Farmland Foods, Inc. - Executive Summary |
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Risk Management Plan Executive Summary Farmland Foods, Inc. Topeka, Kansas Farmland Foods' Topeka processing plant is located in North East Kansas, in the City of Topeka, Kansas. The plant processes fresh pork, chicken and beef products 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., Topeka, KS. Facility Snapshot This facility, was constructed in 1964, was owned and operated by Theis Packing and Hudson Foods prior to Farmland's acquisition of the plant in 1996. The plant produces over 41 million pounds of product annually. Impact on the community * Farmland employs 170 area residents at a combined annual salary of approximately $4 million. * Farmland supports Topeka and the state of Kansas with nearly $2 million in state and local taxes. * The facility purchases over $1.65 million of utilities, including electricity, natural gas, water, and wastewater treatment. Employee snapshot Farmland employees are involved in community activities. The facility supports United Way and other community support organizations, such as Lets help Program and the National Blood Bank. Employees are also active in many community organizations, such as Topeka Chamber of Commerce, Fire Department, Water Committee, LEPC, and Rotary. Accidental Release Prevention and Emerg ency 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 * Improvements 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 ac cidental release to minimize the impact to employees, the community, and environment. The response plan is coordinated with the Local Emergency Planning Committee, 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 refrigeration is covered by the EPA Risk Management Plan rule. The facility has 15,526 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 Alt ernate 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. For this facility Ammonia Anhydrous is the only regulated hazardous substance. 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 should 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 va lves, 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 8,710 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 1,300 pounds of ammonia in 20 minutes prior to the operator stopping the leak. 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 this 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 * Complianc e Audit Emergency Response Plan The Farmland Topeka 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 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 sett ing, 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 Topeka plant has an excellent five-year accident record with no reportable releases or injuries. Planned Changes for Safety Improvements Safety 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 continuousl y, as needs are identified through these procedures and policies. |