Dairy Farmers of America - Executive Summary |
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DAIRY FARMERS OF AMERICA Cabool, MO EXECUTIVE SUMMARY 1.0 Release Prevention and Emergency Response Policies Dairy Farmers of America located in Cabool, Missouri (DFA-Cabool) is committed to the protection of the safety, health, and environment in our routine operations and emergency responses. Our prevention and emergency response practices are developed to protect the public as well as our own employees. It is our policy to comply with applicable laws, and to support and work with local emergency response agencies. DFA-Cabool has a refrigeration system which contains anhydrous ammonia (ammonia) in an amount greater than the threshold under the Risk Management Program (RMP) of the Environmental Protection Agency (EPA) according to Section 68 of Title 40 of the Code of Federal Regulations (40 CFR 68). The refrigeration system is designed and operated according to good engineering and safe work practices. DFA-Cabool has established an Emergency Response Program that provides fo r trained personnel on call in the event of a release. DFA-Cabool is also coordinated with the Cabool Fire Department and the Texas County Local Emergency Planning Committee (LEPC). DFA-Cabool has an excellent safety record in preventing and minimizing releases of ammonia. 2.0 Facility description and Regulated Substances The DFA-Cabool facility processes and packages dairy related products. DFA has on-site an ammonia refrigeration system used to maintain product freshness, to meet processing requirements, and to provide cooling for employee comfort. DFA-Cabool is subject to the requirements of 40 CFR 68 because the refrigeration system contains more than the 10,000-pound threshold for ammonia, a regulated hazardous substance. 3.0 Worst-case and Alternative-case release scenarios 3.1 Worst Case Release Scenario Section 68.25 of the RMP requires a modeling of a worst-case scenario of a release of the hazardous substance. A worst-case scenario release is defined as the release of the largest quantity of a regulated substance from a [single] vessel or process line failure. RMP*Comp is used to calculate the greatest distance from the point of release where a specified toxic concentration is reached. At DFA-Cabool, the worst-case accidental release scenario assumes an instantaneous release of the entire contents of the largest vessel containing ammonia. Application of EPA'sdispersion modeling software RMP*Comp shows that the toxic endpoint would affect residential populations and industrial areas. This worst-case release scenario is pre-defined and is highly unlikely to occur. 3.2 Alternative Case Release Scenario A Process Hazard Assessment (PHA) was recently performed at the DFA-Cabool facility. From the PHA, the alternative case release scenario was determined. The alternative release scenario is based on a 1/4" hole in the process piping. This failure will conservatively assume ammonia will release for 30 minutes from the roof of the facility (30 fee t above ground). Modeling of this release was performed using the EPA's dispersion modeling software RMP*Comp and shows that the toxic endpoint will affect residential populations. 4.0 The General Accidental Release Prevention Program and Chemical-Specific Prevention Steps DFA-Cabool has an accidental release prevention program to prevent and minimize the effects of a spill or release of ammonia. This program includes a training program for all operators and maintenance personnel, written maintenance and operating procedures, and a preventative maintenance program that includes regular inspections and tests of all equipment within the ammonia system. 5.0 Five year Accident History In the past five years, there have been no accidental releases of ammonia as outlined in '68.42 of the RMP Regulations. 6.0 The Emergency Response Program DFA-Cabool maintains a written Emergency Response Plan to help assure timely, safe, compliant responses in the event of an emergency. As stated previously, DFA-Cabool's Emergency Response Program provides for trained personnel on call in the event of a release. DFA-Cabool is coordinated with the Cabool Fire Department and the Texas County LEPC. In the event of a release, we would immediately notify our affected employees, the Cabool Fire Departments, the Texas County LEPC and initiate emergency shutdown procedures. 7.0 Planned Changes to Improve Safety A PHA was recently performed at the DFA-Cabool facility. Recommendations from that PHA are being implemented which will improve the safety of the ammonia process as well as reduce the likelihood and magnitude of any ammonia spill. |