Rocco Farm Foods, Inc. - Executive Summary |
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The Rocco Farm Foods, Inc. ("Rocco") chemical accident prevention and emergency response policies for ammonia refrigeration involve the development of this Risk Management Program and Plan ("RMP") which has the objective of preventing the accidental release of ammonia, and the further objective of minimizing the consequences of a release in the event that a release should occur. The stationary source that is the subject of this RMP is Rocco's chicken processing facility located near Edinburg, Virginia. The regulated substance that is the subject of this RMP is the anhydrous ammonia contained in the facility's ammonia refrigeration system. In accordance with the RMP regulations promulgated by the Federal Environmental Protection Agency ("EPA"), Rocco has determined that its worst-case release scenario for the ammonia refrigeration system would be the loss of the contents of its largest liquid ammonia containing vessel, which is a 2,141 gallon high-pressure receiver located in the pro cessing plant. Under normal operating conditions, this receiver contains a liquid level of approximately 20%. However, during pump-downs, which occur approximately 0-2 times per year for system maintenance and repair, the high-pressure receiver can hold up to 80% liquid, an amount that is limited by administrative controls. Using the parameters set forth in the RMP regulations, and using an atmospheric dispersion modeling program made available by EPA, the worst-case release would travel to a toxic endpoint offsite and potentially reach nearby public receptors. The worst-case release scenario takes into account that the release would occur in an enclosed space that is in direct contact with the outside air, but assumes that no active mitigation measures are taken. Rocco's alternative release scenario, defined in the RMP regulations as a scenario that is more likely to occur than the worst-case release scenario and which will reach a toxic endpoint offsite, assumes a 1/4" effectiv e orifice leading to an airborne release of ammonia, representative of a pump seal leak or gasket rupture on the high-pressure receiver. Under normal operating conditions and average weather conditions, and for the rural topography where the facility is located, the predicted distance to toxic endpoint is 0.2 miles. There are public receptors located within the distance to toxic endpoint whihc could be affected by a release. These calculations are based on formulas and atmospheric dispersion modeling tables and graphs contained in a model risk management program and plan for ammonia refrigeration which was made available by EPA. The alternative release scenario takes into account that the release would occur in an enclosed space that is in direct contact with the outside air, but assumes that no active mitigation measures are taken. In accordance with the RMP regulations, the general accidental release prevention program for this facility's ammonia refrigeration system is comprise d of the following components: process safety information, process hazard analysis, operating procedures, operator training, procedures for maintaining mechanical integrity, procedures for managing system changes, pre-start-up review procedures for significant system modifications, procedures for investigating release incidents, and hot work permit protocols. This program was developed with the participation of employees, and it will be periodically audited for compliance as required by the RMP regulations. In addition, the facility has in place procedures for notifying contractors and their employees of the hazards pertaining to the system, as required under the RMP regulations. Chemical-specific prevention steps are included within the program, including engineering and administrative controls designed to prevent and minimize accidental releases. In the five years preceding development of this RMP, this facility has not had any accidental releases of ammonia which have resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. This facility has in place an emergency response program to address accidental releases of ammonia. The emergency response program consists of a Hazardous Materials ("HazMat") Team which operates pursuant to an emergency response plan developed under the OSHA Hazardous Waste Operations and Emergency Response Regulations. The emergency response plan has been coordinated with local emergency responders, including fire departments, rescue squads, and the Local Emergency Planning Commission ("LEPC"). The facility is included in the LEPC's community emergency response plan. If necessary, regional HazMat Teams are available to assist the facility in responding to any accidental releases of ammonia. A process hazard analysis report prepared for the facility in January 1995 identified fourteen recommended actions to be taken to minimize the risk of accidental releases and improve safety related to the ammonia refrigeration system. All of the recommended actions have been completed or otherwise addressed. As a result of development of this RMP, this facility has also implemented administrative controls which reduce the maximum amount of ammonia that can be placed in the high-pressure receivers during pump-downs, such controls having the effect of minimizing the consequences of a worst-case release in the unlikely event it should ever occur. |