Alto Dairy Cooperative - Executive Summary

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Alto Dairy Cooperative is a dairy product manufacturer located in the Town of Alto, Fond du Lac County, Wisconsin.  As a cooperative, it is owned by area milk producers.  The facility produces cheese and powdered whey from milk purchased from area farmers. 
The processing of these dairy products requires the use of anhydrous ammonia, propane, and other chemicals.  Milk that arrives at the facility, as well as the products produced at the facility must be kept at refrigerated temperatures to maintain quality and shelf-life.  As a result of this need for chilling processes and refrigerated storage areas, Alto Dairy utilizes an ammonia refrigeration system.  The system contains approximately 12,950 pounds of anhydrous ammonia.  The powdered whey produced at the facility must be processed on daily basis.  Because of the possibility of natural gas interruption to the facility and the need to handle the whey on a daily basis, Alto Dairy has propane storage tanks on site for back-up fuel for  
the boilers and the dryer facility.  There are three propane storage tanks on the site with a total capacity of 90,000 gallons or 330,000 pounds.     
Propane and ammonia, although necessary components of Alto Dairy's processing, can be dangerous to employees, the public in the immediate vicinity of the plant, and the environment if released in an uncontrolled manner in substantial quantities.  Alto Dairy has recognized the inherent risks with these two materials and has therefore developed and implemented a Risk Management Program to: 
- prevent accidental releases of ammonia and propane; and 
- respond appropriately to accidental releases, if any, of ammonia and propane. 
Alto Dairy's Prevention Program for propane and ammonia consists of the following elements:   
1)  Safety information for propane and ammonia has been gathered and evaluated to assist Alto Dairy employees in understanding the hazards associated with the process.  This information then formed the basis for other preve 
ntion program elements to minimize the potential of accidental releases, fires, or explosions. 
2)  A hazard evaluation was completed for propane and ammonia.  The purpose of the analysis was to identify, evaluate, and control the hazards in the process. 
3)  Written operating procedures were carefully developed so that employees at Alto Dairy have access to written instructions for the safe operation of and maintenance of the ammonia and the propane processes. 
4)  Employees at Alto Dairy have been trained, and will continue to be trained, on the job and in the classroom, on all aspects of the prevention program and the emergency response program. 
5)  A preventive maintenance system has been developed to assure that all components of the systems are in good working order so that they can function appropriately. 
6)  Any modifications to the ammonia system will be carefully evaluated and engineered to confirm that the changes will maintain a safe working system.  Prior to the startup of an 
y new or modified system, Alto Dairy will conduct a comprehensive evaluation of the changes and modify the Risk Management Program to incorporate the new or modified system. 
7)  Employees at Alto Dairy have been part of the development of the Risk Management Program and will have a role in the continuous improvement of the program. 
8)  Any incident, accident, or even "near misses" associated with the propane or ammonia system will be investigated thoroughly and promptly with a commitment to make improvements to the program. 
9)  As part of the continuous improvement process, Alto Dairy will conduct audits at least once every three years to identify and correct any parts of the program that are not functioning up to their standards.  These audits are in addition to efforts to improve the program on a regular basis. 
10)  Alto Dairy will make sure its contractors on the site are aware of the hazards associated with the ammonia system to protect all parties (contractors, employees, and neig 
hbors).  For specific tasks that require an even higher degree of oversight (such as welding, cutting or grinding around the ammonia refrigeration system), Alto Dairy will require its employees and contractors to obtain internal permits that mandate special prevention measures. 
Alto Dairy has developed and implemented an emergency response program to protect public health, the environment, and on-site employees.  Employees have been trained in emergency response.  Systems are in place to inform the public and the Fond du Lac County emergency response agencies in the event of the release.   
Although the main purpose of the Chemical Accident Prevention Provisions (40 CFR 68) is to develop and implement programs to prevent releases of toxic substances and accidents with flammable substances, the federal rule also required that Alto Dairy complete analysis of theoretical impacts from catastrophic accidents on the site.  The federal rule has a very defined method for determining the "wors 
t-case" situation even though the chances of this situation actually occurring are fairly small.  Even the "alternative" scenarios, defined by the rule, require that the hazardous substance is large enough to cause off-site impacts.  Again, the chances of this actually occurring with a prevention program in place are fairly small. 
For ammonia, the worst-case release could impact locations as far as 0.8 miles from Alto Dairy.  The alternative scenario for ammonia, based on leak in a high pressure liquid line, is 0.22 miles from the site.  For propane, the worst-case release could impact locations as far as 0.5 miles from Alto Dairy.  The alternative scenario for propane, based on a leak on one of the three tanks, could impact locations 0.09 miles from the site. 
Alto Dairy has not had an accident with ammonia or propane in the last five years that requires reporting under this rule. 
Alto Dairy has demonstrated their commitment to minimize the potential for accidental releases and thus 
protect their employees, neighbors, and the surrounding environment in the following manner: 
- Committing significant resources to the training of operation, maintenance, and emergency response personnel; 
- Hiring external consultants to provide a high level of program competence; 
-Proceeding with the develop a risk management program for propane even though current legal challenges and proposed regulatory changes do not make it mandatory to do so at this time; and 
- Dedicating themselves to the continuous improvement of the prevention program at Alto Dairy to further minimize the potential for accidents. 
Members of the public are encouraged to talk to Alto Dairy about Alto Dairy's Chemical Accident Prevention Program.  (Telephone:  920-346-2215)
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