Farbest Foods Inc. - Executive Summary |
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A. Farbest Foods, Inc. is committed to the safety of its workers, the public and the environment. Its accidental release policy is an integrated approach, involving employee participation, management practices, written procedures and training. Farbest has created a comprehensive ammonia accident prevention program considering all aspects of process operation and maintenance. It has also developed an emergency action plan and coordinated these efforts with local emergency responders. B. Farbest Foods, Inc. operates a poultry-processing facility in Huntingburg, Indiana. A coil refrigeration system at the site utilizes anhydrous ammonia as its cooling agent. There are approximately 20,000 pounds of ammonia held in the ammonia refrigeration system at any one time. C. The offsite consequence analysis considers a worst case and an alternative scenario involving an ammonia release. No active or passive mitigation exists in either scenario. The release site is clearly rural in nature. The RMP Rule says the toxic endpoint for ammonia is 200 ppm (0.14 mg/L). The Risk Management Program Guidance for Ammonia Refrigeration was used to determine distances to toxic endpoint for each scenario. The worst-case scenario involves the catastrophic failure of the ammonia storage vessel since it holds the greatest amount of ammonia at the site. The tank is a 5-foot by 22-foot horizontal cylinder and administrative controls limit the quantity in the tank to 80% of capacity, so the release amount is approximately 14,000 lb. The guidance for specifies that the entire contents are released over a 10-minute period, yielding a release rate of 1,400 lb/min. The lookup table gives a 2.2-mile distance to toxic endpoint. This clearly extends offsite and there are public receptors within the distance to the endpoint. Farbest has many safeguards in place, which make this scenario very unlikely. Among them, there are relief valves to protect the tank from overpressurization, all vessels a re carefully inspected on a yearly basis and there is also a 5-year replacement program for the pressure relief valves. The alternative scenario involves a pipe leak in the ice house piping. It was chosen since these pipes are under pressure, have outdoor exposure and are under stress 24 hours each day. Using a pipe diameter of 0.5 inches and a pipe pressure of 75 psig, an equation in the guidance document yields a flow rate of 345 pounds per minute sustained over a 10-minute period. This flow rate corresponds to a toxic endpoint distance of 0.4 miles. This distance extends past the facility boundary and public receptors exist within it. D. Farbest Foods, Inc. complies with the Risk Management Program and OSHA Process Safety Management Rules. Taken together, the components its prevention program are designed to ensure that: Process equipment is in proper working order Employees are trained in safety and aware of correct operating procedures Changes to the process or personn el do not result in accidents The hazards of the process are identified and addressed. Mechanics walk through the system every 2 hours, 24-hours-a-day to assure that the equipment is in proper working order. Detectors have recently been updated for engine room monitoring. Farbest has undertaken a large-scale equipment and piping replacement and simplification project. They utilize IIAR training videos and employees attend RETA training courses. E. One accidental release of 110 pounds of anhydrous ammonia occurred at this facility within the past five years. It did not result in any off-site impacts and no off-site emergency responders were notified. F. For the purposes of the RMP Rule emergency response provisions, Farbest Foods Inc. can be considered a non-responding facility. Farbest has implemented an emergency action plan in accordance with the OSHA's (Standard 1910.38) and it includes procedures for evacuation, medical care, communications, practice drills and handling small spills. In addition, Farbest has contacted its LEPC (Dubois County Emergency Management & Civil Defense) to ensure that it is included in the community emergency response plan prepared under EPCRA regarding a response to a potential release. Farbest has compiled a list of emergency contacts and coordinates emergency planning with the local fire department since they would be the emergency responders. G. Farbest has an ongoing commitment to all elements of it risk management program and is always striving to improve safety at the site. By the time this RMP is submitted, they plan to complete a major project to update equipment and piping at the site. |