Farmland Foods, Inc. - Executive Summary |
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Risk Management Plan Executive Summary Farmland Foods, Inc. Dubuque, IA Farmland Foods' Dubuque pork processing plant is located in Eastern Iowa, in the City of Dubuque, Iowa, close to 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 Managemen t Plan for Farmland Foods, Inc., Dubuque, IA. Facility Snapshot This facility, was mostly constructed between 1940 and 1970, was owned and operated by Dubuque Packing Company and FDL Foods, Inc. prior to Farmland's acquisition of the plant in 1996. The plant produces over 500 million pounds of product annually. Impact on the community * Farmland employs 1,350 area residents at a combined annual salary of approximately $32 million. * The facility purchases over $4.4 million of utilities, including electricity, natural gas, water, and wastewater treatment. * The facility paid over $240 million for materials and live hogs from the local area. Employee snapshot 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 Mercy Hospital and the Dubuque Labor Management Council. Accidental Release Prevention and Emergency Response Policy The man agement 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 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, chlorine, or methane release on site. Stationary Source and Regulated Substances Ammonia refrigeration, wastewater chlorination, and methane storage and handling constitute the processes at this facility that are covered by the EPA Risk Management Plan rule. The facility has 115,000 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 recircu lated to refrigerate the meat processing and storage areas in the plant. The facility uses chlorine for wastewater chlorination, and has a maximum inventory of 6,000 pounds of chlorine on site. The facility has an anaerobic wastewater treatment system which generates methane gas, collected under the anaerobic cell cover and burned on site in a process steam boiler. The maximum amount of methane in storage at any time would be 35,600 pounds, included in a biogas mixture volume 87,600 pounds. 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. For this facility, two regulated toxic substances are included, anhydrous ammonia and chlorine; and one regulated flammable substance, methane. The Risk Management rule requires that the largest amount in a single vessel be considered the release quantity for the wor st-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 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 9,950 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. Worst-Case Toxic Release - Methane For this facility, the largest single quantity of methane is held under the anaerobic cell cover. The maximum amount of methane held under the cover is 35,600 pounds. The worst case scenario assumes that this entire amount would released into a vapor cloud over the cover and then detonated. The worst-case scenario would reach offsite endpoints, including public receptors. Alternate Release Toxics - Ammonia This alternate release scenario consists of a pipe leak, which discharges 1,257 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. Alternate Release Toxics - Chlorine This alternate release scenario consists of a half-empty chlorine cylinder containing 1,000 pounds of chlorine, which releases through a piping leak, in 60 minutes. The release rate is mitigated by the concrete building. This scenario would reach offsite endpoints and would effect public and environmental receptors. Alternate Release Flammables - Methane Under normal conditions the maximum methane storage under the cover would be 17,784 pounds. This alternate release scenario consists of this maximum amount releasing in 10 minutes. Such a release is extremely unlikely, but this assumption is required for the endpoint to reach offsite. This scenario would reach offsite endpoints and would effect public receptors. Prevention Program The ammonia refrigeration and wastewater chlorination processes at this plant are 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 const itute the Program Level 3 Prevention Programs, The methane storage and handling process is not subject to the OSHA Process Safety management rule and, therefore, is a Risk management Plan Program Level 2 process. The plant has implemented a Process Safety Management Program for the methane, including all the elements of a OSHA mandated PSM 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: * 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 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 is an active participant in the Local Emergency Planning Committee and interacts with various local agencies in its emergency planning such as fire departments, law enforcement agencies, and hospitals. Employees receive ann ual 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 Dubuque plant has an excellent five-year accident record with one qualifying accidental release, occurring in 1996, in which 360 pounds of ammonia was release to the 16th Street Storm Water Retention Basin. There were no injuries or evacuations resulting from this release. Planned Changes for Safety Improvements Safety impr ovements 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. |