Foster Farms Livingston Complex - Executive Summary |
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FOSTER FARMS LIVINGSTON COMPLEX RISK MANAGEMENT PLAN Anhydrous Ammonia Refrigeration Systems and Chlorine Injection Systems June 1999 EXECUTIVE SUMMARY Foster Farms prepared a chemical risk management program (RMP) for its Livingston Complex in accordance with Title 40 of the Code of Federal Regulations (CFR), Part 68. The Federal Environmental Protection Agency (EPA) promulgated the RMP regulations as required in the 1990 Amendments to the Federal Clean Air Act. The goal of the RMP is to prevent accidental releases of substances that can cause serious harm to the public and the environment from short-term exposures and to mitigate the severity of releases that do occur. The RMP regulations apply to facilities that handle, manufacture, use or store toxic and flammable substances listed in the regulations above specified threshold quantities. Foster Farms prepared a RMP to satisfy regulatory requirements and to demonstrate a commitment to evaluate and improve anhydrous ammon ia and chlorine handling systems and practices at the facility. Foster Farms incorporated many state-of-the-art safety features into the ammonia refrigeration and chlorine injection systems at the facility as part of the original system construction and system modifications. Foster Farms will continue to improve ammonia and chlorine handling safety through the implementation of the prevention program elements of the RMP. In the unlikely event that a chemical release does occur at the facility, Foster Farms personnel are trained in the appropriate response measures. and do not rely on support services provided by the local fire department and/or hazardous materials response team to mitigate the release. Foster Farms will rely on community responders for medical assistance and public evacuation or protection in place, if necessary. The Foster Farms Livingston Complex is located at 843 Davis Street in Livingston, California. The facility is approximately < mile east of State Highway 9 9 in the northeast portion of Livingston. Restaurants, a hotel, a gasoline station, and other small retail facilities are located along State Highway 99 in the vicinity of the complex. Residential properties are also located near the site. The Merced River is approximately = mile north and northwest of the facility. Retention basins and unimproved property lie to the north and northeast of the facility. Railroad tracks border the facility on the west. Agricultural lands generally surround the Livingston area. The Foster Farms facility is surrounded by a security fence, prohibiting unauthorized access. Additionally, the entrance to the facility is staffed by plant security personnel 24 hours per day, 365 days per year. The Foster Farms Livingston Complex consists of four operating units. Operations at Plant 1 and Plant 2 include the slaughter, processing, storage, and packaging of poultry products. Operations at the Deli Plant include the production of deli products. Corn do gs are produced and packaged at the Corn Dog Plant, which is part of the Deli. Operations at the Northern California Distribution Center (NCDC) consist of storage and shipping of poultry products. All of the plants have refrigerated coolers for product storage. Plant 1 and Plant 2 are immediately adjacent with a common wall separating the operations. Plants 1 and 2 are located in the southwest corner of the Foster Farms Livingston Complex. The Deli Plant and the NCDC are immediately adjacent with a common wall separating the operations. The Deli Plant and the NCDC are located in the northwest corner of the site, approximately 200 feet north of Plant 2. Plant 1 was originally constructed in 1965 and has undergone significant changes since that time. Plant 2 was built in 1973 and has also been updated. The NCDC plant was constructed in 1988-89. The Deli Plant was constructed in 1971 and has also undergone significant changes. A second refrigeration system was installed in 199 8 as part of the Corn Dog Plant expansion. There are five independent ammonia refrigeration systems (processes) and two independent chlorine processes covered by the RMP regulations at the Foster Farms Livingston Complex. Of the two chlorine processes, one is a chlorine injection system and one is a chlorine container storage area. Plant 1 has one ammonia refrigeration system and the chlorine storage area. Plant 2 has one ammonia refrigeration system. The Deli Plant has two ammonia refrigeration systems. The NCDC has one ammonia refrigeration system. All equipment is operated and maintained by a single team of trained refrigeration and chlorine systems technicians who are managed and dispatched by a single maintenance management team. Anhydrous ammonia is used in closed-loop refrigeration systems at the facility. The systems provide cooling for production areas, storage areas, freezers, product, water chilling, and ice making. Central computer systems monitor and control th e refrigeration systems. 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 largest ammonia pressure vessel, installed at the Deli Plant, has a capacity of approximately 17,740 pounds of anhydrous ammonia. Gaseous chlorine is used at Plant 2 for disinfecting. Gaseous chlorine is injected into various water streams at the plant to maintain chlorine concentrations in water as required by the regulatory agencies governing poultry processing. Chlorine containers are stored at a central location within the Livingston Complex prior to being deployed at the injection system location. Both 150-pound and one-ton containers are located at the chlorine storage area. The chlorine injection system consists of a container of liquid and gaseous chlorine under pressure connected to an injection system. Vacuum regulators attached to the containers allow gaseous chl orine to pass into the injection system when the regulator senses vacuum. Vacuum is created in the system when water flows past the injection point. A metering system controls the volume of chlorine that is injected. The maximum amount of chlorine in a one-ton container is 2,000 pounds. The RMP regulations require a review of the five-year accident history at the regulated facility. The Foster Farms facility reported one chlorine release within the past five years. The leak occurred in July 1995 from a valve on a one-ton chlorine container. One minor injury was reported to a Foster Farms employee. No off-site release occurred. The quantity of chlorine gas released was approximately three pounds and the duration of the release was less than 30 minutes. 