Rocco Turkeys, Inc. - Executive Summary

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The Rocco Turkeys, 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 turkey processing facility located in Dayton, Virginia.  This facility has two ammonia refrigeration systems that are interconnected.  The regulated substance that is the subject of this RMP is anhydrous ammonia. 
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 1,220 gallon high-pressure receiver located o 
n the roof of one of the buildings at the facility.  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 75% 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 assumes that no mitigation measures are taken to limit the release. 
Rocco's alternative release scenario, defined in the RMP regulations as a scenario that is more likely to occur than the worst-case 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 leal or a gasket rupture on the high-pressure receiver.  Under normal operating conditions and average weather conditions, and for the urban topography where the facility is located, the predicted distance to toxic endpoint is 0.10 miles.  There are public receptors located within the distance to toxic enpoint 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 assumes that no mitigation measures are taken to limit the release. 
In accordance with the RMP regulations, the general accidental release prevention programs for this facility's ammonia refrigeration system is comprised of the following components:  process safety information, processs hazard analysis, operating procedures, operator training, procedures for maintaining mechanical integrity, procedur 
es for managing system changes, pre-startup 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 facilit 
y has developed an Emergency Response Plan for Accidental Releases of Hazardous Susbstances which has been coordinated with the Harrisonburg-Rockingham Joint 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 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 that will be capable of assuming primary responsibility for responding to accidental releases. 
A process hazard analysis report prepared for the facility in May 1995 identified nine recommended actions to be taken to minimize the risk of accidental releas 
es 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.
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