Wampler Foods, Inc. - Moorefield - Executive Summary

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This Risk Management Plan covers the Wampler Foods, Inc. chicken processing facility at Moorefield, West Virginia, a single stationary source.  The facility's refrigeration system is a standard two-stage refrigeration design using anhydrous ammonia as the refrigerant.  There is approximately 52,000 pounds of ammonia on site.  Because anhydrous ammonia is listed by both the U.S. Occupational Safety and Health Administration (OSHA) and the U.S. Environmental Protection Agency (EPA) as a hazardous chemical, our accidental release prevention policy is designed to comply with the Process Safety Management (PSM) and Risk Management Program (RMP) regulations of these two agencies.  These regulations are designed to prevent the accidental release of ammonia and minimize negative consequences in the event that a release should occur.  Wampler Foods' emergency response policy follows the National Response Team's Integrated Contingency Plan Guidance ("one plan") and is designed to comply with all 
government emergency response regulations. 
An offsite consequence analysis was performed for this site, including consideration of two ammonia release scenarios identified as "worst case release" and "alternative release scenario".  The worst case scenario, as defined by the EPA, states that "the owner or operator shall assume that the  maximum quantity in the largest vessel  is released as a gas over 10 minutes", due to an unspecified failure.  The alternative release scenario is defined as "more likely to occur than the worst-case release scenario". 
The worst-case release scenario at the Wampler Foods, Inc. Moorefield facility involves a failure of the High Pressure Receiver under maximum storage conditions.  The computer program, RMP*Comp, was used to determine the distance to the toxic endpoint.  The toxic cloud formed by the evaporating ammonia would reach offsite endpoints and nearby public receptors. This scenario was performed using pre-defined conditions by the EPA, namel 
y release of the entire amount as a gas in 10 minutes, use of the one-hour average ERPG-2 (Emergency Response Planning Guideline Level 2) as the toxic endpoint, and consideration of the population residing within a full circle with radius corresponding to the toxic endpoint distance. The EPA-mandated meteorological conditions used for this scenario were Atmospheric Stability Class F, wind speed of 1.5 m/sec, highest daily maximum temperature (770F), and average humidity (50%).   
The EPA set these conditions to facilitate the performance of the offsite consequence analysis; however, the assumptions used may be unrealistic because: 
1. The maximum amount of anhydrous ammonia this vessel could hold is 14,000 pounds.  Under normal operating conditions, this receiver contains approximately 6400 pounds and seldom, if ever, reaches the 14,000 pound capacity. 
2. Assumption is that ammonia liquified under pressure is released at its boiling point.  At true atmospheric conditions only a fracti 
on (about 20% of the total) of the liquid ammonia will release to the atmosphere flashing as a vapor.  The remaining unflashed liquid will stay in the vessel or pool on the ground. 
3. Requirement to compare a 10-minute release to a one-hour average standard. 
4. Only the population within an elliptical plume extending downwind of the release point is potentially affected.  This plume area, or footprint, is approximately 6% of the area of the full circle. 
5. Assumption of a ground level release when actually the vessel is on the roof. 
The alternative release scenario involves the rupture of a condenser tube.  Rupture could occur if corrosion weakened the tube and an additional force, such as pressure from the loss of a water pump, was placed on the tube.  This scenario, by definition, is "more likely to occur" than the worst case scenario and must reach an endpoint off site using the typical meteorological conditions of Atmospheric Stability Class D, wind speed of 3.0 m/s, average ai 
r temperature of 770F, and 50% average humidity.   The scenario we chose to evaluate does reach offsite endpoints and a few nearby public receptors. 
There is no passive mitigation for either scenario.  We do, however, conduct non-destructive testing of the thickness of our pipes, vessels and condenser tubes on a regular schedule to find any corrosion problems early and correct them as soon as possible.  
Wampler Foods, Inc.'s accidental release prevention program is based on the following key elements: 
7 Hands-on and classroom training of the operators 
7 Preventative maintenance program 
7 Operating procedures, written with the participation of the operators 
7 Performance of a process hazard analysis of the entire system including equipment and piping 
7 Design and implementation of an auditing and inspection program 
7 Procedure for handling all changes to the system 
7 Pre-startup review procedures for significant system modifications 
7 Up-to-date process safety information 
7 P 
rocedures for investigating release incidents or near-misses 
7 Non-routine safe work permits for work on or near the ammonia process. 
This program was developed with the participation of Wampler Foods' refrigeration employees.  They were also instrumental in developing the Process Safety Information. All anhydrous ammonia pipes and valves are labeled and all equipment information has been compiled.  The Company follows the International Institute of Ammonia Refrigeration (IIAR) guidelines for safe operations and preventative maintenance.  In addition, the facility has procedures in place for notifying contractors and their employees of the hazards pertaining to the system, as required under the RMP regulations.  Chemical-specific prevention steps include availability of self-contained breathing apparatus (SCBA) and respirators for the operators' use, and awareness of the hazardous and toxic properties of anhydrous ammonia.  We also give our refrigeration operators HAZMAT training on  
an annual basis. 
In accordance with the PSM and RMP regulations, the Company performs periodical audits and hazard reviews to enhance continued safe performance.  Several recommended actions to improve safety were identified in May 1998, when a Process Hazards Analysis was completed for the Moorefield facility.  These recommended actions are being tracked on a monthly basis for timely completion as required.  
No accidental releases of ammonia resulting in deaths, injuries, or significant property damage onsite have occurred at this facility in the past five years.  There has been one accidental ammonia release in the past five years that resulted in ammonia being released into a nearby stream, resulting in a limited fish kill. 
The Wampler Foods, Inc. Moorefield facility has an emergency response program, that has been coordinated with the Moorefield Fire Company and the Hardy County Joint Local Emergency Response Planning Committee (LEPC).  This program includes an emergency respons 
e notification plan.  Emergency response drills and drill evaluations are conducted annually for chemical releases; emergency operation and response procedures are also reviewed at that time. 
WLR Foods, Inc. is a fully integrated provider of high quality turkey and chicken products primarily under the Wampler Foods brand.  It is nationally ranked as the seventh largest poultry processor by sales volume and is an international leader in poultry exports.  We are committed to enhancing shareholder value and to maintaining and improving the quality of life in our communities.
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