Foremost Farms - Marshfield Facility - Executive Summary

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Foremost Farms USA (Foremost Farms) stores up to 10,001 pounds of anhydrous ammonia at the dairy plant located at 1511 East 4th Street, Marshfield, Wisconsin (the Property).  Ammonia is used as a refrigerant at the fluid milk dairy facility.  The quantity stored exceeds the 10,000 pound TQ for ammonia, and is therefore regulated under 40 CFR Part 68.  Foremost Farms contracted Northern Environmental to prepare a Risk Management Program for ammonia at the Marshfield facility.  The Risk Management Program consists of five elements:  the management system, hazard assessment, prevention program, emergency response, and the risk management plan (RMP) submittal. 
The Foremost Farms-Marshfield management system lists Mr. Randy Paulson, Plant Manager, as having overall responsibility for implementation of the risk management program. Facility managers and supervisors assist the plant manager as delegated. 
The hazard assessment included an off-site consequence analysis (OCA) and a summary of t 
he 5-year accident history.  The OCA's worst-case release scenario was the loss of 2160 pounds of ammonia from the ice builder unit of the refrigeration system, resulting in a distance to toxic endpoint of 0.8 miles. The OCA's selected alternative release scenario was a release of 2160 pounds of ammonia from the ice builder unit in 36 minutes,  resulting in a distance to toxic endpoint of 0.07 miles.  According to 1990 Census data, there are a total of 904 persons within the worst-case vulnerable zone and 7 persons within the alternative release vulnerable zone.  Residences, schools, recreation areas, and commercial/office/industrial areas are located within the worst-case release vulnerable zone.  Residences and commercial/office/industrial areas are located within the alternative release vulnerable zone.  There have not been any accidents within the last five years that resulted in deaths, injuries, property damage, or environmental damage.  
Since ammonia is also regulated under the 
Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Standard (29 CFR 1910.119), the prevention program elements under Program 3 of 40 CFR Part 68 apply.  These elements are safety information, process hazard analysis, operating procedures, training, mechanical integrity, management of change, pre-startup review, compliance audits, incident investigation, employee participation, hot work permit, and contractors.  These elements are being implemented at the facility under the PSM program.  
The actions that Foremost Farms employees will perform in the event of an ammonia release  will not constitute a "response" by the OSHA definition.  Foremost Farms will coordinate with the Marshfield Fire Department to respond to ammonia releases.
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