Foremost Farms USA, aka Golden Guernsey Dairy - Executive Summary |
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Foremost Farms USA (Foremost Farms) stores up to 32,000 pounds of anhydrous ammonia at the dairy plant located at 2101 Delafield Street, Waukesha, 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 Waukesha 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-Waukesha management system lists Mr. Eric Van Den Huevel, 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 the 5-year accident history. The OCA's worst-case release scenario was the loss of 15,000 pounds of ammonia from the refrigeration system, resulting in a distance to toxic endpoint of 1.5 miles. The OCA's selected alternative release scenario was a release of 4200 pounds of ammonia in fifteen minutes and a distance to toxic endpoint of 0.1 miles. According to 1990 Census data, there are a total of 11,062 persons within the worst-case vulnerable zone, and 23 persons within the alternative release vulnerable zone. Residences, schools, recreation areas, prisons/correctional facilities, hospitals, and commercial/office/industrial areas are located within the worst-case 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. Because ammonia is also regulated under the Occupation al 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 existing PSM program. The Waukesha facility also has an existing Emergency Action Plan (EAP) designed to meet the requirements of: 7 29 CFR 1910.119 (n) - Emergency Planning and Response 7 29 CFR 1910.38 (a) - Emergency Action Plan 7 29 CFR 1910.38 (b) - Fire Prevention Plan 7 29 CFR 1910.120 (q) - Emergency Response to Hazardous Substances The actions that Foremost Farms employees will perform in the event of an ammonia release will in some cases constitute a "response" by the OS HA definition. Foremost Farms will coordinate with the Waukesha fire department to respond to ammonia releases. Based upon a review of the existing PSM and EAP, and discussion with facility management, specific items must be addressed to ensure continued compliance with the requirements of 40 CFR Part 68. The items are described in the Risk Management Program Manual that is maintained at the facility. |