program is to prevent unwanted releases or minimize the impacts of accidental releases of hazardous chemicals, especially into locations that could expose employees and others to serious hazards. Our management systems address each of the key features of successful prevention programs including: ( Process safety information: Technical information about how a process operates ( Process hazard analysis: Technical analysis of the plants processes in order to anticipate what might go wrong ( Operating procedures: Technical and administrative procedures used to operate the plant safely ( Training: Provide employees with information necessary to ensure safe operation ( Mechanical integrity: Proper care on an ongoing basis ( Management of change: Analyze and understand the impact of changes in equipment, procedures or personnel ( Pre-startup review: Check equipment and make sure everyone knows what to do before introducing a hazardous substance to a process ( Compliance audits: Evaluate PSM program on a routine basis ( Incident investigation: Procedures for investigating the cause of an accident and developing measures to prevent future accidents ( Employee participation ( Hot work permit ( Contractors PSM modifications necessary to further account for protection of public health and the environment will be made when PSM elements are updated under the existing schedule as required by OSHA. The PSM Program was last revised on March 31, 1999. The PSM Program is maintained by the Safety Manager. Our company and our employees are committed to the standard that the PSM Program and Risk Management Program set. We do business and have s pecific accountabilities and controls to ensure that we are meeting high standards for accident prevention. MCP has developed a risk management system which identifies positions and responsibilities for proper management of the RMP. An organizational chart is included as Attachment 2. 5.0 Five-Year Accident History We keep records for accidental chemical releases and "near misses" that occur at our facility. Incident reports are completed and the appropriate emergency response agencies are notified by MCP for any accidental chemical release exceeding federal or state Reportable Quantities. Reporting and notification procedures are documented in the MCP Environmental Compliance Manual. Reports are also completed for First Aid or chemical release "near misses" that occur on-site. Appropriate corrective measures are taken to help prevent similar situations from occurring in the future. The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule which occurred at the MCP Columbus facility during the past five years: - Aqueous Ammonia - 8/19/95, 1:00 PM, 650 gallons (4,979 lbs.) - Tank overfill (high alarm failure) For this incident we conducted a formal incident investigation to identify and correct the root causes of the event. During the ammonia release incident, a construction worker at the facility was taken to the hospital for emergency care. The incident did not result in any off-site consequences that affected the public or damaged the environment. Additional information regarding this release is included in the RMP Registration Data Elements. 6.0 Emergency Response Program MCP has developed and maintains an Emergency Response / Fire Prevention Plan and an Emergency Response Plan for Hazardous Chemical Spills, Leaks and Releases. The Plans consolidate various federal, state, and local regulatory requirements for emergency response planning. Our emergency response program provides the essen tial planning and training for effectively protecting workers, the public, and the environment during emergency situations. The Emergency Response Plans include written procedures to follow in the event of an incident. Furthermore, we coordinate our plan with the Columbus Emergency Planning Committee (LEPC) and perform drills regularly. 7.0 Planned Changes to Improve Safety The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: - Evaluate the use of alternate sources of sulfur dioxide (dry/solid forms) - Evaluate placing additional administrative controls on the quantity of sulfur dioxide stored on-site. - Evaluate the use of chemical release scrubbers. - Evaluate the use of alternative materials and processes to replace aqueous ammonia. In addition, recommended changes identified during Process Hazard Analysis will be implemented as necessary. |