Foremost Farms - Madison Facility - Executive Summary

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Foremost Farms USA (Foremost Farms) stores up to 12,000 pounds of anhydrous ammonia at the fruit juice plant located at 3101 Fish Hatchery Road, Madison, Wisconsin (the Property). Ammonia is used as a refrigerant at the 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 Madison 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-Madison management system lists Mr. Bob Voss, General 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 hi 
story.  The OCA's worst-case release scenario was the loss of 2000 pounds of ammonia from the high pressure receiver of the refrigeration system, resulting in a distance to toxic endpoint of 0.6 miles. The OCA's selected alternative release scenario was a release of 350 pounds of ammonia in five minutes and a distance to toxic endpoint of 0.3 miles.  According to 1990 Census data, there are a total of 774 persons within the worst-case vulnerable zone, and 632 persons within the alternative release vulnerable zone.  Residences, recreation areas, and commercial/office/industrial areas are located within both the worst-case and alternative release vulnerable zones.  In addition, schools are located within the worst-case 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 Manag 
ement (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 Madison 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 Foremost Farms-Madison facility also has an Off-Site plan for the facility in conformance with the emergency planning requirements of Title III of the Superfund Amendments and Reauthorization Act (SARA).  Th 
e most recent updates to the plan were prepared in 1999, and submitted to the Dane County Department of Emergency Management. 
 
The actions that Foremost Farms employees will perform in the event of an ammonia release  will in some cases  constitute a "response" by the OSHA definition.  Foremost Farms will coordinate with the Fitchburg fire department to respond to ammonia releases.
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