Murco Foods, Inc. - Executive Summary |
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EXECUTIVE SUMMARY The Facility: Murco Foods, Inc. is a beef processing facility located south of the town of Plainwell, in Allegan County, Michigan. The company is a subsidiary of Packerland Packing Company of Greenbay, Wisconsin. Murco Foods performs cattle slaughter and fabrication in its facility and employs approximately 900 west-Michigan residents. Chemical Safety, Release Prevention, and Emergency Response: Murco Foods, Inc. takes seriously its role as a good corporate citizen and in controlling its processes and the chemicals used or generated in those processes. The company has worked extensively with technical consultants, state and local regulatory agencies, and in-house experts to develop programs that promote a safe working environment, the health and welfare of the local community, and the protection of Michigan's natural resources. From these endeavors have come a more efficient refrigeration system, operated by trained and tested maintenance personnel; a new wast e water facility, run by certified operators; and, management programs to control the processes. Process control is the single most significant step toward release prevention. As the old saying goes, "If you don't control the process, the process controls you." Company management has expended great energy and resources to ensure process control, such as a computerized preventive maintenance system; process-specific module training for affected employees; and, when necessary, off-site training programs. Process control is not a panacea for every problem that might arise, however, and it is not a guarantee that the potential for a significant release of a regulated substance will not occur. Murco Foods has factored this possibility into the mix and established response plans that include trained, in-house personnel capable of stopping or controlling a release and notification of local authorities that a release has occurred, the chemical released, wind and weather factors, and pote ntial community areas affected by a release. Regulated Substances: In the course of its operations, the company handles two regulated substances, in quantities reportable under the Risk Management Plan (RMP): (1) Anhydrous Ammonia and (2) Methane 1. Anhydrous Ammonia: Murco Foods uses a refrigeration system to keep stored product fresh or frozen until it is shipped to market. The system uses 50,000 pounds of anhydrous ammonia, liquefied under pressure, and piped throughout the facility's cooling units similar to the refrigerator in a home, only on a larger scale. Worst case and Alternate case scenarios Worst Case: Based on the criteria provided for a worst case scenario, the loss of the entire contents of the ammonia receiver represents the most substantial threat. Assuming that a catastrophic event> e.g. a truck goes out of control and strikes the receiver results in a rupture to the tank and all 50,000 pounds of ammonia are released at a rate of 5000 pounds per minute, the release would have a radius of 4 miles. The area potentially affected by such a catastrophic release, depending on wind-speed and temperature variables, includes the towns of Plainwell, Otsego, the village of Cooper, and an approximately 8 mile stretch of US 131 between mile marker 43 to the south to mile marker 52 to the north. Approximately 10,000 residents live within the circle. A catastrophic incident, such as the one described above, is unlikely to occur. The tank is isolated from general traffic flows and is of a rated construction for anhydrous ammonia. Personnel have been trained and equipped to respond to ammonia leaks and equipment is available to allow for applying water to a spill and the concurrent vapor cloud. Alternate Case: An alternate release, based on the theory that an outside pipe might be ruptured e.g. struck by a construction crane> threatening the loss of up to 50,000 pounds of ammonia through a 71/2 inch diameter hole. The release would result in a loss of 1630lbs/minute of ammonia and a total lapsed time of 31 minutes for a total loss. Based on criteria provided for an alternate release scenario, the distance to the endpoint would be approximately 1 mile. The area potentially affected by such a release, depending on wind-speed and temperature variables, includes the southern boundary of the town of Plainwell, west to 13th Street, east to Douglas Avenue, and south to AB Avenue. An approximately 2-mile stretch of US 131 between mile marker 46 to the south to mile marker 48 to the north could also potentially be affected. Approximately 2500 residents could potentially be affected by such a release. The potential for this alternate release scenario, while more reasonable in contemplation, is unlikely. All outside ammonia-refrigeration equipment is isolated from general traffic and facility activities. Personnel are trained in SCBA use and have available high volume water hoses to mitigate the release and concurrent vapor cloud. M odeling: Modeling for these scenarios was performed using the RMP*Comp program. Release Prevention Programs Anhydrous Ammonia is covered within the Murco Foods facility by OSHA's Process Safety Management program. Before our recent acquisition, Murco conducted an audit of its Process Management Program, at which time it determined certain deficiencies existed in the program. Consultants were brought in and a modified and revised PSM program was instituted. PSM is a process control program. It requires a variety of checks and balances on the operation of an ammonia refrigeration system. All equipment is rated for use in the system by the IIAR>an organization of refrigeration specialists which is recognized by both industry and the government. Specific procedures, designed to prevent releases or catastrophic