Foremost Farms - Milan Facility - Executive Summary |
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Foremost Farms USA (Foremost Farms) stores up to 10,770 pounds of anhydrous ammonia at the dairy plant located at 2794 Randall Road, Athens, Wisconsin (the Property). It should be noted that the mailing address for the facility is Athens, while the plant is actually located within the Village of Milan. 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 Milan 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-Milan management system lists Mr. Dan Williams, Plant Manager, as having overall responsibility for implementation of the risk management program. Facility managers and supervisors assist th e 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 2,570 pounds of ammonia from the refrigeration system, resulting in a distance to toxic endpoint of 0.9 miles. The OCA's selected alternative release scenario was a release of 2060 pounds of ammonia in ten minutes and a distance to toxic endpoint of 0.3 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. Recreation areas are also located within both the worst-case and alternative release vulnerable zones. 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 Occupational Safety and Health Administration (OSHA) Process Safety Management (P SM) 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 Milan facility also has an existing Emergency Response Program (ERP). Based upon a review of the existing PSM and ERP, and discussion with facility management, specific items must be addressed to meet the requirements of 40 CFR Part 68. The items are described in this report. The final major component of the risk management program is the submittal of the risk management plan (RMP), a summary document which must be submitted to the EPA by June 21, 1999. RMPs must be submitted on diskette (USEPA (b), November 1998). A certification statement must also be signed by a person with overall responsibility for implementing the risk management program. The certification statement must be submitted with the diskette. A certification statement for Foremost Farms' signature, and a diskette with the RMP information is provided with this report. The analysis and recommendations presented in this report are based upon information provided by Foremost Farms to Northern Environmental. Information was obtained from Foremost Farms documents, responses to questionnaires, and site visits to the Milan plant by Northern Environmental. On March 18, 1999, Mr. Joseph E. Winch, P.E. (Northern Environmental) met with Mr. Dan Williams (plant manager) and Mr. Mengel ("Curley") Kruger (maintenance supervisor) to verify information previously provided by Foremost, and to discuss the hazard assessment, prevention program, and emergency response program. |