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 St. Pauls, North Carolina. This facility has two interconnected refrigeration systems which contain anhydrous ammonia, a regulated substance under the RMP regulations. 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 3,685 gallon intermediate-pressure receiver l ocated in the processing plant. Under normal operating conditions, this receiver contains a liquid level of approximately 33%. However, during pump-downs, which occur approximately 0-2 times per year for system maintenance and repair, the intermediate-pressure receiver can hold up to 65% 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. This 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" effective 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 which 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 distance to toxic endpoint 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 refrigera tion system is comprised 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 ammon ia 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 developed an Emergency Response Plan for Accidental Releases of Hazardous Susbstances which has been coordinated with the Robeson County Local Emergency Planning Commission ("LEPC"). The facility is included in the LEPC's community emergency response plan. The facility is deemed a "non-responding facility" under the RMP regulations and under the facility's RMP, which means that the local Hazardous Materials Team, local fire departments, and other local emergency responders have primary responsibility for responding to accidental releases of ammonia which pose a health or safety hazard to persons or property located on site or off site. The facility is in the process of developing an employee Hazardous Materials Team which will be capable of assuming primary responsibility for responding to accidental releases. A process hazard analysis report prepared for the facility in July, 1994, identified six 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, intermediate-pressure, and low-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. |