Butterball Turkey Company - Executive Summary

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The Butterball facility in Turlock, California has a good record in preventing releases of anhydrous* ammonia.  As part of their release prevention program, the plant has an excellent operator training program and preventative maintenance program.  More information about these aspects of the prevention program are discussed in Section 4.0 of this Executive Summary. 
The facility has implemented an Emergency Action Plan which is to ensure the safety of its employees', the community and the environment.  This detailed emergency response program includes procedures for handling an emergency - the established action plan and appropriate personnel involved in containing an ammonia release - Emergency Response Team (HAZMAT).  As part of this program, there is emergency response training and medical surveillance of the HAZMAT team prior to and after an incident.  All of these components make the Emergency Action Plan a 
thorough and comprehensive plan for release prevention and emergency response. 
The emergency response policies at the Butterball facility ensure that there is emergency response coverage 24 hours - 7 days per week.  There are also provisions for coordination of the Emergency Action Plan with numerous outside agencies including the Stanislaus County Hazmat Division and the Turlock Fire Department in the event of an emergency.  Any updates to the Emergency Action Plan are provided to all the agencies with which the plan is coordinated. 
*From this point in the Executive Summary, anhydrous ammonia will be synonymous with ammonia. 
Butterball is a producer of poultry products, primarily turkeys.  The plant has evisceration and deboning operations.  The NAICS code for these processes at this facility is 311615.   Many areas of the plant are refrigerated to preserve the poultry products.  The plant is also capable of freezing the product.  
Butterball has one regulated substance under 40 CFR 68: ammonia.  Ammonia is used as a refrigerant in the refrigeration of the products in the various areas of the plant. 
The  ammonia threshold for triggering applicability to 40 CFR 68 is 10,000 pounds.  The quantity of ammonia stored in the refrigeration process is approximately 78,000 pounds.  The process exceeds the threshold quantity of 10,000 pounds as set by 40 CFR 68 and thus is regulated by the Risk Management Program. 
The ammonia refrigeration system has associated hazards that can potentially affect on-site employees and the general public off-site if there is a release from the system.  Described below are the associated hazards and the worst-case and alternative release scenario for the regulated chemical.  Though there may be other scenarios possible, EPA only requires that one worst-case and one alternative scenario be reported for each regulated chemical.  
Ammonia i 
s classified as a Group 2 Refrigerant per ASHRAE Standard 34-1989.  The dominant characteristic of this chemical is its toxicity.  It is a self-alarming chemical by its distinctive pungent odor.  Due to this odor, persons exposed to ammonia vapor will not voluntarily stay in areas of even small concentrations.  Ammonia will burn at a very narrow and high range of concentrations accompanied with a high ignition temperature.  Although ammonia is not poisonous, it is corrosive to human tissue.  Ammonia is readily absorbed into the moisture of the skin and, at high concentrations, can cause severe burns. 
The risks to persons in an accidental release of ammonia include: 
1.    Corrosive attack of skin and other tissue (including lung tissue) 
2.    Freezing of skin and other body tissue when contacted by liquid ammonia 
Below is a description of the scenarios for ammonia and their off-site consequences: 
3.1    Worst-Case Scenario Description 
One worst-case scenario has been developed for the Turloc 
k plant. Taking the specific definition of the worst-case from 40 CFR 68.25, the largest potential release of ammonia would occur with a failure of the high pressure receiver.  The largest quantity of ammonia that can be stored in a vessel is 15,840 pounds in the high pressure receiver during a pump-out condition.  Administrative and passive mitigation controls are not applicable.  It is assumed that the entire 15,840 pounds is released to the atmosphere in 10 minutes.  For the worst-case release, the release height must be zero feet and thus, is modeled as if it originates at ground level. 
Under Section 68.25(c)(1), a regulated toxic substance such as ammonia that is normally a gas at ambient temperature and handled as a liquid under pressure shall be considered to be released as a gas over a 10 minute period.  Thus, ammonia's physical state in the worst-case scenario is a gas. 
Since this facility is located in a populated area, the worst-case release scenario distance-to-endpoint w 
ill reach off-site public receptors.  
