Farmland Foods, Inc. - Executive Summary

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Risk Management Plan 
Executive Summary 
 
Farmland Foods, Inc. 
Albert Lea MN. 
 
Farmland Foods' Albert Lea pork processing plant is located in Southern Minnesota, in the city of Albert Lea. The plant manufactures processed meats that provide consumers with high-quality meat products. This facility is subject to the Environmental Protection Agency's Risk Management Program rules under the Clean Air Act Amendments of 1990. 
 
The Risk Management Program rules require facilities handling threshold amounts of certain chemical substances to submit Risk Management Plans for the prevention of accidental releases of these substances.  The plan submission to include hazard assessments defining possible off-site impacts of certain regulated substance release scenarios, a five-year accident history, description of the facilities accidental release prevention program, and an emergency response program.  
 
The following is the Executive Summary of the Risk Management Plan for Farmland Foods, Inc., Albert 
Lea, MN. 
 
Facility Snapshot 
This facility, was constructed in the 1920's with significant construction in 1950's and 1980's  and has been operated by Wilson Foods,  Farmstead Foods and Seaboard Farms until 1995 when Farmland began operations. One hundred twenty million pounds of product is processed through the Albert Lea facility annually. 
 
Impact on the community 
* Farmland employs 500 area residents at a combined annual salary of approximately $14 million. 
* The facility purchases over $50 million of utilities, including electricity, natural gas, water, and wastewater treatment and local purchases. 
* Farmland supports Albert Lea and the state of Minnesota with $120,000 in state and local taxes annually.  
 
Employee snapshot 
Farmland employees are involved in community activities.  The facility supports United Way and other community support organizations like the Mayo Health Systems and the United Employees Credit Union.  Employees are also active in many community organizations. In 
cluding the Rotary Club, Stateline Safety Council, the Albert Lea Fire Department, Minnesota Incident Command System and the Local Emergency Planning Committee. Farmland employees recognize community involvement and volunteerism is the most effective way to improve the communities in which they live. 
Accidental Release Prevention and Emergency Response Policy 
The management and employees of this facility are committed to the prevention of any accidental releases of hazardous and regulated substances and to minimize the effects of any such releases that may occur.  Prevention of accidental releases is critical to the safe operation of this plant, to the safety of its employees, and to the safety of the general public. 
 
To achieve its goals of accident and accidental release prevention, the facility is committed to the following: 
* A knowledgeable and highly trained and motivated employee group 
* A well designed facility that is maintained and operated in a superior manner 
* Improvement 
s that enhance safety and accident prevention where appropriate 
* Excellence in safety programs and practices; a superior safety and accident record 
* Preparation and training for emergency response and mitigation 
 
The plant has had a written Emergency Response Plan in effect for many years and is committed to respond to and mitigate any accidental release to minimize the impact to employees, the community, and environment.  The response plan is coordinated with the Local Emergency Planning Committee and emergency response agencies and the plant has interacted with possible responding agencies for many years regarding the plan and activities at the plant.  Employees are trained in the implementation of the plan and in possible response activities that could be required in the event of an emergency.  The plant has a Hazmat Team made up of plant employees who are trained to respond in the event of an ammonia release on site. 
 
Stationary Source and Regulated Substances 
Ammonia refrigerati 
on, storage and handling constitute the processes at this facility that are covered by the EPA Risk Management Plan rule. 
 
The facility has  50,000 pounds of ammonia on site which is used as a refrigerant in its ammonia refrigeration system.  This is a closed, contained system, in which the ammonia is recirculated to refrigerate the meat processing and storage areas in the plant.  
 
Synopsis of Worst-Case and Alternate Release Scenarios 
The Risk Management rule requires a hazard analysis for worst-case and alternate  release scenarios for regulated substances present in threshold quantities at the site.  
 
The Risk Management rule requires that the largest amount in a single vessel be considered the release quantity for the worst-case event, unless smaller quantities handled at different conditions result in a greater distance to the regulated endpoint of consideration.  This is a requirement of the rule regardless of whether the event is likely, or, could even reasonably occur.   It sho 
uld be emphasized that the possibility of such an event as described by the worst-case scenario is extremely low.  
 
Alternate scenarios, for each regulated toxic and flammable substance, which are more likely events, must also be presented.  More likely release events tend to concentrate in areas such as failure of smaller valves, lines, and hoses. Significantly lower quantities are involved and operator intervention would tend to mitigate and limit the consequences of such failures. 
 
Worst-Case Toxic Release - Ammonia 
The largest vessel, located outdoors, has a maximum capacity of  7,000 pounds.  The worst case scenario assumes that this entire amount would release in 10 minutes, as a result of a catastrophic failure of the tank.  The worst-case scenario would reach offsite endpoints, including public and environmental receptors. 
 
Alternate Release Toxics - Ammonia 
This alternate release scenario consists of a pipe leak, which discharges 1,200 pounds of ammonia in 20 minutes prior to 
the operator stopping the leak.  A similar incident did occur in 1996, releasing a smaller amount of ammonia.  This scenario would reach offsite endpoints and would effect public and environmental receptors. 
 
Prevention Program 
The ammonia refrigeration at this plant is subject to the OSHA Process Safety Management rule, 29 CFR 1910.119.  Therefore, under the EPA Risk Management Rule, these are Program Level 3 processes.  The OSHA Process Safety Management Programs are in place for these processes, which constitute the Program Level 3 Prevention Programs,   
 
The OSHA Process Safety Management /EPA Prevention Program consists of facility management policies and procedures which promotes and recognizes process safety and the prevention of accidents in plants that handle, use, store, and process hazardous chemical materials.  
 
The plant adheres to the requirements of Process Safety Management and has written policies and procedures addressing all aspects of Process Safety Management and  
EPA Prevention Programs.  The Prevention Programs consist of several elements and policies listed below: 
 
* Employee Participation 
* Process Safety Information 
* Process Hazard Analysis 
* Operating Procedures 
* Operator Training  
* Contractors 
* Pre-startup Safety Review 
* Mechanical Integrity 
* Hot Work Permits 
* Management of Change 
* Incident Investigation 
* Emergency Planning and Response 
* Compliance Audit 
 
Emergency Response Plan 
The Farmland Albert Lea plant has a written Emergency Response Program as required by the Risk Management rule and other Environmental Protection Agency and OSHA rules.  This Plan is coordinated with the local community response plan and is available to those responding agencies.  Emergency planning and Community Right-To-Know information as required under SARA Title III has been provided to the State Emergency Response Commission, Local Emergency Planning Committee, and other appropriate agencies such as the local fire department. The facility interacts 
with various local agencies in its emergency planning such as the Local Emergency Planning Committee, fire departments, law enforcement agencies, and hospitals. Employees receive annual training in the response plan and also receive various safety training, both in general, and in the competencies relative to their required roles in the plan.  Periodically, the plan is practiced in a table top, classroom type setting, and also  drilled in mock emergencies including participation by outside responding agencies. 
 
5-Year Accident History 
The Risk Management rule requires inclusion of the five-year accident history of the facility for all accidental releases that resulted in deaths, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. The Albert Lea plant has an excellent five-year accident record with no qualifying accidental releases. 
 
Planned Changes for Safety Improvements 
Saf 
ety improvements are a continual and ongoing process at the plant, facilitated by the EPA Prevention Program/OSHA Process Safety Management Program.  Formal process hazard analysis is conducted at least every five years, but review is constant through management of change procedures, operator training, incident investigation, and mechanical integrity programs.  As a result, changes relevant to safety occur continuously, as needs are identified through these procedures and policies.
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