Kraft Foods, Inc. - Executive Summary |
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EXECUTIVE SUMMARY for AVON: 1.0 Release Prevention and Emergency Response Policies The Kraft Foods facility in Avon, New York, has an excellent record in preventing and minimizing releases of anhydrous ammonia (hereafter, anhydrous ammonia will be referred to as ammonia). This facility has implemented an electronic preventive maintenance system. This system uses a real time data base to track preventive maintenance, training and inspection dates and issue reminders to responsible groups. The emergency response procedures at this facility ensure emergency response coverage, 24 hours a day, 7 days a week. There are also adequate provisions for coordination with outside agencies, such as with the Avon, New York Fire Department and the Livingston County, New York Emergency Planning Committee, in the event of an emergency. 2.0 Process Description and Regulated Substances Kraft manufactures frozen whipped toppings and lunch combination products at the Avon, NY, plant. The North Ame rican Industrial Classification System (NAICS) code for the primary process at this facility is 311991. Kraft has one regulated substance under 40 CFR 68 at the Avon, NY, plant -- ammonia. The storage and process areas of the plant are refrigerated by ammonia to keep the products fresh and wholesome. Ammonia has been widely used as a refrigerant in the food industry for decades. The ammonia threshold for triggering applicability to 40 CFR 68 is 10,000 pounds. The quantity of ammonia stored on-site is approximately 95,000 pounds. Ammonia is classified as a Group 2 Refrigerant per ASHRAE Standard 34-1989. Its distinctive, pungent odor is very noticeable to most people, even in small quantities. Ammonia is flammable in a very narrow and high range of concentration with a high ignition temperature. It is not poisonous, but it can be corrosive to human tissue. Ammonia is readily absorbed into the moisture of the skin and, at high concentrations, can cause burns. The potential risks to people exposed to an accidental ammonia release include irritation of respiratory tract, burning of skin and other tissue when contacted by ammonia vapor, and freezing of skin and other body tissue when contacted by liquid ammonia. 3.0 Release Scenarios Although there are quality and safety systems in place at Krafts Avon, New York plant, a release 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 alternate release scenarios for each regulated chemical. Given the safety precautions at the plant, both scenarios are unlikely to occur. If a release occurred, however, the alternative scenario would be more likely. The ammonia release scenario was modeled using SLAB (June 1990 version) to obtain the distance to the ERPG-2 endpoint. The Emergency Response Planning Guideline, Level 2, ERPG-2, was developed by the American Industrial Hygiene Association. It refers to the level of ammonia that individuals could be exposed to for up to one hour without being subjected to irreversible or other serious health effects that could make it difficult for them to leave the affected area. 4.0 General Accidental Release Prevention Program and Chemical-Specific Prevention Steps This facility has developed an OSHA PSM program for its ammonia refrigeration program. There are several key aspects of the prevention program: 1. Utility personnel are present on site and assigned to the ammonia system, 24 hours a day, 7 days a week, all year round. 2. There is a plant-wide ammonia detection system which alerts the utility personnel and security area personnel, and both of these areas are staffed continuously. 3. Most of the ammonia pipe work is located away from employee traffic patterns and machinery to minimize the chance of an ammonia release. 4. The plant maintains good training, certification and employee awareness of operating procedures (monthly drills with the emergency response team and an annual drill with the Avon fire department and the LEPC). 5. About 80% of the entire ammonia system has been replaced within the last 36 months to further improve the safety and efficiency of the plant. This facility also has developed and implemented an OSHA Process Safety Management (PSM) program for its ammonia refrigeration system. 5.0 Five-year Accident History There have been no accidental releases at this facility between June 22, 1994 and June 21, 1999, as defined by 40 CFR Part 68.42(a). 6.0 Emergency Response Program As mentioned earlier, this facility has developed an emergency response plan, including, but not limited to, steps to address the following topics: 7 accidental discharge of hazardous substances and hazardous waste into the envir onment 7 the measures to be taken to prevent an accident 7 countermeasures to be taken in the event of an emergency, and; 7 procedures for containing and limiting the duration of the emergency measures to be employed for further protection of employees responding to the emergency, as well as other plant personnel This plan also incorporates the Spill Prevention Control and Countermeasures Plan (SPCC), by reference, which includes information about the location, types and amounts of chemicals stored on-site, notification procedures, and countermeasures to be taken in the event of a spill. It also deals with training for plant personnel who respond to spills and leaks anywhere on site. The purpose of the SPCC document is to also establish procedures to notify appropriate agencies (like the LEPC and the Avon Fire Department) and company personnel in the event of an emergency. It includes planning for potential spills and the appropriate responses and countermeasures. Our comprehensive emergency response plan is designed to protect our employees and the community and, among other things, requires that: 7 All nonessential personnel immediately exit the area affected by the release; 7 Kraft immediately notify local officials, requesting their assistance, if necessary; For a release which leaves the Kraft site, the company would work with local fire and police officials to notify neighbors so that appropriate safety precautions could be taken. If ammonia is in the outside atmosphere, the safest place to be is indoors with windows and doors shut. 7. Improvements to Enhance Safety Program Over the past 36 months, the following improvements have been made to the Facility ammonia system: -Installed a plant wide ammonia leak detection system. -Constructed a centralized ammonia equipment room with state of the art safety features. -Emergency shutdown controls for ammonia system. -Facility wide monitoring/control of ammonia system. -Renovation of 80% of t he ammonia piping, valves, and vessels. |