Foster Farms Kansas Dairy (2/01 Rev.) - Executive Summary

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RISK MANAGEMENT PROGRAM (CalARP) 
AND PROCESS SAFETY MANAGEMENT PROGRAM 
 
Anhydrous Ammonia Refrigeration Systems 
Foster Farms Kansas Avenue Dairy 
 
Revised February 2001 
 
 
EXECUTIVE SUMMARY 
 
 
Foster Farms Dairy revised this document, previously submitted in January 2000, due to an updated Process Hazard Analysis and regulatory requirements requiring re-submittal. 
 
Foster Farms Kansas Avenue Dairy (hereafter referred to as Foster Farms or Foster Farms Dairy) prepared a chemical risk management plan (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 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 Dairy prepared this RMP to satisfy regulatory requirements and t 
o demonstrate a commitment to evaluate and improve anhydrous ammonia handling systems and practices at the facility. Foster Farms Dairy has incorporated state-of-the-art safety features into the ammonia refrigeration systems at the facility as part of system modifications and upgrades.  Foster Farms Dairy will continue to improve ammonia-handling safety through the implementation of the prevention program elements of the RMP.  
 
The Foster Farms Dairy at 415 Kansas Avenue in Modesto, California is located in an area zoned for commercial and industrial use.  The facility is near Highway 99, which runs north and south through Modesto.  Foster Farms Dairy is a family owned business that processes milk into fluid milk, powdered milk, and butter and packages fruit juices.  Foster Farms Dairy purchased the facility in 1988. Knudsen formerly owned the facility.  The facility has undergone significant modifications since 1988 and the majority of the ammonia refrigeration system components are l 
ess than 12 years old.   
 
Anhydrous ammonia is used at the facility in two refrigeration systems ("A" and "B").  Each system contains approximately 16,000 pounds of anhydrous ammonia.  The ammonia refrigeration systems are closed systems.  The refrigeration systems provide cooling to the cold storage rooms, milk silos, glycol chillers, and air conditioning systems.  The cold rooms are used to store product. Some of the "A" side milk silos are jacketed with ammonia coils and store refrigerated milk and fruit juice concentrate.  The glycol chillers supply cooled liquid to processing units and other equipment for refrigeration of raw materials.  The "A" system provides refrigeration for the liquid products operations.  The "B" system provides refrigeration for powdered processing and other operations.   
 
The RMP regulations require facilities to identify and evaluate chemical release scenarios resulting from potential failures of the chemical handling systems covered by an RMP.  Program 3 
requirements of the RMP apply to the Foster Farms Dairy facility due to the quantity of ammonia used.  Program 3 facilities are required to evaluate a worst-case release scenario (release parameters are defined in the regulations) and an alternative release scenario.  A worst-case release scenario is defined by the regulations 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 vessels at the Foster Farms Dairy, the high-pressure receivers, each have a maximum capacity of 20,000 pounds of ammonia. The estimated maximum quantity of ammonia used in each system is only 16,000 pounds; therefore, the worst-case release scenario for the facility is a release of approximately 16,000 pounds of ammonia in 10 minutes.  Catastrophic failure of the high-pressure receiver is required for this scenario to occur.  Assuming pessimistic atmosp 
heric conditions, very conservative chemical dispersion characteristics and a toxic endpoint of 200 parts per million (ppm) ammonia vapor, the worst-case release scenario could impact an area, the predicted distance to the toxic endpoint for the worst-case release scenario is approximately 0.88 mile. This distance is slightly different than previously reported due to the use of atmospheric data more representative of the site.  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 Dairy used the alternative release scenario for ammonia described in the EPA's Model Risk Management Program and Plan for Ammonia Refrigeration, November 199 
8, 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 79.4 pounds/minute and average weather conditions.  The predicted distance to the toxic endpoint for the alternative release scenario is approximately 0.08 miles.  The release rate and predicted distance are slightly different than previously reported due to the use of atmospheric data more representative of the site. The SLAB Model was used 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 Dairy has incorporated many safety features in the ammonia refrigeration systems to prevent system failures and to mitigate potential releases.  The predominant safety con 
cern with closed-loop ammonia systems is inadvertent buildup of pressure exceeding pressure ratings or capacities of equipment due to ammonia expansion.  The Foster Farms Dairy ammonia systems are continuously monitored by automated control systems that shut down components if deviations from normal operating conditions occur.  Further, the systems are equipped with pressure relief valves on all pressure vessels and most, if not all, locations within the ammonia system where ammonia could become trapped.  These pressure relief valves are manifolded to a water-filled diffusion tank.  Any ammonia vapor that is unintentionally released through pressure relief valves bubbles through water that absorbs the ammonia.  Other safety features at the facility include:  
? central computer monitoring and control system 
? emergency shutdown systems  
? component specific safety shutdowns that are independent of the central computer control system 
? pressure relief valves are replaced every five years 
 
