National Starch & Chemical - Executive Summary

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Executive Summary for National Starch & Chemical 
North Kansas City - Starch 
Accidental Release Prevention and Emergency Response Policies 
National Starch & Chemical is committed to employee, public and environmental safety.  This commitment is inherent to a comprehensive accidental release prevention program in place 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 processing corn to manufacture food grade and industrial starch.  We have two regulated substances present at our facility.  These are Propylene Oxide and Sulfur Dioxide.  The regulated substances at our facility are involved in several uses.  Sulfur Dioxide is used to treat the corn during the steeping process to a 
id in the separation of starch from the other components in the kernel.  Propylene Oxide is used as a reactant to modify food grade starches. 
The maximum inventory of Sulfur Dioxide at our facility is 92,565 pounds while Propylene Oxide is present at our facility in a maximum quantity of 206,700 pounds. 
The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario. 
The following paragraphs provide details of the chosen scenarios.  
The Environmental Protection Agency's criteria for worst case scenarios does not allow for active mitigation and requires simultaneous failure of all safety systems.  To perform the required worst case offsite consequence analysis for our facility, we have used an instantaneous failure of the storage tank for Sulfur Dioxide.  This would release the entire contents over a 10 minute time period, a highly unlikely scenario.  The distance t 
o the endpoint of 2.9 parts per million is 11 miles.  The affected distance extends beyond our property boundaries and includes residences, schools, hospitals and major office and industrial areas. 
The alternate scenario for Sulfur Dioxide is a rupture of the 3/4 inch unloading hose.  By the time the release can be stopped by closing a manual valve and the emergency valve on the trailer, 2,550 pounds are released with an off site impact of 0.47 miles.  This could impact an industrial or residential area, depending on wind direction. 
The alternate scenario for Propylene Oxide is a leaking flange on the discharge of the pump.  The leak is detected by the combustible detector after 10 minutes and the system is shut down.  The off site impact distance is 0.02 miles and would not impact any residential area.  It could possibly impact a warehouse that is at the fringe of the property boundary. 
The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
facility has taken all the necessary steps to comply with EPA's accidental release prevention requirements set out under 40 CFR part 68.  The following sections briefly describe the elements of the release prevention program that are in place at our facility. 
Process Safety Information 
National Starch & Chemical maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. 
Process Hazard Analysis 
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and efficiently controlled.  The methodology used to carry out these analyses is a HAZards Operability Study (HAZOPS).  The studies are undertaken by a team of qualified personnel with expertise in safety, engineering, process chemistry and process operations and are revalidated at a regular interval of three years.  Any findings related to the hazard analysis are addressed in a time 
ly manner. 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, National Starch & Chemical maintains written operating procedures.  These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround.  The information is regularly reviewed and is readily accessible to operators involved in the processes.  Our facility is ISO certified and the procedures are reviewed as part of the recertification process. 
National Starch & Chemical has a comprehensive training program in place to ensure that employees who operate processes are competent in the operating procedures associated with these processes.  Refresher training is provided at least every three years and more frequently as needed. 
Mechanical Integrity 
National Starch & Chemical carries out documented maintenance checks on process equipme 
nt to ensure proper operations.  Process equipment examined during these checks include among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps.  Maintenance operations are carried out by qualified personnel 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 National Starch & Chemical to manage changes in process chemicals, technology, equipment and procedures.  Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. 
Pre-startup Reviews 
Pre-start up safety reviews related to new processes and to modifications in establishe 
d processes are conducted as a regular practice at National Starch & Chemical.  These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. 
Compliance Audits 
National Starch & Chemical conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented.  These audits are carried out at least every three years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. 
Incident Investigation 
National Starch & Chemical 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 the life of the process. 
ee Participation 
National Starch & Chemical believes that process safety management and accident prevention is a team effort.  Employees are 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 analyses. 
Our company hires contractors to conduct specialized maintenance and construction activities.  Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out.  National Starch & Chemical 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 
National Starch & Chemical h 
as had an excellent record of preventing accidental releases over the last five years.  Due to our stringent release prevention policies, there has been no accidental release during this period. 
Emergency Response Plan 
National Starch & Chemical has a written emergency response plan to deal with accidental releases 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 is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 
Planned Changes to Improve Safety 
All recommended changes or improvements documented as a result of hazards analyses, audits or inspections have been ev 
aluated and, if found to be beneficial, have been implemented.  There are currently no planned changes. 
Certification Statement 
The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. 
Name:        Wayne D. Harkins 
Title:        Plant Manager 
Date signed: June 18, 1999
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