events, include: Management of Change, where each change in system design or components to the system must be evaluated before, during, and after installation; Process Haz ard Analysis, consisting of "what if" questions relating to equipment failures and the response to those failures; Training, for both line employees and supervisors to ensure continuity in process management and ability to address system failures. Five-year Accident History We have experienced approximately twelve minor "hot gas" ammonia leaks in the past five years. They are termed "hot gas" because they are most often the result of a worn seal or packing nut allowing trace amounts of ammonia vapor to escape from the system. These releases have all occurred indoors, have not resulted in a full plant evacuation, rarely result in disruption of the production process, and have generally not exceeded the in-house established PEL of 25 ppm. Most of these releases calculate out to one pound or less of actual ammonia released in the plant and none have resulted in a reportable quantity release of 100 pounds or more. On May 21, 1999, we experienced our most significant release over the past five years. A compressor motor seal failed, resulting in the loss of approximately 3 pounds of ammonia, part of it in liquid form. The release was contained within ten minutes, the inside area around the pump was evacuated, and the entire event was resolved in a little over an hour. Emergency Response Program General response measures are controlled by the facility's Process Safety Management program. Under PSM and the facility's emergency response procedures, several concurrent activities will occur upon notification of a release with the potential to migrate off-site. They include notification of the local fire company, the LEPC, and community police authorities. Murco Foods has in-house response personnel trained in basic hazardous waste operations. In case of a catastrophic release beyond the facility's capability to control, containment is the alternate response until a Kalamazoo Fire Company HAZMAT team could arrive. Planned Changes for Safety Improvement With impro ved resources, Murco Foods will be developing a more comprehensive response program to deal with potential catastrophic releases. Hazardous Waste Operations training will be improved to eliminate our potential need to rely on outside HAZMAT response groups. 2. Methane: Methane is a natural by-product resulting from biological processes used by Murco Foods to reduce BOD levels in the anaerobic water treatment pond. The gas is captured under a specially designed pond cover. Approximately 33,000 pounds of methane can be accumulated beneath the cover. The methane gas is then drawn off the surface of the pond through a pipe to a propane-fired flare. The methane is continuously being burned off. Worst case and Alternate case scenarios Worst Case: The worst case scenario is based on fixed data. If the cover were billowed with 33,000 pounds of methane, and the contents were suddenly released> a wind tears the cover from its moorings and the resulting vapor cloud was ignited by t he flare, the explosion would encompass a .3 mile radius. Such an explosion, while potentially devastating to occupants within the blast zone, would not reach beyond the facility's property. Some affects may potentially involve property adjacent to ours i.e. windows broken by the subsequent shock wave but even that event is minimal and unlikely. Alternate Case: The alternate case scenario, also base on fixed data, embraces the idea that a hole in the pond cover is releasing methane. A carelessly discarded cigarette ignites the escaping methane and a fireball erupts. Again, the resulting explosion would only encompass approximately .3 miles and the after affects would be no more extensive than those indicated for a worst case scenario. Modeling: Modeling for these scenarios was performed in-house using the RMP*Comp program. Release Prevention Programs Release prevention is the product of in-house procedures developed and employed by the environmental manager in conjunction with wastewater plant employees. The pond and its flare require visual inspection, which is performed on a daily basis. The operation is inspected to ensure that the flare is activated and that the cover seams are in tact. The cover acts as a release preventative should the flare be temporarily extinguished. Breaks in the welded seams of the cover are noted and a contractor is utilized to make necessary repairs. Five-year Accident History We have experienced periodic releases of methane over the past three years because of occasional breaks in the cover seams. No injuries or other adverse affects resulted from those incidents. Before that time methane was not captured and was released as it was generated. Emergency Response Program Due to the nature of the process and the limited possibilities for the type of emergency, response is limited principally to preventive measures. Leaks are repaired as they occur. Should a catastrophic explosion or fire occur, it would self-extingui sh within seconds. In the aftermath of an explosion, wastewater personnel would notify the local fire company authorities and damage assessments would be made within the blast zone. Potential casualties should primarily be limited to persons in the immediate vicinity of the pond or inside buildings within the .3 miles of the center of the blast. Planned Changes for Safety Improvement No changes are currently planned for the anaerobic system. The simplicity of the process, the minimal technology used to maintain the system, and the continuous depletion of the potential hazard makes this a very rudimentary process. Changes in the future would likely involve replacement of the existing cover and/or replacement of worn or defective elements of the propane flare. |