Accidental release of toxic or flammable chemicals has the potential to harm industrial facility employees, or even the public. Avoiding such incidents by prevention is, of course, crucial to ethanol plant safety.

Ethanol plants invariably must store and use some toxic, and sometimes flammable, chemicals. Prevention of accidental releases has received additional regulatory attention in recent years and, as more and more ethanol plants are built, the chances for accidents will likely increase.

The U.S. Environmental Protection Agency (EPA) regulates air quality with rules referred to as the Clean Air Act Amendments. One provision of these air quality rules was established to prevent an accidental release of chemicals from storage tanks at industrial plants. This provision is the EPA's Risk Management Program and the details of this regulation can be found in 40 Code of Federal Regulations, Part 68, Section 112r. Essentially this program requires facilities to plan for the prevention of an accidental release of toxic or flammable substances that are included in this program. The Occupational Safety and Health Administration (OSHA) has a similar program called Process Safety Management. This regulation includes many of the same chemicals that are applicable to the EPA program.

Facilities, including ethanol production facilities, that store chemicals regulated by the Risk Management Program at or above specified quantities (known as threshold quantities) are then required to have a Risk Management Plan (RMP) and Program in place. Ethanol facilities typically become applicable to this regulation due to the storage of anhydrous or aqueous ammonia, pentane as a 30-percent to 50-percent component of denaturant, and sometimes chlorine for water treatment. Denaturant is used to render the final 200-proof ethanol product non-potable. Other chemicals stored on site may also be included in this regulation and it is important that each facility evaluate the chemicals and quantities of those chemicals to make a proper determination of RMP program applicability.

The RMP program is similar to pollution prevention plans, safety and spill prevention programs that many facilities may already have in place. However, the RMP program requires a facility to conduct an analysis of the potential worst-case accidental event (assumes the most catastrophic situation possible) and an alternative case (a more realistic event) scenario if a release of those chemicals occurred.

An example of an alternative case scenario at an ethanol facility may be a pipe break from an anhydrous ammonia tank due to a truck backing into it, allowing a release of ammonia for a limited period of time. The release time will depend on the size of the breech and the amount of ammonia available for release. This scenario may assume the shutoff valves in place and other safety equipment operated correctly and that the only release of the chemical was the contents of the pipe. This quantity would need to be calculated and then an analysis (most often using computer models) would be conducted to determine the radius of impact from a potential release of this type. Population estimates of neighboring residents are then evaluated to determine the effects of the release that may be possible, although remote. This is important for emergency response planning so that any potential harm to the employees or the public is minimized, if not negated.

The initial implementation deadline for preparing RMPs was on June 21, 1999, or prior to a facility storing the RMP chemicals above its respective threshold quantities. This regulation has a five-year review and update requirement. Therefore, many facilities that met the initial deadline in 1999 will have to update their RMP programs by June 21, 2004. Ethanol facilities will want to review their program applicability and update existing RMPs in advance of the due date.

The EPA has recently revised the RMP regulations to include some additional elements and items for the purpose of Homeland Security. The revisions also include additional provisions to track facility updates to the RMPs as operations and conditions change. To include these new items, the EPA is in the process of updating and creating a revised version of the RMPSubmit software program. RMPSubmit was the program that the EPA provided to create the initial RMPs. The majority of the facilities reporting under the RMP program used RMPSubmit in the past. The new revised version of RMPSubmit will include the additional required information and will allow for easier updating in the future. The EPA anticipates having the updated software available sometime in February 2004. This program will be available on the EPA Web site.

The EPA also has another imminent deadline approaching in 2004. The Spill, Prevention, Control and Countermeasure (SPCC) rule amendments will go into effect August 2004. This regulation also requires a facility to create a SPCC plan and program to prevent a spill or release of chemicals, but also includes petroleum fuels, like fuel oil or gasoline. Some of the changes to this rule include use of 55 gallon containers, changing the review requirement to a five-year time frame, raising the threshold for single container criteria, limiting training to only oil-handling employees and allowing for alternative formats to be used for this planning effort.

Industry has many regulations with which they are required to comply. These regulatory requirements include many aspects of environmental, health and safety concerns. Each regulatory requirement involves planning and implementation of a program. Because of this, an individual facility may end up with an overwhelming number of plans that end up sitting on a bookshelf collecting dust instead of being actively used as they are intended. The Integrated Contingency Plan (ICP) is an excellent way of combining the numerous plans required, reducing redundancy in implementation, and describing and tracking changes at facilities. The ICP, sometimes referred to as a "One Plan," is becoming more widely utilized and is fully accepted by the state and federal agencies.

The ICP is useful from the standpoint of reducing redundancy; making changes and revisions easier to maintain (only changing one plan as opposed to each of the many plans that the revision may affect); making it easier for employee training (only have to familiarize employees with one plan); making employee response more effective and efficient (not having to decide which plan to grab as a reference when needing to respond to an incident); and is more cost effective (only have to maintain one plan so employees can have more time to concentrate on their other job tasks). This option also may allow the facility general and plant managers increased confidence that accident prevention is being efficiently and optimally preformed. EP


Therese Benkowski, a meteorologist and scientist, along with Todd Potas, PE, QEP, both of Environmental Resource Group (ERG), authored this article. ERG is based in Minneapolis, Minn.