Moyer Packing Company, Inc/Souderton Beef Division - Executive Summary |
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Moyer Meat Packing Company (MOPAC) is committed to worker and public safety in the operation of our facility. This commitment to safety is demonstrated by the resources invested in accident prevention, such as personnel training programs and engineering and administrative controls in our process. MOPAC utilizes the elements of a process safety management (PSM) program to ensure that our ammonia refrigeration system is operated in the safest manner achievable. MOPAC has chosen to use ammonia gas as their refrigerant since it has the most efficient heat transfer capability in comparison to all other types of refrigerant. In addiiton, ammonia gas will not harm the ozone layer as will other chlorofluorocarbons (CFCs) including R-12 and R-22. MOPAC operates a beef processing facility that slaughters cattle to produce beef products such as ground beef, boxed beef, and variety meats. The plant uses an ammonia refrigeration system to chill the beef products before shipping them to custom ers such as restaurants and grocery stores. The refrigeration system holds up to 80,000 pounds of anhydrous ammonia which is kept in a liquid state under pressure. Because MOPAC's ammonia refrigeration system is subject to OSHA PSM standards, the system falls under Program 3 requirements according to EPA's Risk Management Program. No additional RMP processes were identified at the site. The worst-case release of ammonia at the facility consists of a catastrophic release of 14,200 pounds of anhydrous ammonia from the controlled pressure receiver over a 10-minute period at a rate of 781 lbs/min. The controlled pressure receiver is located inside engine room No. 2. Although MOPAC utilizes numerous administrative and active mitigation systems to minimize the consequences of such a release, no credit was taken for any mitigating factors in calculating the extent of the release. This is in accordance with EPA requirements in calculating the effects of a worst-case release. The estima ted distance to the toxic endpoint of 0.14 mg/L is 1.6 miles, and a residential population of 6,400 would potentially be impacted. The toxic endpoint distance was calculated using USEPA's RMP.COMP program. The population figure was obtained using the US Census Bureau MABLE/GEOCORE V2.5 Geographic Correspondence Engine. The alternative release scenario for ammonia consists of a liquid leak created by the failure of packing material located around a refrigerant system valve stem located on the process building's roof. Although unlikely to occur, this release scenario is more likely to occur than the worst-case release scenario described above. The packing failure would release anhydrous ammonia at a rate of 2.8 lbs/hr over a period of 24 hours. The leak scenario is based upon the reasonalbe assumption that one drop of anhydrous ammonia develops every second for a duration of 24 hours prior to detection. It is assumed that one drop equals 0.5 ml, and at this rate a total of approx imately 67 lbs of anhydrous ammonia is released. The maximum distance to toxic endpoint equals < 0.1 miles or approximately 500 ft. The surrounding residential population would not be effected as a result of this release. The toxic endpoint distance was calculated using USEPA's RMP.COMP program. The population figure was obtained using the US Census Bureau MABLE/GEOCORE V2.5 Geographic Correspondence Engine. A reasonable assumption that effects the toxic endpoint distancefor the alternative scenario includes the fact that the release to atmosphere occurs at a slow rate (2.8 lbs/min). This limits the toxic endpoint distance by assuming the concentration of the anhydrous ammonia cloud is dispersed into the atmosphere at a rate which limits the lateral movement of the cloud with respect to ground level. In addition, the release would be minimized by MOPAC's mitigation systems, which consist of operating procedures that include daily inspections of the refrigeration system by qualifi ed personnel. The process at the facility that is regulated by the RMP is also regulated by OSHA's PSM standard. MOPAC's PSM program includes detailed process safety information. MOPAC conducts process hazards analyses to identify hazards and ensure that adequate controls are in place to manage the hazards. Operations at the facility are conducted according to standard operating procedures, and employees are trained on the procedures. MOPAC ensures mechanical integrity of its ammonia refrigeration system by conducting routine daily, weekly, bi-weekly, monthly, quarterly, semi-annual, and yearly inspections and promptly correcting identified deficiencies. MOPAC's chemical-specific release prevention programs include temperature, pressure, and flow alarms in the process units; ammonia sensors in the engine rooms; and pressure relief valves located throughout the process. MOPAC had no accidental releases of ammonia in the past five years that resulted in onsite or offsite injuri es or deaths, onsite property damage, or offsite environmental damage. MOPAC maintains a written emergency response plan that is modeled after the National Response Team's Integrated Contingency Plan (ICP), also known as the "One Plan". The ICP contains response procedures for ammonia releases. MOPAC maintains an emergency response trailer with material and equipment to respond to hazardous material emergencies. Personnel are trained as emergency responders, and MOPAC conducts tabletop and hands-on emergency response drills annually. Some of the response actions are coordinated with the Montgomery County Emergency Preparedness Agency. Planned changes to improve safety at the facility include continued training of employees on the ICP. |