Kraft Foods Inc. - Executive Summary
KRAFT RISK MANAGEMENT PROGRAM DOCUMENT |
This document contains all required information in order to meet 40 CFR 68 Risk Management Program including an Executive Summary and RMP data elements (68.155 through 68.185).
1.0 Release Prevention and Emergency Response Policies
The Kraft Foods facility in Kirksville, Missouri has an excellent record in preventing releases of anhydrous* ammonia. The Kraft Foods facility has a thorough emergency training program for on-site emergency responders. The facility has implemented the MUSCLE system which is a system that uses a real time data base to track training and inspection dates and issue reminders to responsible groups. As part of the MUSCLE program, an annual audit is carried out by the Technical Services Group.
The emergency response policies at the Kraft facility ensure that there is emergency response coverage 24 hours - 7 days per week. There are also adequate provisions for coordination with outside agencies
, such as with the Kirksville Fire Department, in the event of an emergency.
*From this point in the Executive Summary, anhydrous ammonia will be synonymous with ammonia.
2.0 Process Description and Regulated Substances
Kraft Foods is a manufacturer of meat products. The NAICS code for the primary process at this facility is 311612. The facility is capable of producing and packaging various ham and bacon products for consumer intake but the plant is not equipped to slaughter hogs. Many areas of the plant are refrigerated to preserve the meat products.
Kraft Foods has a regulated substance under 40 CFR 68: ammonia. Ammonia is used as a refrigerant in the refrigeration of the meats in the various areas.
The ammonia threshold for triggering applicability to 40 CFR 68 is 10,000 pounds. The quantity of ammonia stored on-site is approximately 42,5006 pounds. Thus, 40 CFR 68 is applicable to Kraft Foods in Kirksville.
3.0 Worst-case and Alternative Release Scenarios
here are quality and safety systems in place at Kraft's Kirksville plant, a relaease from the ammonia refrigeration system could potentially affect employees on-site and the general public offsite. USEPA requires companies to use models for "worst case" and "alternative" release scenarios for each regulated chemical. Given the safety precautions at the plant, both scenarios are unlikely to occur. If a release occured, the alternative scenario would be more likely.
Ammonia is classified as a Group 2 Refrigerant per ASHRAE Standard 34-1989. The dominant characteristic of this chemical is its toxicity. It is a self-alarming chemical by its distinctive pungent odor. Due to this odor, persons exposed to ammonia vapor will not voluntarily stay in areas of even small concentrations. Ammonia will burn in a very narrow and high range of concentration with a high ignition temperature. It is not poisonous, but it is corrosive to human tissue. Ammonia is readily absorbed into the moisture o
f the skin and, at high concentrations, can cause severe burns.
The risks to persons in an accidental release of ammonia include:
1. Corrosive attack of skin and other tissue
2. Freezing of skin and other body tissue when contacted by liquid ammonia
Below is a description of the release scenarios for ammonia and their off-site consequences:
Worst-case scenario - the largest potential release of ammonia will occur with a puncture in one of the receivers located on the south side of the plant approximately 50 feet from the fenceline. Because of interconnecting pipework and other vessels that can discharge into this pipework, the amount of ammonia released will be greater than amount stored in one of the receivers. The connected other vessels include the condensers (eight) and the liquid transfer units. The low and high temperature accumulators are connected to the receivers through pipework; however, the accumulators cannot discharge ammonia into the receivers. The ammonia rel
ease in pounds is grouped in the following way:
1. Receivers #1 and #2 = 4,802 pounds
2. Condensers #1 - #8 = 2,642 pounds
3. Liquid Transfers Units AHD and ALD = 129 pounds
4. Interconnecting pipework = 360 pounds
Total Ammonia Released = 7,933 pounds
Under Section 68.25(c)(1), a regulated substance such as ammonia that is normally a gas at ambient temperature and handled as a liquid under pressure shall be considered to be released as a gas over a 10 minute period. Thus, ammonias physical state in the worst-case release is a gas. Passive mitigation controls were not applicable to the worst-case release at this plant.
The Model Risk Management Program and Plan for Ammonia Refrigeration (look-up tables - Table 2-1) was used to obtain the distance to toxic endpoint which is 1.6 miles. Rural dispersion coefficients were used.
The estimated affected residential population is 6,900 people. The types of affected receptors are listed in the Data Elements section.
ive Release Scenario - This scenario is more likely to occur than the worst-case release. In Krafts case the alternative release scenario is caused by the failure/blowing of a relief valve. The release rate of ammonia due to the relief valve failure is calculated to be 118 lb/min.
Table A-1 was used to determine the distance to toxic endpoint. An interpolation was made between the 100 lb/min and 150 lb/min release rate. The distance to toxic endpoint is 1,100 feet (0.2 miles).
The estimated affected residential population is 5 people. Only residences will be affected by a PRV release.
4.0 General Accidental Release Prevention Program and Chemical-Specific Prevention Steps
Kraft Foods has developed an OSHA PSM program for the ammonia refrigeration system. At Kraft, ammonia falls under the RMP Program 3 prevention program which is identical to the OSHA PSM program. EPA has said that if the process is in compliance with OSHA PSM, then it is in compliance with RMP Progra
m 3. Thus, Krafts ammonia PSM has been reviewed and determined to be complete for the RMP document.
There are several aspects of the prevention program that are key:
1. The Utility Service Area (USA) serves as an excellent safeguard for plant personnel because it greatly reduces the amount of ammonia piping inside the occupied rooms. Also, since most of the pipework is out of the way of people and the machinery, there is less of a chance of a ammonia release.
2. The plant maintains good training, certification and employee awareness of operating procedures.
5.0 Five-year Accident History
The review of Kraft Foods accident history includes the following range of dates: June 22, 1994 - June 21, 1999. To date, there have been no accidents with ammonia at the facility.
6.0 Emergency Response Program
As mentioned earlier, the Kraft facility has developed an emergency response program in which plant employees are divided into various response teams. There are nine in-plant c
ontacts for an emergency which can be found in the Emergency Response Plan. There are also back-up personnel in the event that the primary incident response personnel cannot be contacted. The emergency response plan includes information about the frequency of employee emergency response training as well as a detailed description of the training content. There are also specific procedures to follow in the event of an ammonia emergency.
At the discretion of the Incident Commander, the Kirksville Fire Department will be called to provide back-up emergency responders and equipment. The Kirksville Fire Department will be called for fire related emergencies. In all cases where the fire department is called, Adair County Ambulance District personnel will be called to the scene.
7.0 Planned Changes to Improve Safety
Based on the PHA completed for ammonia, a list of action items were developed and monitored to determine if implementation was accomplished. For example, in the ammon
ia system, a leak from condenser fittings, piping, valves or other instrumentation is a potential release scenario. The following action item was recommended: implement visual inspection program on piping systems. The recommendations were followed and the condenser inspection system was updated on 9/5/94. There are numerous other examples of safety improvements as a result of the PHA results. These include:
1. Need to post signs in appropriate locations that unauthorized personnel are not permitted in the engine room nor the USA areas. (Implemented, 4/97)
2. A hand truck will occasionally enter the engine room to move oil drums. Proper awareness of hazards is required. Only authorized personnel should be permitted to do this. (Implemented, 4/97)
3. Production personnel currently enter the engine room to turn evaporators on and off. These people need to be properly trained and certified in the operation of the ammonia system or this function should only be performed by the r
efrigeration system operators. (Implemented, 3/94)