Dairy Farmers of America - Executive Summary
Established in 1909, the Goshen, Indiana facility is a major food processor of milk based products. The Goshen facility produces butter, powdered milk, and condensed milk under the brand name Dairy Maid and many other private labels. The facility uses anhydrous ammonia, a regulated substance, as a refrigerant in two industrial sized refrigeration systems for cooling raw milk, process operations and final product storage. Some portions of both systems are located indoors and some are located outdoors. |
DFA corporate and facility staff is committed to safety and is continually evaluating ways to improve safety programs and reduce chemical usage. In 1995 DFA developed a Process Safety Managment (PSM) Plan in compliance with OSHA 29 CFR 1910.119. The OSHA PSM Plan for all practical purposes is identical to the EPA Risk Management Prevention Program 3 Plan. In the preamble to the final Risk Management Rule, EPA States: "A source owner or operator can demonstrate compliance with the P
rogram 2 of 3 prevention program under today's rule for a covered process by showing that it complies with the PSM standard." Within the last eight months the facility has hired new managers to replace those managers who had been previously responsible for administering the PSM Plan and other safety and environmental programs. Due to DFA management's concern for the safety of its employees, the community and the environment, DFA has voluntarily elected to conduct a thorough review and update of its PSM Plan, including a new Process Hazard Analysis (PHA).
The worst-case release scenario was modeled according to EPA guidelines and evaluated the catastrophic failure of the largest, full, high pressure anhydrous ammonia tank which is located outdoors. No mitigation measures were considered in the off-site consequence analysis. It is not likely that such an event would occur.
EPA requires that five alternative release scenarios be considered and it should be one more likely to occur t
han the worst-case scenario. For purposes of the Risk Management Plan, the example alternative release scenario was used from EPA's guidance document entitled "Model Risk Management Programand Plan for Amonia Refrigeration".
DFA had a small reportable release of anhydrous ammonia (greater than 100 lbs.) on March 15, 1995, which was immediately reported upon detection to appropriate local, state and federal agencies. The release was due to a faulty anhydrous ammonia safety relief valve on the cooling jacket of a raw milk storage tank. Shortly after the incident, DFA inspected and replaced, as needed, all safety relief valves on the two refrigeration systems. DFA has also implemented a program to replace all safety relief valves every 5 years.
The facility is covered by the Elkhart County Local Emergency Planning Committee (LEPC) emergency response plan and has procedures for notifying local emergency responders in the event of an accidental release of anhydrous ammonia.