3.2    Alternative Release Scenario Description 
The alternative release scenario is an ammonia release from the pump seal on the Cornell liquid ammonia recirculation pump in the new engine room.  The release height is one foot above ground level and the release orifice is one-quarter inch.  Administrative and passive mitigation controls are not applicable to this scenario.  Active mitigation of the release is human intervention (close the valves and isolate the pump from the vessel).     
Since this facility is located in a populated area, the alternative release scenario distance-to-endpoint will reach off-site public receptors.  
Butterball has developed an OSHA PSM  program for their ammonia refrigeration system. At Butterball, ammonia falls under the RMP Program 3 Prevention Program which is identical to the OSHA PSM program.  EPA has said that if th 
e process is in compliance with OSHA PSM, then it is compliance with RMP Program 3.  Butterball's ammonia PSM system has been reviewed and the PSM system elements are being implemented for the RMP. 
Listed below are key aspects of the ammonia prevention program: 
1.    The training program incorporates a buddy system with on-the-job training for experienced as well as new operators.  All new operators are trained and tested in each of the required operating and maintenance procedures to ensure safe and efficient operation of the refrigeration system.  Documentation of this training includes the date of achieved proficiency and by whom the proficiency was judged.  This documentation is placed in the individual operators file. 
2.    The plant uses a Computerized Maintenance Management System (CMMS) for control scheduling and accomplishment of preventative maintenance on components of the refrigeration system.  The scope of preventative maintenance (PM) and testing/inspection (T/I) for refrige 
ration components is based on individual vendor recommendations and generally accepted engineering practices with regard to types of preventative maintenance and inspections and their recommended frequencies.  The plant has created work tasks for each type of PM and T/I associated with the refrigeration system.  These tasks are included on the individual work order generated by the CMMS.  This system ensures that each operator/mechanic is aware of the pertinent safety precautions required for a PM procedure as well as the step-by-step actions required to complete the procedure.  Results of PM and T/I procedures are documented on the individual work order.  The work order is signed off by both the operator/mechanic and their supervisor. 
The review of Butterball's accident history includes the following range of dates: December 1, 1993 - December 1, 1998.  According to 40 CFR Part 68.42(a), there has been one accidental release at this facility. 
6.0    EMER 
As mentioned previously, the Butterball facility has developed an OSHA hazardous substance emergency response program called Emergency Action Plan & Fire Prevention Program. This document was developed in accordance with 29 CFR 1910.38 and 29 CFR 1910.120(q). 
Butterball's Emergency Action Plan is a detailed document which discusses the role of employees and management in an emergency situation.  All emergency response personnel undergo emergency response training.  The plan outlines specific procedures for evacuations and incident alarms by means of an emergency horn system.  Depending upon a given situation, the Stanislaus County Hazmat Division as well as the Fire Department will be called to provide back-up emergency responders and equipment.   The Fire Department will be called for all fire related emergencies.  The incident commander has ultimate control of implementation of the emergency response plan. 
This document contains specific procedures for:  1)  
coordination with outside authorities and communications; 2)  emergency notification procedures, evacuation instructions, personnel accounting procedures as well as notification of response groups; 3)  emergency medical treatment and first-aid; 4)  hazmat-chemical spills and releases (includes roles and lines of authority, emergency recognition and prevention, safe distances and places of refuge, site security and control, decontamination, personal protective equipment, and emergency equipment); and 5)  critique of response and follow up. 
Based on the completed Process Hazard Analysis (PHA) for ammonia, a list of action items to improve safety was developed and their status monitored to ensure that implementation was accomplished.  An example of safety improvements made at the plant is discussed below: 
The plant has recently taken several steps to ensure the refrigeration system is operating safely and complies with the requirements of PSM.  Th 
ese steps include installation of an ammonia detection system.  Ammonia detectors are installed in and around all ammonia equipment as well as in the process areas where ammonia equipment is present.  These detectors are tied into a master detection system which controls individual valves and equipment based on the presence of ammonia sensed by the detectors.  The detectors in the process areas initiate closure of the liquid ammonia feed valve to a given area when ammonia is detected in that area.  The detectors in the engine rooms initiate emergency ventilation upon detection of ammonia above the set threshold limit.  Additionally, the plant has installed shutdown switches outside each engine room to allow emergency shutdown of each refrigeration system from outside the engine room in the event of a leak inside the engine room.
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