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 Livingston Complex due to the quantity of ammonia and chlorine used. Program 3 facilities are required to evaluate one worst-case release scenario (release parameters are defined by the regulations) for a facility and an alternative release scenario for each covered chemical. 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. For facilities with multiple processes, the regulations require that the worst case scenario with the greatest distance to the toxic endpoint must be modeled. Additional worst case scenarios are not required if the affected populations from worst case release scenarios from other processes are within the populations affected by the selected scenario. A release of chlorine from a one-ton container results in the greatest distance to the toxic endpoint for t he Foster Farms Livingston Complex. Therefore, the worst-case release scenario for the facility is a release of 2,000 pounds of chlorine in 10 minutes. Catastrophic failure of the chlorine container would be required for this scenario to occur. Assuming pessimistic atmospheric conditions, very conservative chemical dispersion characteristics, and a toxic endpoint of three parts per million (ppm) chlorine vapor, the predicted distance to the toxic endpoint for the worst-case release scenario is 3.0 miles. Table A5-1 of the American Water Works Association (AWWA) Compliance Guidance and Model Risk Management Program for Water Treatment Plants, September 1998, was used for the chemical dispersion analysis. No administrative controls or mitigation measures were considered in the analysis. As required by the RMP regulations, Foster Farms modeled an alternative release scenario for each toxic substance contained in a process covered by RMP regulations. Foster Farms used an alternative chlorine release scenario described in Table 5-5 of the above referenced AWWA document. The release scenario is described as a 5/16-inch effective diameter orifice leading to an airborne release, representative of a faulty regulator or valve. The evaluation used a maximum average sustained release rate of 10.5 pounds/minute and average weather conditions. The predicted distance to the toxic endpoint is 0.56 miles. Foster Farms used the alternative release scenario for ammonia described in the Environmental Protection Agency's (EPA) Model Risk Management Program and Plan for Ammonia Refrigeration, November 1998, for an ammonia release from the Complex. The release scenario is described as a <-inch effective diameter orifice leaking liquid ammonia and resulting in an airborne release, representative of a pipe 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 fo r the alternative release scenario is 0.1 miles, or approximately 539 feet. The SLAB Model was used for modeling the alternative 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. 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 and chlorine injection systems 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 ammon ia systems are continuously monitored by automated control systems that shut down components if deviations from normal operating conditions occur. The major pressure vessels in all of the systems except Plant 2 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 all the systems are equipped with pressure relief valves. Other safety features of the ammonia refrigeration systems at the complex include: 7 Emergency shutdown systems 7 Component specific safety shutdowns 7 Safety shutdowns are tested annually 7 Many of the ammonia pipes, valves and components are labeled 7 Pressure relief valves are replaced at least every five years 7 Fire alarm and sprinkler systems exist at the facility 7 All plants except Plant 2 have emergency fire diffusion panels to protect vessels from over-pressurization - manually invoked 7 A new a mmonia system at the Deli Plant that is equipped with a passive diffusion system connected to all pressure relief valves to protect against over-pressurization 7 An ammonia leak detection system in the new engine room at the Deli Plant Foster Farms considers three primary hazards for chlorine storage and use in plant operations. The primary concerns are over-pressurization, physical damage to the chlorine containers and damage/ deterioration to associated piping and tubing. Locating the chlorine storage area on a north-facing exterior wall helps to mitigate the potential for over-pressurization that may be caused by exposure to direct sunlight. The containers located at the injection system are shaded. The containers at both the chlorine storage area and the chlorine injection system at the Foster Farms Livingston Complex are protected from vehicle traffic by barriers and by their location. The potential for a significant release at the injection system due to damage to connect ed tubing and piping is greatly minimized by the use of vacuum regulators at the cylinders. Additionally, flexible tubing used in the system is replaced on a regular basis. In addition to the physical features of the ammonia refrigeration and the chlorine injection systems 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 and chlorine systems at the facility. The SOPs provide a basis for site specific operator training and a ready reference for oper ating and trouble-shooting the systems. Foster Farms is committed to maintaining the mechanical integrity of the ammonia refrigeration and chlorine injection systems. A preventive maintenance system is utilized to manage the maintenance of the refrigeration and chlorine systems. Preventive maintenance at the facility includes shift, daily, weekly, and periodic inspection; calibration; testing; and overhaul of equipment in the ammonia and chlorine systems. 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 several months. The status of significant mitigation measures is as follows: 7 The review and revision of SOPs is nearly complete d 7 Operator training will include SOPs 7 Valve tagging is underway 7 Spring return valves are proposed for all oil draining 7 Management is evaluating the benefit of installing leak detection systems for existing facilities 7 Recommendations for equipment inspection and maintenance are being incorporated into company programs and policies 7 Management is evaluating alarm notification systems for the plants 7 Management is evaluating the installation of a fire diffusion panel for the Plant 2 ammonia refrigeration system 7 Management is evaluating engine room ventilation requirements 7 Two chlorine injection systems were eliminated to reduce the potential for chlorine incidents Foster Farms will respond to all suggested mitigation measures. 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. |