Foster Farms Fresno Poultry - Executive Summary
FOSTER FARMS |
FRESNO POULTRY PLANT
RISK MANAGEMENT PROGRAM
Anhydrous Ammonia Refrigeration System
Foster Farms Fresno Poultry Plant (Foster Farms) prepared a chemical risk management program (RMP) in general accordance with California Code of Regulations, Title 19, Section 2735.1, et. Seq. The regulations are also referred to as the California Accidental Release Prevention (CalARP) program. The Federal Environmental Protection Agency (EPA) also regulates facilities with certain toxic and flammable substances. The federal regulations are codified in Title 40 of the Code of Federal Regulations (CFR), part 68.
Foster Farms prepared an RMP to satisfy regulatory requirements and to demonstrate a commitment to evaluate and improve anhydrous ammonia handling systems and practices at the facility. Many state-of-the-art safety features have been incorporated into the ammonia refrigeration system at the facility as part of the original system construction
and system modifications. In the unlikely event that a chemical release does occur at the facility, Foster Farms personnel are trained in the appropriate response measures, relying on backup support services provided by the local fire department and/or hazardous materials response team. Foster Farms will continue to improve ammonia-handling safety through the implementation of the prevention program elements of the RMP.
The address of the Foster Farms facility is 2960 South Cherry Avenue in Fresno, California. The surrounding area consists of industrial and commercial businesses. The facility is approximately 1.5 miles west of Highway 99. The site is bordered by North Avenue to the south, a scrap metal/salvage yard to the north, Highway 41 to the west, and Cherry Avenue to the East.
The facility was constructed in 1986-1987 for Rockford Turkey Processing. Foster Farms purchased the plant in 1990. Operations at the facility consist of the slaughter, processing, storage and pack
aging of poultry products. The facility is surrounded by chain-link fencing and has a secured entrance that is staffed by security personnel 24 hours per day, 365 days per year.
Anhydrous ammonia is used in a refrigeration system at the facility. The ammonia refrigeration system, which is a closed system, contains approximately 37,300 pounds of anhydrous ammonia. The system provides cooling for production areas, product, water chilling, and ice making. A central computer system monitors and controls the refrigeration system. The desired temperatures are maintained by controlling the flow of ammonia with manually and electrically operated valves, float switches, transfer pumps, and compressor controls.
The RMP regulations require a review of the five-year accident history at the regulated facility. The Foster Farms facility had three reported accidental releases of ammonia during the past five years. The first release (June 13, 1997) resulted from a failed high-level safety sh
utoff in a recirculator vessel. Liquid ammonia from the recirculator backed up into two compressors. Ammonia was released through an inspection manway and a compressor discharge flange. No off-site release occurred and no injuries were reported. The facility has since implemented a program to test safety shutdowns annually.
The second reported release of ammonia (November 1997) was caused by loose packing on two valves. The packing nuts were tightened to end the release. No injuries nor off-site release occurred.
The third release (February 1998) was caused by a failed gasket on a valve. Two employees were hospitalized. No off-site release occurred. Foster Farms personnel mitigated all releases. The local fire department provided backup support during response to the June 1997 and February 1998 incidents.
The RMP regulations require facilities to identify and evaluate chemical release scenarios resulting from potential failures of the chemical handling systems covered by
the RMP. Program 3 requirements of the RMP apply to the Foster Farms facility due to the quantity of ammonia used. Program 3 facilities are required to evaluate a worst-case release scenario (release parameters are defined by the regulations) and an alternative release scenario. The regulations define a worst-case release scenario as "the greatest amount held in a single vesselreleased as a gas over 10 minutes." An alternative release scenario is identified as a release that is more likely to occur at the facility.
The largest ammonia vessel at Foster Farms, the high-pressure receiver, has a capacity of 27,188 pounds of ammonia at 80 percent liquid level, the safe fill level for the vessel. Therefore, the worst-case release scenario for the facility is a release of 27,188 pounds of ammonia in 10 minutes. Catastrophic failure of the high-pressure receiver would be required for this scenario to occur. As required by the RMP regulations, pessimistic atmospheric conditions, very
conservative chemical dispersion characteristics, and a toxic endpoint of 200 parts per million (ppm) ammonia vapor were assumed. The predicted distance to the toxic endpoint for the worst case release scenario is 1.80 miles, or approximately 9,528 feet. The SLAB Model was used for modeling the worst case release scenario. SLAB was first developed by Lawrence Livermore National Laboratory under contract with the U.S. Department of Energy. SLAB has been revised and updated by the USAF Engineering and Services Center and the American Petroleum Institute. SLAB is commonly used to simulate the atmospheric dispersion of denser-than-air releases.
