Dairy Farmers of America - Executive Summary

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Cabool, MO   
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 
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 
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.
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