Lewiston - Executive Summary

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Executive Summary for Perdue Farms Incorporated Lewiston Facility 
Perdue Farms Incorporated, founded in 1920, is the largest poultry producer in the Northeast and the third largest in the United States.  Headquartered in Salisbury, Md., the family-owned, privately held company has operations in 14 states.  Twenty processing facilities produce about 50 million pounds of poultry products each week.  Perdue also has grain storage and merchandising operations and is ranked among the top 20 largest U.S. grain companies.  Perdue also manufactures edible oils, specialty feeds, livestock feed ingredients and premium pet food ingredients. 
Operations at the Perdue Farms Incorporated Lewiston Complex consists of a poultry processing plant (P-9197), by-products facility, and a vehicle maintanence area.  The operation is located at 3539 Governor's Road, Highway 308 West in Lewiston, North Carolina.  Perdue Farms Incorporated began operations at this facility February 26, 1976.  The facility is lo 
cated in a rural setting surrounded by farmland and residences which include a public school.   
Chemical Management Program 
As a concerned member of the communities in which Perdue facilities are located, the company takes its role as a responsible corporate citizen very seriously.  All Perdue facilities are operated to protect employees, contractors, and the public from injury and illness, and to minimize environmental impact.  A company-wide safety and wellness program stresses safe  working conditions and safe practices.  Perdue's policy is to inspect, maintain and operate equipment and facilities to prevent accidents, including release of hazardous materials; and to train employees in prevention, as well as to prepare them to respond rapidly and effectively should an accident occur 
Perdue Farms has developed and implemented Spill Prevention Control and Countermeasures (SPCC) and Process Safety Management (PSM) plans at each operations facility as a part of an overall chemical ma 
nagement program.  The program involves a wide range of senior management personnel, including the Director of Environmental Services and the Director of Safety and Security.  Additionally, Perdue conducts regular safety meetings and provides a wide variety of environmental, health and safety training to its staff. 
Accidental Release Prevention and Emergency Response Policies 
The Lewiston facility is strongly committed to employee, public and environmental safety.  This commitment is demonstrated by a comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training.  It is a policy to implement appropriate controls to prevent possible releases of regulated substances. 
The Stationary Source and the Regulated Substances Handled 
The primary activities associated with this facility are poultry processing and poultry by-products rendering.  There are two regulated substances present at the facili 
ty.  These substances include ammonia (anhydrous) and chlorine.  Ammonia (anhydrous) is used for product refrigeration and cooling.  Chlorine is used for disinfection of process waters. 
The maximum inventory of ammonia (anhydrous) at the facility is 66,540 pounds while chlorine is present at the facility in a maximum quantity of 30,000 pounds. 
Worst Case Release Scenario and Alternative Release Scenario(s) 
The EPA's OCA Guidance Reference Tables or Equations and the EPA's RMP Guidance for Ammonia Refrigeration  Reference Tables or Equations were used to  perform the off-site consequence analysis, which follows: 
The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from chlorine.  In this scenario 12,000 pounds of chlorine is released.  The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place.  The entire pool is estimated to evaporate over 10 minutes. At Class F atmospheric s 
tability and 1.5 m/s windspeed, the maximum distance of 14 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. 
The alternative release scenario for chlorine involves the release of 10 pounds of toxic liquid, assumed to be released to form a 1 cm deep pool from which evaporation takes place.  The entire pool is estimated to evaporate after 45 minutes.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of chlorine is 0.10 miles. 
The alternative release scenario for ammonia (anhydrous) involves a release from any ammonia compressor room.  The scenario involves the release of 1 pound of  toxic liquid,  assumed to be released to form a 1 cm deep pool from which evaporation takes place.  The entire pool is estimated to evaporate after 120 minutes.  Passive mitigation controls such as enclosure(s) are taken into account to calculate the scenario.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg 
/L of ammonia (anhydrous) is 0.01 miles. 
General Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
The facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA.  This facility maintains a process safety management (PSM) plan in accordance with the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.119.  The following sections briefly describe the elements of the release prevention program that is in place at the stationary source. 