Foster Farms used the alternative release scenario described in the Environmental Protection Agency's (EPA) Model Risk Management Program and Plan for Ammonia Refrigeration, November 1998. The release scenario is described as a <-inch effective diameter orifice leaking liquid ammonia and resulting in an airborne release, representative of a p
ipe connection leak or a gasket rupture. The evaluation used a release rate of 88.9 pounds/minute and average weather conditions. The predicted distance to the toxic endpoint for the alternative release scenario is 0.10 miles, or 539 feet. The SLAB Model was used also for modeling the alternative release scenario.
The RMP regulations require a review of the accidental release prevention program and chemical specific prevention steps used by the facility. Foster Farms has incorporated many safety features in the ammonia refrigeration system to prevent system failures and to mitigate potential releases. The predominant safety concern with closed-loop ammonia systems is an inadvertent buildup of pressure exceeding pressure ratings or capacities of equipment due to ammonia expansion. The Foster Farms ammonia system is continuously monitored by automated control systems that shut down components if deviations from normal operating conditions occur. The major pressure vessels in the
system are connected to a diffusion panel. Ammonia from the vessels can be mixed with water (neutralized) and discharged to the sewer system to prevent over-pressurization of the vessels. Further, all pressure vessels in the system are equipped with pressure relief valves.
Other safety features at the facility include:
7 Emergency shutdown systems
7 Component specific safety shutdowns
7 Safeties are tested annually
7 Pressure relief valves on all vessels, compressors, and several other areas in the system where trapped ammonia could build pressure
7 All vessels are connected to a fire diffusion panel
7 Many of the ammonia pipes, valves and components are labeled
7 Pressure relief valves are replaced at least every five years
7 A fire sprinkler system is installed in the plant
7 A central computer system monitors the refrigeration system and alarms when safety set-points are exceeded
7 Operators receive ongoing training in operations, maintenance and emergency response
to the physical features of the ammonia refrigeration system at the facility, Foster Farms has extensive administrative controls in place to maintain safe operation of the system. Administrative controls include, but are not limited to: formal training programs for system operators and mechanics, emergency training, a hot work permit program, a lock-out/tag-out program, a contractor safety program, incident investigation program, mechanical integrity program, management of change program, pre start-up safety review program, and a RMP auditing and inspection program. Written standard operating procedures (SOPs) have been prepared for the ammonia system at the facility. The SOPs provide a basis for site specific operator training and a ready reference for operating and trouble-shooting the systems.
Foster Farms is committed to maintaining the mechanical integrity of the ammonia refrigeration system. A preventive maintenance system is utilized to manage the maintenance of the refrig
eration system. Preventive maintenance at the facility includes shift, daily, weekly, and periodic inspection; calibration; testing; and overhaul of ammonia system equipment. The system is used to track equipment performance and to create reports that are used by maintenance personnel to monitor the frequency of repairs and deviations from normal operating parameters.
Changes to improve safety at the facility are ongoing. Many of the mitigation measures suggested by the process hazard analysis team have already been implemented. Others will be implemented during the next eighteen months. The status of significant mitigation measures is as follows:
7 The review and revision of SOPs is nearly completed
7 Line labeling and valve tagging is underway
7 Management is evaluating the installation of spring return valves for all oil draining
7 Management is evaluating the installation of an ammonia leak detection system at the plant
7 Preventive maintenance program is being reviewed to ve
rify that all ammonia system components are included and maintenance frequencies are appropriate
7 Management is evaluating engine room exhaust requirements
7 Foster Farms is evaluating equipment protection issues in the main hallway
7 Ammonia awareness will be added to forklift training program
Foster Farms will respond to all suggested mitigation measures promptly. Foster Farms is establishing schedules of proposed actions. Management responses and support will be consistent with Foster Farms' commitment to safe and environmentally responsible operations.