Kraft Foods, Inc., Champaign - Executive Summary

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1.0 Release Prevention and Emergency Response Policies 
The Kraft Foods facility in Champaign, Illinois has an excellent record in preventing and minimizing releases of anhydrous* ammonia.  This facility has implemented an electronic preventive maintenance system.  This is a system that uses a real time data base to track training and inspection dates and issue reminders to responsible groups. 
The emergency response policies at this 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 Champaign 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 
At this location Kraft Foods  manufactures  processed cheese, pourable and spoonable salad dressings, and pasta dinners.  The SIC codes for the  primary proces 
ses at this facility are 2022, 2035 and 2098.  The facility is divided into east and west side production units.  The east side consists of two production units, one vacant and the other for processed cheese (single slices, etc.).  The west side consists of four (4) production units with three working units - 1) pourable salad dressings, 2) spoonable salad dressings, and, 3) pasta dinners.  Many areas of the plant are refrigerated to preserve the ingredients and finished products.  Some of these areas include: receiving, processing, and other storage areas.  
Kraft Foods has one regulated substances under 40 CFR 68: i.e., ammonia, at this location.  Ammonia is used as a refrigerant in the refrigeration of the products in the various areas described above. 
The  ammonia threshold for triggering applicability to 40 CFR 68 is 10,000 pounds. The quantity of ammonia stored on-site is approximately 100,000 pounds. Thus, 40 CFR 68 is applicable to Kraft Foods in Champaign, IL 
3.0 Worst-case  
and Alternative Release Scenarios 
The ammonia refrigeration system has associated hazards that can potentially  effect on-site employees and the general public off-site if there is a release from either system. Although the alternative release scenario is more probable, the US EPA requires that one worst-case and one alternative release scenario be reported for each regulated chemical. Described below are the associated hazards and the worst-case and alternative release scenarios for each regulated chemical. 
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 is flammable in a very narrow and high range of concentration with a high ignition temperature.  It is not poisonous, but it is corrosive to hum 
an tissue.  Ammonia is readily absorbed into the moisture of the skin and, at high concentrations, can cause severe burns. 
The risks to persons in an accidental release of ammonia include: 
1. Irritation of respiratory tract, 
2. Corrosive attack of skin and other tissue, 
3. 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 one inch diameter puncture in the liquid portion of the high pressure receivers (largest vessel capacity is the 2 high pressure receivers combined and their associated piping when used for pumpout of the system) located outside the west compressor room.  Taking the specific definition of the worst-case from 40 CFR 68.25, the largest quantity of ammonia that can be stored in a vessel is in the high pressure receiver during a pump-out situation.  The total quantity of am 
monia that can be stored in the 2 high pressure receivers is 47,293 pounds without administrative controls.  It is assumed that 47,293 pounds is released to the atmosphere in 10 minutes. 
Under Section 68.25(c)(1), a regulated toxic substance such as ammonia, which 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. 
 The ammonia worst case release scenario was modeled using SLAB (June 1990 version) to obtain the distance to endpoint. The ERPG-2, has been developed by the American Industrial Hygiene Association and are applicable to exposures for up to one hour.  ERPGs protect individuals from health-threatening or escape-impairing injury and is not generally considered fatal. 
SLAB is a computer model developed (1983) by Lawrence Livermore Laboratories and sponsored by the Department of Energy (DOE) and EPA.  SLAB is a 
dense gas model (also models neutrally-buoyant and includes lofting of a cloud if it becomes lighter than air) for various types of releases including a ground-level evaporating pool, an elevated vertical and horizontal jet, and an instantaneous volume source.  The model solves the conservation equations of mass, momentum, energy, and species.  It can simulate continuous, finite duration, and instantaneous releases. 
Urban dispersion coefficients  (0.9 m surface roughness) were used during modeling runs for the Champaign facility in accordance with Appendix W to Part 51- Guidelines on Air Quality Models Section 8.2.8. 
Alternative Release Scenario - The worst-case release is less likely to occur than the following scenario:  
Alternative Release Scenario Description  
 The alternative release scenario that meets both selection criteria is an ammonia release from the PRVs on the compressors (HC1, HC2, HC3 and HC4) in the east compressor room.  This produces a horizontal jet releas 
e.  The compressors are located indoors in the east engine room and the PRVs on these compressors all release at the same time through the same line (1 line) on the roof. There are no applicable administrative controls or passive mitigation. Active mitigation of the release is human intervention (PRVs shutdown at 10 minutes from the start of the release).   
 Our calculations showed that the ammonia vapor release rate is 230.8 lb/min (combined - for HC1, HC2, HC3 and HC4 releasing at the same time). 
 Refined computer modeling was used to determine the distance to ERPG-2 endpoint.  A surface roughness coefficient of 0.9 m was used as well as a wind speed of 3 m/s and an atmospheric stability class D. 
4.0 General Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
This facility has developed an OSHA PSM  program for  their  ammonia refrigeration system.  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 Program 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. Since most of the pipe work is out of the way of people and the machinery, there is less of a chance of an ammonia release. 
2. The plant  maintains good training, certification and employee awareness of operating procedures). 
5.0 Five-year Accident History 
The review of this facility's accident history includes the following range of dates: June 22, 1994 - June 21, 1999.  According to 40 CFR Part 68.42(a), there have been no accidental releases at this facility. 
6.0 Emergency Response Program 
As mentioned earlier, this facility has developed an emergency response program which complies with the OSHA standard and contains procedures for: 
7 Emergency escape 
7 employees and accounting of all employees 
7 Rescu 
e and medical duties 
7 Reporting 
7 Emergency notification (Champaign Fire Department) 
7 Alarm systems 
7 Evacuation, and 
7 Training 
As part of the emergency notification procedures, the Champaign Fire Department will be called to provide first emergency responders, equipment, and service.  The Champaign Fire Department will be called for all fire related emergencies.  In all cases where the fire department is called, an ambulance will also be called to the scene. 
This HAZWOPER and Emergency Response plan addresses all the above mentioned procedures in detail.  This level of detail makes the emergency response program at Kraft Champaign a thorough and comprehensive program. 
7.0 Planned Changes to Improve Safety 
Based on the what-if" PHA completed for ammonia a list of action items was developed and is being monitored to determine if implementation was accomplished.  For example, in the ammonia system, a potential release scenario is when the oil drain valve sticks open.  The followi 
ng action items were recommended: initiate operating procedures (IOP), implement oil drain procedures, double valve arrangement, and attach to blow back line  the management response was to replace reciprocating and screw compressors to minimize the need for oil draining.  This recommendation was followed and as of May 1995 all compressors are of the screw type.  There are numerous other examples of safety improvements as a result of the PHA results.  These include: 
1. Require annual fork truck training (fork truck training program expanded in 1996) 
2. Need expanded PMs, lubrication log, ammonia detection and IOP (Equipment logs are now available on the east compressor room computer) 
3. Leak could occur and the ammonia detectors are not operating properly  
(ammonia detection system installed in 1998) 
4. Production personnel only have access to process cooling equipment controls (not to refrigeration system controls).  The refrigeration system is maintained and controlled by prope 
rly trained refrigeration system operators.
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