Farmland Foods, Inc. - Executive Summary
Risk Management Plan |
Farmland Foods, Inc.
Farmland Foods' Monmouth pork processing plant is located in Western Illinois, in the City of Monmouth, Illinois, 16 miles east of the Mississippi River. The plant manufactures fresh pork and 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., Monmouth, IL.
This facility, was mostly constructed in 1963, was owned and operated by several owners prior to Farmland's acquisition of the plant in 1993. The plant produces over 500 million pounds of product annually.
Impact on the community
* Farmland employs 900 area residents at a combined annual salary of approximately $24 million.
* The facility purchases over $4 million of utilities, including electricity, natural gas, water, and wastewater treatment.
* The facility paid over $200 million for materials and live hogs from the local area.
Farmland employees are involved in community activities. The facility supports United Way and other community support organizations. Employees are also active in many community organizations, such as Jaycees and the Chamber of Commerce.
Accidental Release Prevention and Emergency Response Policy
The management and employees of this facility are com
mitted 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 accidental release to minimize the impact to employees, the community, and e
nvironment. 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 a release on site.
Stationary Source and Regulated Substances
Ammonia refrigeration is the only process at this facility that is covered by the EPA Risk Management Plan rule.
The facility has 52,135 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 Mana
gement 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, the regulated toxic substance is anhydrous ammonia.
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 valves, lines, and hoses. Significantly lower quantit
ies 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 21,040 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.
The ammonia refrigeration process 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 Safet
y Management Programs is in place for this process, which constitute the Program Level 3 Prevention Program.
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:
* Process Safety Information
* Process Hazard Analysis
* Operating Procedures
* Operator Training
* Pre-startup Safety Review
* Mechanical Integrity
* Hot Work Permits
* Management of Change
* Incident Investigation
* Emergency Planning and Response
* Compliance Audit
Emergency Response Plan
Dubuque 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 emerge
ncies 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 Monmouth plant has had no such releases.
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 continuously, as needs are identified through these procedures and policies.