Perdue Farms Inc. Dillon, SC Processing Plant - Executive Summary

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Description of the facility and the regulated substance: 
 
Perdue Farms Incorporated, founded in 1920, is the largest poultry producer in the Northeast and the third largest in the United States.  Headquartered in Salisbury, MD, the family-owned, privately held company has operations in 14 states.  Twenty processing facilities produce about 50 million pounds of poultry products each week.  Perdue also has grain storage and merchandising operations and is ranked among the top 20 largest U.S. grain companies.  Perdue also manufactures edible oils, specialty feeds, livestock feed ingredients and premium pet food ingredients. 
 
The Perdue Farms, Dillion Processing Plant is a poultry-processing plant located approximately two (2) miles west of Interstate I-95 on Highway 9 in Dillon, South Carolina.  The facility is a fast-food poultry processing plant that employs approximately 1,300 associates.  The facility normally operates 24 hours per day, five days per week. 
 
The regulated substance at  
the Dillon facility, covered by 40 CFR Part 68, is anhydrous ammonia (R-717).  The facility utilizes anhydrous ammonia as an integral part of its refrigeration system.  The refrigeration system consists of several storage vessels, compressors, condensers, piping, and air handling units located throughout the facility, in order to maintain proper food safety temperatures.  The total quantity of anhydrous ammonia on-site is approximately 45,000 pounds distributed throughout the refrigeration components. 
 
Accidental release prevention and emergency response policies: 
 
As a concerned member of the community, the company takes its role as a responsible corporate citizen very seriously.  All Pedue facilities are operated to protect employees, contractors, and the public from injury and illness, and to minimize environmental impact.  A company-wide safety and wellness program stresses safe working conditions and safe work practices.  Perdue's policy is to inspect, maintain and operate equipme 
nt and facilities to prevent accidents, including the release of hazardous materials; and to train employees in prevention, as well as to prepare them to respond rapidly and effectively should an accident occur. 
 
Perdue Farms has developed and implemented a Spill Prevention Control and Countermeasures (SPCC) plan and Process Safety Management (PSM) plan as part of an overall chemical management program.  The program involves local managers and a wide range of senior management personnel, including the Director of Environmental Services and the Director of Safety and Security.  Additionally, Perdue conducts regular safety meetings and provides a wide variety of environmental, health, and safety training to its staff. 
 
General accidental release prevention program: 
 
The Perdue Farms Dillion facility maintains a Process Safety Management plan in accordance with the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.119.  The maintenance personnel at the facility u 
tilize a preventative maintenance program for all the system components.  As part of the program, trained refrigeration personnel routinely inspect the refrigeration system operating parameters and conduct routine maintenance, as needed. 
 
Worst-case release scenario: 
 
The predicted worst-case scenario for the refrigeration system is the catastrophic failure of one of the High Pressure Receivers (HPRs) located on the roof of the plant.  The vessel has a maximum storage capacity of 14,413 pounds of anhydrous ammonia.  Using EPA's RMP Comp Ver 1.06 modeling software, the calculated distance to the toxic endpoint is 2.2 miles.  The estimated population within the 2.2-mile radius is 2,801 based on U.S. Census Bureau information contained in the LandView III mapping software. 
 
Alternative release scenario: 
 
The predicted alternative release scenario for the refrigeration system is the release of anhydrous ammonia from breakage of the sight glass associated with one of the HPRs located on the 
roof of the plant.  This is a very low traffic remote location and the most probable cause of this alternative release would be human error.  The quantity of ammonia released in this scenario is 7,207 pounds.  This type of release would occur within 3.05 minutes.  Using the SLAB dispersion model, the calculated distance to the toxic endpoint is 1.21 miles.  The estimated population within the 1.21-mile radius is 466, based on U.S. Census Bureau information contained in the LandView III mapping software. 
 
Five-year accident history: 
 
The Dillon facility has been operated by Perdue Farms since 1992 and has not had a serious accident involving anhydrous ammonia that caused death, associate injuries, or property or environmental damage. 
 
Emergency response program 
 
In the event of an emergency involving the refrigeration system, Perdue's Dillon facility has a well defined incident command system.  The written Emergency Response program includes procedures to safely evacuate the facility,  
minimize and/or contain the release and notify the appropriate local fire department and LEPC officials.  Perdue continues to train its associates on hazardous responses and awareness, and conducts mock drills routinely.  Perdue officials have discussed the company's response program with local LEPC and fire department representatives. 
 
As part of its Risk Management Program (RMP), Perdue Farms has developed a RMP Communications Plan.  The goals of this plan are (1) to educate the public on potential risks of regulated substances used by Perdue; (2) to respond to any concerns that RMP disclosures may cause with honest, fact-based communications; and (3) to be fully prepared to effectively respond to any accidental chemical release scenario.  Proactive materials about disclosure information, how the company is prepared to deal with an incident, and how the community should respond; and a process for announcing that an incident has occurred are being prepared.  In addition, training and  
information materials for the Perdue managers and employees, community officials, civic groups, media, environmental groups, emergency response personnel and the public in general will be available. 
 
Planned changes to improve safety: 
 
As part of Perdue's continual improvement philosophy, all Perdue facilities continue to identify and update components and techniques to ensure safety.
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