Roche Vitamins Inc. - Executive Summary |
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The Roche Vitamins Inc. (Roche) facility in Willow Island, WV manufactures livestock feed additives via batch fermentation. The facility operates two "processes" that are subject to the US Environmental Protection Agency's (EPA's) Risk Management Planning regulation: two 10,000-gallon anhydrous ammonia tanks. The ammonia is used as a feed material for fermentation. This Executive Summary has been prepared to provide an overview of the facility's Risk Management Plan, and address the requirements of 40 Code of Federal Regulation (CFR) 68.155(a)-(g). Accidental Release Prevention and Emergency Response Policies: The Roche Vitamins facility complies with the Occupational Safety and Health Administration's (OSHA's) Process Safety Management regulation, as well as the USEPA's Accidental Release Prevention requirements. Roche Vitamins has an Emergency Response Plan, and coordinates emergency response activities (procedures, training, drills, etc.) with the adjacent Cytec Industries Inc. facility. Regulated Substances Handled: The only processes at the Roche Vitamins facility that are subject to the Risk Management Planning requirements are the two 10,000-gallon anhydrous ammonia tanks. Worst-Case and Alternative Release Scenarios: The worst-case release scenario for the facility is the release of the entire contents of one 10,000-gallon anhydrous ammonia tank in 10 minutes. The distance to the endpoint for the worst-case release scenario is estimated to be 3.7 miles. The alternative release scenario is a failure of the liquid line used to transfer anhydrous ammonia from tank trucks to storage tanks while material is being transferred. The distance to the endpoint for the alternative release scenario is estimated to be 0.3 miles. General Accident Prevention Program and Specific Prevention Steps: Roche Vitamins has an Accident Prevention Program for the ammonia tanks that includes the following elements: - Identification of the potential hazards associ ated with the subject processes. - Written operating procedures that provide clear instructions for operating the tanks in a wide range of conditions. - Training of employees and contractors on the hazards associated with the ammonia tanks. - A Mechanical Integrity Program that includes a schedule for inspection, maintenance, and replacement of equipment associated with the ammonia tanks. - A Management of Change Program to ensure that a safety review is conducted whenever critical components of the subject processes are changed. - A Hot Work Permit Program. - Review of contractors' safety programs, and periodic review of performance. Five-Year Accident History: There have been no releases in the past 5 years that resulted in an on-site or off-site impact. Emergency Response Program: Roche Vitamins and the adjacent Cytec Industries facility have a joint Emergency Response Program. This program includes procedures for responding to an ammonia release, evacuating employees, and no tifying local police and fire departments as appropriate. Planned Changes to Improve Safety: None. |