Kraft Foods, Inc. - Executive Summary

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1.0 Release Prevention and Emergency Response Policies 
The Kraft Foods,  Lehigh Valley facility in Allentown, PA has an excellent record in preventing and minimizing releases of anhydrous* ammonia. This facility has a thorough emergency training program for on-site emergency responders.  The facility has implemented an electronic preventive maintenance system.  One of the features of this system is that it uses a real time database to track training and inspection dates.  The database is used to 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 Trexlertown Fire Department and the LEPC, 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 

t this location Kraft Foods manufactures processed and natural cheeses, portion control (small packaged condiments), salad dressing, viscous and pourable mayonnaise, and barbecue sauce.  The North American Industry Classification System (NAICS) code for the primary process at this facility is 311513.  Several areas of the plant are refrigerated to store raw materials and finished products.  Some of the areas that require refrigeration include: cheese processing, receiving, distribution, raw ingredient storage, and finished product storage. 
Kraft Foods has one regulated substance, ammonia, under 40 CFR 68. Ammonia is used as a cooling agent in the refrigeration of the food products listed above. 
The ammonia threshold for triggering applicability to 40 CFR 68 is 10,000 pounds. The quantity of ammonia stored on-site is approximately 73,710 pounds.  The federal regulation 40 CFR 68 is applicable to the Lehigh Valley facility. Thus, Kraft is submitting an RMP to the EPA in compliance with 
the regulation. 
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 Allentown, PA plant, a release from the ammonia refrigeration system could potentially affect employees on-site and the general public off-site.   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 is regulated under PSM, and 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. The majority of the ammonia piping is located in low traffic areas.  The placement of the piping allows for the majority of the pipe work to remain out of the way of people and machinery, proving less chance for an ammonia release.   
2. The plant maintains good training, certification and employee awareness of operating procedures. 
3. The plant has installed a control system to monitor and notify plant personnel by the use of alarms in the event of an ammonia release. 
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 has been no accidental relea 
ses at the Lehigh Valley facility.   
6.0 Emergency Response Program  
The Lehigh Valley Facility has developed an emergency response program and a Process Safety Management Program in which plant employees are divided into various management and response teams. There are back-up personnel in the event that the primary incident response personnel cannot be contacted. The emergency response plan and the Process Safety Management plan include 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 a fire or an  ammonia emergency.   
At the discretion of the Incident Commander, the Trexlertown Fire Department will be called to provide back-up emergency responders and equipment.   The Trexlertown 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. 
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 environment 
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 
Our comprehensive emergency response plan is designed to protect our employees, environment 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 officials to notify neighbors so that appro 
priate safety precautions could be taken. If ammonia is in the outside atmosphere, the safest place to be is indoors with windows and doors shut and the ventilation system turned off. 
7.0 Planned Changes to Improve Safety  
Based on the what-if PHA completed for ammonia, a list of action items were developed and are being monitored to determine if implementation was accomplished.  During the PHA the plant personnel examined specific ammonia process units for possible hazardous situations.  Several of the items listed in the PHA are discussed below. 
1. The plant was concerned about an ammonia leak from the compressor units.  In order to prevent this from happening the plant installed an ammonia detection system, exhaust fans, conducting daily inspections, installed guard posts, and conducting operator training. 
2. The Lehigh Valley personnel examined the possibility of a hazardous situation occurring by an ammonia leak from the process condensers. The personnel developed a plan to  
reduce such an occurrence.  The items addressed by this plan were: operator training, system alarms, audit of equipment, guard posts, forklift training, warning signs, HAZWOPER training, and insertion of valve access equipment. 
3. Hazardous situations that could arise from pressure vessels were also examined.  The Lehigh Valley plant personnel addressed the initiation of the following precautions: operator training, daily inspections, instrumentation audit, guards and supports, warning signs, replacement of damaged insulation, valve tagging, installation of valve access equipment, forklift training, and HAZWOPER training. 
4. A PHA was performed on the oil coolers.  The plant personnel developed the following preventative measures: installation of catwalks. 
5. Evaporator units were examined for possible hazardous situations.  The following preventative measures were developed: installation of ammonia detectors, ammonia detection controlled fans, evacuation drills, operator training,  
piping inspection, replacement of damaged insulation, daily round inspection, and installation of valve access equipment. 
6. The A/C Unit was also analyzed for causing a possible hazard release.  The plant personnel determined the following items would minimize the possibility of such an event from occurring: PM program, operator training,  and daily inspections. 
7. The failure of the refrigeration piping system would result in a hazardous release of ammonia.  Several preventative measures were examined during the PHA and are described as: equipment audits, replacement of damaged insulation, checking of vent sizes, operator training, audit of piping design, piping insulation audit, pipe chases, daily rounds, and extensive piping labeling. 
8. A PHA was performed for the refrigeration process valves.  Plant personnel listed the following action items for the hazard assessment pertaining to the process valves: operator training, change all valves to left-hand bonnet type, ensure proper 
installation of insulation, tagging of existing valves with screw type right-hand threads, place special ladders throughout the plant for valve access to be used during emergencies only, and installation of catwalks.
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