Wampler Foods, Inc. - New Oxford - Executive Summary

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This Risk Management Plan covers the Wampler Foods, Inc. turkey processing facility at New Oxford, Pennsylvania, 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 24,000 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 g 
overnment 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 or piping 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. New Oxford facility involves a condenser tube rupture.  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.  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 endpo 
ints and nearby public receptors. This scenario was performed using pre-defined conditions by the EPA, namely 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. Assumption is that ammonia liquified under pressure is released at its boiling point.  At true atmospheric conditions only a fraction (about 20% of the total) of the liquid ammonia will release to the atmosphere flashing as a vapor.  The remaining u 
nflashed liquid will stay in the condenser or pool on the ground. 
 
2. Requirement to compare a 10-minute release to a one-hour average standard. 
 
3. 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. 
 
4. Assumption of a ground level release when actually the condenser is on the roof. 
 
The alternative release scenario involves a condenser tube leak.  This scenario, by definition, must reach an endpoint off site using the typical meteorological conditions of Atmospheric Stability Class D, wind speed of 3.0 m/s, average air 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 schedul 
e to find any corrosion problems early and correct them as soon as possible.  We also have Ammonia detection systems in the compressor rooms electrically tied into the emergency exhaust fans and to an alarm in the guard shack. 
 
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 Procedures 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 participa 
tion 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 recommend 
ed actions to improve safety were identified in December 1998, when a Process Hazards Analysis was completed for the New Oxford facility.  These recommended actions are being tracked on a monthly basis for timely completion as required.  
 
Neither accidental releases of ammonia resulting in deaths, injuries, or significant property damage onsite nor known offsite deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage have occurred at this facility in the past five years. 
 
The Wampler Foods, Inc. New Oxford facility has an emergency response program, that has been coordinated with the New Oxford Community Fire Company and the Adams County Joint Local Emergency Response Planning Committee (LEPC).  This program includes an emergency response 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 fu 
lly 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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