? fire alarms and sprinkler system  
? an ammonia leak detection system in the engine room and all process areas that contain ammonia equipment 
? a backup ammonia leak detection system in each machine room 
? an ammonia fire dump system that can be used to relieve pressure in vessels 
 
? a computerized preventive maintenance program 
? all ammonia piping is color coded 
? all ammonia piping, valves and components are labeled 
? operators receive regular training on ammonia system maintenance, operation and emergency response 
? SOPs for the ammonia system 
? accurate piping and instrumentation drawings for the ammonia system have been prepared 
 
In addition to the physical features of the ammonia refrigeration systems at the facility, Foster Farms Dairy has extensive administrative controls in place to maintain safe operation of the systems.  Administrative controls include, but are not limited to: formal training programs for system operators and emergency responders, a hot work permit progra 
m, a lock-out/tag-out program, a contractor safety program, and a management of change program.  Written standard operating procedures (SOPs) have been written for the ammonia systems at the facility and will provide a basis for site specific operator training and a ready reference for operating and trouble-shooting the systems. 
 
Foster Farms Dairy is committed to maintaining the mechanical integrity of the ammonia refrigeration systems.  A computerized preventive maintenance system is utilized to manage the maintenance of the refrigeration systems.  Preventive maintenance at the facility includes shift, daily, weekly and periodic inspection, calibration, testing and overhaul of ammonia system equipment.  The computerized 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. 
 
The RMP regulations require a review of the five-year accident history at t 
he regulated facility. The Foster Farms Dairy facility at 415 Kansas Avenue reported two accidental releases of ammonia within the past five years: August 2000 and September 2000.  Foster Farms personnel mitigated all releases.  The local fire department and county hazmat team provided backup support during both incidents.  Both  
 
The first release (August 2000) resulted from a failed manhole gasket on FES Compressor #4B. Ammonia vapor was released through the failed gasket.  No off-site impact occurred and no injuries were reported.  The facility has since implemented a program to verify compressor manhole gasket installations.   
 
A piping tie-in to a valve was the cause of the second release (September 2000). Ammonia liquid was released through the valve.  No off-site impact occurred and no injuries were reported.  The facility has since implemented a program to verify valves can not be opened after being chain closed. 
 
In the unlikely event that an ammonia release that requires emer 
gency response occurs at the facility, Foster Farms Dairy has trained refrigeration system operators for emergency response.  Each operator receives 40 hours of emergency response training consistent with the California Safety Training Institute (CSTI) curriculum, presented by a CSTI certified instructor.  The facility has a written emergency response program that identifies the roles, responsibilities and actions of the emergency responders.  Foster Farms Dairy will not rely on local community responders to mitigate ammonia releases at the facility.  Foster Farms Dairy will rely on community responders for medical assistance and public evacuation or protection in place, if necessary. 
 
Changes to improve safety at the facility are ongoing.  All of the mitigation measures suggested by the process hazard analysis team have been addressed and/or implemented. Significant mitigation measures included: 
? spring return valves are now used for all oil draining 
? preventive maintenance and insp 
ection recommendations have been implemented 
? valve and equipment identification was completed 
? administrative programs were prepared and implemented 
? color-coding of the ammonia pipes is completed 
? relocation of SOVs to accessible area for butter cold boxes is completed 
? SOVs were programmed into Utility PLC for emergency shut down of systems 
? audible alarms were installed throughout plant and included in preventive maintenance program 
? liquid and hot gas SOVs throughout plant have been connected to ammonia detection system to close upon detection of ammonia 
? added critical level floats to all glycol chillers 
? preventive maintenance and inspection recommendations have been implemented 
? management evaluated the need for additional catwalks for inspection and maintenance of equipment and decided not to install catwalks 
? management evaluated the need for a water-wash system for the machine room exhaust fans and decided not to install water wash systems 
? Machine room ventilati 
on requirements are being reviewed 
 
Foster Farms will respond to all suggested measures to improve the safety and operations of the ammonia refrigeration system.  Foster Farms' employee participation policy provides a mechanism for all employees to provide comments and concerns to Foster Farms management.  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 Farms 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 i 
mprovements/modifications to the RMP/PSM, 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 in submittals made to EPA and other regulatory agencies.
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