Foster Farms Livingston Complex (4/00 Rev.) - Executive Summary |
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FOSTER FARMS LIVINGSTON COMPLEX RISK MANAGEMENT PROGRAM AND PROCESS SAFETY MANAGEMENT PROGRAM Anhydrous Ammonia Refrigeration Systems Revised April 2000 EXECUTIVE SUMMARY Foster Poultry Farms revised this document, previously submitted on June 21, 1999, due to the removal of their chlorine processes and the regulatory requirements requiring re-submittal within six months of a significant change to a process. Regulated chlorine processes are no longer present at the facility and therefore, are not included in this documentation. Foster Farms Livingston Complex (referred to hereafter as Foster Farms or Livingston Complex) 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 Federal Regulations (CFR), Part 68. Finally, both CalOSHA and OSHA 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 chlorine and anhydrous ammonia handling systems and practices at the facility. Foster Farms recently removed all liquid/gaseous chlorine processes and replaced them with alternative systems, further demonstrating their commitment to reduce chemical risks. Therefore chlorine systems are no longer in this RMP/PSM. Many state-of-the-art safety features were incorporated into the ammonia refrigeration systems at the facility as part of the ori ginal system construction and system modifications. Foster Farms will continue to improve ammonia handling safety through the implementation of the prevention program elements of the RMP/PSM. In the unlikely event that a ammonia 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 end the release. The Livingston Complex is located at 843 Davis Street in Livingston, California. The facility is approximately ? mile east of Highway 99 in the northeast portion of Livingston. Restaurants, a hotel, a gasoline station, and other small retail facilities are located along 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 o f the facility. Railroad tracks border the facility on the west. Agricultural lands generally surround the Livingston area. The facility is surrounded by a security fence, prohibiting unauthorized access. Additionally, the entrance is staffed by plant security personnel 24 hours-per-day, 365 days-per-year. The Livingston Complex consists of four operating units, which are Plant 1, Plant 2, Deli, and Distribution. Operations at Plants 1 and 2 include the slaughter, processing, storage, and packaging of poultry products. Operations at the Deli include the production of deli products. Corn dogs 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. Plants 1 and 2 are immediately adjacent with a common wall separating the operations and are located in the southwest corner of the Livingston Complex. The Deli and NCDC are immediately adjacent with a common wall separating the operations. The Deli and 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. NCDC was constructed in 1988/1989. The Deli was constructed in 1971 and has also undergone significant changes. A second refrigeration system was installed in 1998 as part of the Corn Dog Plant expansion. There are five independent ammonia refrigeration systems (processes) at the Livingston Complex. Plant 1 has one ammonia refrigeration system. Plant 2 has one ammonia refrigeration system. The Deli has two ammonia refrigeration systems. NCDC has one ammonia refrigeration system. All equipment is operated and maintained by a single team of trained refrigeration system technicians who are managed and dispatch ed 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 the 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 RMP/PSM regulations require a review of the five-year accident history at the regulated facility. The 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 chlorine process has sin ce been removed from the facility. 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 Livingston Complex due to the quantity of ammonia 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 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. 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 po pulations from worst case release scenarios from other processes are within the populations affected by the selected scenario. The largest ammonia vessel at Foster Farms, the Deli high-pressure receiver, contains 17,740 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 17,740 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 predicted distance to the toxic endpoint for the worst case release scenario is approximately 1.37 miles. 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. Departmen t 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 for ammonia described in the EPA's 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 79.7 pounds per minute and average weather conditions from updated weather data. The predicted distance to the toxic endpoint for the alternative release scenario is approximately 0.11 mile. The SLAB Model was used for modeling the alternative release scenario. SLAB was first developed by Lawrence Livermore National Laboratory un der 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/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 ammonia refrigeration 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 ammonia 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 diffu sion 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: ? emergency shutdown systems ? component specific safety shutdowns ? safety shutdowns are tested annually ? many of the ammonia pipes, valves and components are labeled ? pressure relief valves are replaced at least every five years ? fire alarm and sprinkler systems exist at the facility ? all plants except Plant 2 have emergency fire diffusion panels to protect vessels from over-pressurization - manually invoked ? the Deli Plant that is equipped with a passive diffusion system connected to all pressure relief valves to protect against over-pressurization ? an ammonia leak detection system in the new engine room at the Deli Plant In addition to the physic al features of the ammonia refrigeration 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 lockout/tagout program, a contractor safety program, incident investigation program, mechanical integrity program, management of change program, pre start-up safety review program, and a RMP/PSM auditing and inspection program. Written standard operating procedures (SOPs) have been prepared for the ammonia systems 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 systems. A preventive maintenance system is utilized to manage the maintenance of the refrigeration sy stems. Preventive maintenance at the facility includes shift, daily, weekly, and periodic inspection; calibration; testing; and overhaul of equipment in the ammonia 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: ? the review and revision of SOPs is nearly completed ? operator training will include SOPs ? valve tagging is underway ? spring return valves are proposed for all oil draining ? management is evaluating the benefit of installing leak detection systems for existing facilities ? recommendations for equipment inspection and maintenance are being incorporated into company programs and policies ? management is evaluating alarm notification systems for the plants ? management is evaluating the installation of a fire diffusion panel for the Plant 2 ammonia refrigeration system ? management is evaluating engine room ventilation requirements ? the chlorine injection systems were eliminated to reduce the potential for future chlorine incidents 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 safe 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 a nd 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 and Foster Farms will maintain the most current versions on site. Thus, the most current version RMP/PSM, related documents and elements maintained on site may vary slightly from the information submitted to the EPA and other regulatory agencies. |