Kraft Foods, Inc. - Executive Summary |
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EXECUTIVE SUMMARY 1.0 Release Prevention and Emergency Response Policies The Kraft Foods facility in Farmdale, Ohio has an excellent record in preventing and minimizing releases of anhydrous* ammonia. This facility utilizes outside assistance from the local fire department and Trumbull County HAZMAT in the event of a hazardous release. Preventive maintenance is performed to maintain the proper operation of the refrigeration system. The emergency response procedures at this facility ensure emergency response coverage 24 hours - 6 days per week. There are also adequate provisions for coordination with outside agencies, such as with the Kinsman 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 At this location Kraft Foods manufactures cultured dairy products. The North American Industry Classification System (NAICS) code for th e primary process at this facility is (311513). Kraft has one regulated substance under 40 CFR 68 at the Farmdale, Ohio plant - Ammonia. Several areas of the plant are refrigerated by ammonia to keep 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 10,650 pounds. Thus, 40 CFR 68 is applicable to the Farmdale facility. Ammonia is classified as a Group 2 Refrigerant per ASHRAE Standard 34-1989. The 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 risk to people e xposed 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 Kraft?s Farmdale plant, a release from the ammonia refrigeration system could potentially affect employees on-site and the general public offsite. US EPA 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 le vel 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 our 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, Kraft?s 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 process piping is located on the roof of the facility. This allows for most of the pipe work to remain out of the way of people and machinery, reducing the chance for an ammo nia release. 2. The plant maintains good training, certification and employee awareness of operating procedures. 3. A new engine room detection and ventilation system was installed in 1998. 4. Nearly 67% of all the equipment and piping, located outside the building, has been replaced in the last 10 years. 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 release at the Farmdale facility. 6.0 Emergency Response Program As mentioned earlier, in Section 1.0, the Farmdale Plant has developed an emergency response program. The emergency response program is comprised of three elements: emergency communications, emergency evacuation procedures and an off-site plan. Separate documents, or plans, were produced to define the policies and procedures of the Farmdale Plant. The plans were also written to identify to the plant employees the precautions and steps to be taken in the event of the release of a hazardous substance. The combination of the three documents yields a comprehensive Emergency Response Program document. The following paragraphs discuss briefly the contents of each of the three specified documents. The emergency communications document is written to establish procedures to notify appropriate agencies (like the Kinsman Fire Department) The Kinsman Fire Department will be notified by the employee with the authority and responsibility, as per the established hierarchy in the ER program, via 911. The emergency evacuation procedures document is designed to provide an orderly, effective plan of action for protecting employees in emergency situations when an evacuation is necessary. The off-site plan was written to identify the hazardous chemicals on-site (and the quantities), the primary emergency responders site diagrams, support available at/from the facility and a hazard analysis (off-si te consequences and affected area, including receptors). 7.0 Planned Changes to Improve Safety Based on the "what-if/checklist" Process Hazard Analysis (PHA) completed for ammonia, a list of action items were developed and are being monitored and revised to determine if implementation was accomplished. The following paragraph contains examples of the PHA conducted for ammonia at the Farmdale Plant. Below is a list of implemented changes that has help improve the safety of our ammonia system: 1. An evaportive condensor was aquired and used to replace an older evaporative condensor that was located at ground level in the parking area. The replacement was installed on the roof. (1999) 2. The engine room continuous ventilation, detection and emergency ventilation system was installed replacing the old ventilation/detection system. (1998) 3. 67% of the refrigeration piping on the roof was replaced. (1997-98) 4. A Pump-out was upgraded. (1997) 5. E/A/07 liquid accumulation tank w as replaced (1997) 6. A new suction accumulator and transfer system was installed (1996) 7. An ammonia receiver was installed (1995) |