Foster Farms Fresno Poultry (4/00 Rev.) - Executive Summary |
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FOSTER FARMS FRESNO POULTRY PLANT RISK MANAGEMENT PROGRAM (CALARP) AND PROCESS SAFETY MANAGEMENT PROGRAM Anhydrous Ammonia Refrigeration System Revised April 2000 EXECUTIVE SUMMARY Foster Farms Fresno Poultry Plant (referred to hereafter as "Fresno Poultry" or "Foster Farms") revised this document, previously submitted on June 21, 1999, due to an updated Process Hazard Analysis and regulatory requirements requiring re-submittal. Foster Farms prepared a Chemical Risk Management Program and Process Safety Management Program (RMP/PSM) in general accordance with state and federal regulations. The state risk management regulations, also referred to as the California Accidental Release Prevention (CalARP) program, are codified in California Code of Regulations (CCR), Title 19, Section 2735.1, et. Seq. The 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 Federa l Regulations (CFR), Part 68. Finally, both the Occupational Safety and Health Administration (OSHA) and the California Occupational Safety and Health Administration (CalOSHA) regulate facilities with certain acutely hazardous materials under the PSM regulations, as defined in CCR Title 8 Section 5189 and CFR Title 29 Part 1910 Section 119, respectively. Foster Farms prepared the RMP/PSM 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 were 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/PSM. Fresno Poultry is located at 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 packaging 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 syst em, 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. Fresno Poultry reported three accidental releases of ammonia within the past five years: June 1997; November 1997; February 1998. Foster Farms personnel mitigated all releases. The local fire department provided backup support during the June 1997 and February 1998 incidents. The first release (June 1997) resulted from a failed high-level float switch in a vessel. Liquid ammonia from the vessel backed up into two compressors causing a higher discharge pressure. Ammonia was releas ed 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. Loose packing on two valves caused the second reported release of ammonia (November 1997). The packing nuts were tightened to end the release. No injuries or off-site release occurred. A failed gasket on a valve was the cause of the third release (February 1998). Two employees were examined at a local hospital, but were not admitted. No off-site release occurred. 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) an d an alternative release scenario. The regulations define a worst-case release scenario as "?the greatest amount held in a single vessel?released 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, contains approximately 29,811 pounds of ammonia at 80% capacity -- the safe fill level for the vessel. Therefore, the worst-case release scenario for the facility is a release of 29,811 pounds of ammonia in 10 minutes. Catastrophic failure of the high-pressure receiver is 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 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 EPA's 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 pipe connection leak or a gasket rupture. The evaluation used a release rate of 82 pounds/minute and average weather conditions. The SLAB Model was used also for modeling the alternative release scenario. The RMP/PSM 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 ammoni a 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 Fresno Poultry 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. Additionally, all pressure vessels in the system are equipped with pressure relief valves. Other safety features at the facility include: ? Emergency shutdown systems ? Component specific safety shutdowns ? Safeties are tested annually ? Pressure relief valves on all vessels, compressors, and several other areas in the system where trapped ammonia could build pressure ? All vessels are connected to a fire diffusion panel ? Many of the ammonia pipes, valves and components are labeled ? Pressure relief valves are replaced at least every five years ? A fire sprinkler system is installed in the plant ? A central computer system monitors the refrigeration system and alarms when safety set-points are exceeded ? Operators receive ongoing training in operations, maintenance and emergency response In addition 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 lockout/tagout program, a contractor safety program, incident investigation program, mechanical integrity program, management of change program, pre start-up safety review p rogram, and a RMP/PSM 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 refrigeration 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: ? the review and revision of SOPs is nearly completed ? line labeling and valve tagging is underway ? management is evaluating the installation of spring return valves for all oil draining ? management is evaluating the installation of an ammonia leak detection system at the plant ? preventive maintenance program is being reviewed to verify that all ammonia system components are included and maintenance frequencies are appropriate ? management is evaluating engine room exhaust requirements ? Foster Farms is evaluating equipment protection issues in the main hallway ? ammonia awareness will be added to forklift training program Foster Farms will respond to all suggested mitigation measures promptly. Foster Farms is scheduling completion of proposed actions. Management responses and support will be consistent with Foster Farms' commitment to saf e and environmentally responsible operations. Foster Farms recognizes that the RMP/PSM is a continuous process for evaluating, monitoring, and improving anhydrous ammonia handling operations at its facility. As such, this document and related attachments and program elements will evolve as Foster Farm continues their ongoing focus and dedication of risk minimization and safety improvement for their employees and surrounding community. Foster Farms will submit revised information if a change occurs that is considered significant and requires resubmission under the regulations. However, minor improvements/modifications to the RMP/PSM and related attachments and program elements will be incorporated consistent with Foster Farms' internal review practices; Foster Farms will maintain the most current versions on site. Thus, the most current version RMP/PSM and related documents and elements maintained on site may vary slightly from the information submitted to the EPA and other regulat ory agencies. |