Process Safety Information 
Lewiston maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. 
Process Hazard Analysis 
The facility conducts comprehensive studies to ensure that hazards associated with processes are identified and controlled efficiently.  The methodology used to carry out these analyses is What If/Chec 
klist (combined) and HAZOP.  The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated yearly, with a regular audit of processes every five years.  Any findings related to the hazard analysis are addressed in a timely manner.  The most recent PHA/update was performed on 05/04/1999. 
Operating Procedures 
For the purposes of safely conducting activities within covered processes, the Lewiston Perdue Farms facility maintains written operating procedures.  These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround.  The information is regularly reviewed and is readily accessible to operators involved in the processes. 
Lewiston has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedu 
res associated with these processes.  Refresher training is provided at least yearly and more frequently as needed. 
Mechanical Integrity 
Lewiston carries out highly documented maintenance checks on process equipment to ensure proper operations.  Process equipment examined by these checks includes pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps.  Maintenance operations are carried out by qualified personnel with previous training in maintenance practices.  Furthermore, these personnel are offered specialized training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
Management of Change 
Written procedures are in place at the Perdue Lewiston facility to manage changes in process chemicals, technology, equipment and procedures.  The most recent review/revision of maintenance procedures was performed on 05/24/1999.  Process operators, maintenance p 
ersonnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. 
Pre-startup Reviews 
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at the Perdue Lewiston facility.  The most recent review was performed on 05/28/1999.  These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. 
Compliance Audits 
The facility conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented.  The most recent comliance audit was conducted on 08/17/1998.  These audits are carried out at least every three years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. 
Incident Investigati 
The facility promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance.  These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring.  All reports are retained for a minimum of  five years. 
Employee Participation 
Perdue Farms believes that process safety management and accident prevention are a team effort.  Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements.  In addition, employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. 
On occasion, the company hires contractors to conduct specialized maintenance and construction activities.  Prior to selecting a contractor, a thorough evaluation of 
safety performance of the contractor is carried out.  Lewiston has a strict policy of informing the contractors of known potential hazards related  to the contractor's work and the processes.  Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 
Five-year Accident History 
There have been no accidents involving the accidental release of regulated substances that have resulted in death, injury, property damage, evacuation, environmental damage, or sheltering in place. 
Emergency Response Plan 
Lewiston carries a written emergency response plan to deal with accidental releases of hazardous materials.  The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. 
To ensure proper functioning, the emergency response equipment i 
s regularly inspected and serviced.  In addition, the plan is promptly updated to reflect any pertinent changes taking place within processes that would require a modified emergency response. 
Bertie Co. Emergency Manager is the head of Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 
Perdue Farms Incorporated also coordinates activities pertaining to emergency response with local fire departments and North Carolina Regional Response Team 1 located in Williamston, N.C. 
RMP Communications Plan 
As part of its Risk Management Program, Perdue Farms has developed a RMP Communications Plan. The goals of this plan are (1) to educate the public on the potential risk of regulated substances used by Perdue; (2) to respond to any concerns that RMP disclosures may cause with honest, fact-based communication; and (3) to be fully prepared to effectively respond to any accidental chemical release scenario.  Proactive materials about the dis 
closure information, how the company is prepared to deal with an accident, how the community should respond to an accident, and a process for announcing that an accident has occurred (to be used as needed) are being prepared.  In addition, training and information materials for Perdue managers and employees, community officials, civic groups, the media, environmental groups, emergency response personnel and the public in general will be available. 
Planned Changes to Improve Safety 
Several developments and findings have resulted from the implementation of the various elements of the accidental release prevention program.  
Perdue Farms Incoporated has installed an ammonia detection system in conjunction with the exhaust fans located in the compressor rooms, in order to minimize exposure of facility personnel during a release. The strict adherence to standard operating procedures and process safety management  guidelines will ensure operator and associate safety.  The aforementioned ite 
ms along with certification training for operators and regularly scheduled mechanical inspections are some of the major steps taken to ensure safety at the Lewiston facility.  These changes are an ongoing process to maintain a safe workplace environment.
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