Perdue Farms Incorporated - Executive Summary |
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EXECUTIVE SUMMARY MILFORD, DELAWARE Facility Description and Regulated Substances Perdue Farms Incorporated, founded in 1920, is the largest poultry producer in the Northeast and the third largest in the United States. Headquartered in Salisbury, Maryland, the family-owned, privately held company has operations in 14 states. Twenty processing facilities produce about 50 million pounds of poultry products each week. Perdue also has grain storage and merchandising operations and is ranked among the top 20 largest US grain companies. In addition, Perdue manufactures edible oils, specialty feeds, livestock feed ingredients and premium pet food ingredients. The Perdue Farms Milford Processing Facility (P-1318) is located at 255 North Rehobeth Boulevard, Milford, Delaware. This facility processes broilers (fryers) and other valued-added poultry products. Perdue Farms purchased this facility and started operations in October 1995. The facility is sited on about 25 acres, on the north side of town, east of Route 113. It is bounded by some residences, industries and farmland. Anhydrous ammonia is onsite and is regulated under CFR Part 68. It is used for refrigeration. The Perdue Milford facility has one system containing 22,780 pounds of ammonia. It is distributed throughout the components (compressors, condensers, evaporators, etc.). The system has equipment both inside and outside of the facility. Accidental Release Prevention and Emergency Response Policies As a concerned member of the communities in which Perdue facilities are located, the company takes its role as a responsible corporate citizen very seriously. All Perdue facilities are operated to protect employees, contractors and the public from injury and illness, and to minimize environmental impact. A company-wide safety and wellness program stresses safe working conditions and safe practices. Perdue's policy is to inspect, maintain and operate equipment and facilities to prevent accidents, inc luding release of hazardous materials; and to train employees in prevention, as well as to prepare them to respond rapidly and effectively should an accident occur. Perdue Farms has developed and implemented Spill Prevention Control and Countermeasures (SPCC) and Process Safety Management (PSM) plans at each operations facility as part of an overall chemical management program. The program involves a wide-range of senior management personnel, including the Director of Environmental Services and the Director of Safety and Security. Additionally, Perdue conducts regular safety meetings and provides a wide variety of environmental, health and safety training to its staff. Ammonia Worst-Case and Alternate-Case Release Scenarios Worst-Case Scenario Based on the EPA RMP Guidance, a worst-case scenario for a toxic substance must be the release of the largest quantity that results in the greatest distance to the specified toxic endpoint with emergency systems and procedures not funct ioning. Perdue Milford's scenario would be the release of the entire contents of the high pressure receiver in 10 minutes. This would equate to a loss of 22,780 pounds in 10 minutes, resulting in a toxic endpoint of 2.2 miles for a concentration of 0.14mg/l. This would have the potential of affecting 6,300 people. Alternate-Case Scenario Alternate-case scenarios are those that result in off-site concentrations that reach the specified toxic endpoint. Appropriate active and passive mitigation systems may be considered in the analysis. The Perdue Milford alternate-case scenario would be the release of ammonia through a pressure relief valve (PRV) associated with a pump package (recirculator). The release was calculated to last 5 minutes, resulting in the loss of 127 pounds of ammonia for a toxic endpoint of 0.1 mile. This would have the potential of affecting 20 people. Accident Release Prevention Program Perdue Milford has complied with Delaware's Extremely Hazardous Substance Risk Management Act (EHSRMA) since its promulgation in 1989 and the OSHA Process Safety Management regulation 29 CFR 1910.119 of 1992. Up-to-date process information, such as equipment information, piping and instrument diagrams and Material Safety Data Sheets, are kept onsite. Employee participation includes operating and maintenance procedures development, review and training. Contractors are required to submit qualification statements of competency. Process hazard analyses with recommendations have been done, and corrective actions taken. Annual mechanical integrity inspections are scheduled. In addition, Perdue performs internal audits on its PSM substances. Five Year Accident History There have been no on- or off-site accidents involving ammonia at the Perdue Milford facility that have resulted in death, injuries, property damage or environmental damage. Emergency Response Program Perdue Milford has implemented a comprehensive Emergency Response Plan in accordance with the OSHA PSM regulations. The facility has a trained HAZWOPER (HAZardous Waste Operations and Emergency Response) team that will respond in the event of a hazardous material release, fire or other emergency situation. The Plan contains specific information regarding emergency response organization and procedures, as well as incident notification, mitigation and incident preparedness. Evacuation exercises are conducted, and annual drills are scheduled with the local emergency responders, Carlisle Fire Company and Houston Fire Department (dual responders). Perdue Milford is a member of the Kent County Local Emergency Planning Committee and is part of the community emergency response plan. Risk Communications Plan As part of its Risk Management Program, Perdue Farms has developed a RMP Communications Plan. The goals of this plan are: (1) to educate the public on the potential risk of regulated substances used by Perdue; (2) to respond to any concerns that RMP disclosures may cause with honest, fact-based communication; and (3) to be fully prepared to effectively respond to any accidental chemical release scenario Proactive materials about the disclosure information, how the company is prepared to deal with an accident, how the community should respond to an accident, and a process for announcing that an accident has occurred (to be used as needed) are being prepared. In addition, training and information materials for Perdue managers and employees, community officials, civic groups, the media, environmental groups, emergency response personnel and the public in general, will be available. Planned Changes to Improve Safety Perdue Milford has replaced all exterior piping in the past year. There are four RETA (Refrigeration Engineering Technician Association) Level A Certified operators at the facility. The G and L gas/liquid cooler is scheduled to be replaced this year. As part of Perdue Farms' continual improvement philosophy, the Perdue Milford facilit y continues to identify and update system components and techniques to ensure safety and quality. |