Kraft Foods Inc. - Executive Summary |
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RISK MANAGEMENT PLAN (Executive Summary and Data Elements) KRAFT FOODS, INC. Springfield, Missouri REVIEWED: _______________ CORRESPONDING REVISION: _______________ (if necessary) ________________ _______________ ________________ _______________ ________________ _______________ ________________ TABLE OF CONTENTS EXECUTIVE SUMMARY 1.0 Release Prevention and Emergency Response Policies 2.0 Process Description and Regulated Substances 3.0 Worst-Case and Alternative Release Scenarios 4.0 General Accidental Release Prevention Program and Chemical-Specific Prevention Steps 5.0 Five-year Accident History 6.0 Emergency Response Program 7.0 Planned Changes to Improve Safety DATA ELEMENTS 1. Registration 2. Accompanying Spreadsheet CERTIFICATION STATEMENT To the best of my knowledge, information and belief formed after reasonable inquiry, the information submitted in this document is true, accurate and complete . __________________________ _____________ Plant Manager Date KRAFT FOODS, Springfield, MO RISK MANAGEMENT PROGRAM (Executive Summary and Data Elements) This document and the accompanying spreadsheet contain 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). EXECUTIVE SUMMARY 1.0 Release Prevention and Emergency Response Policies The Kraft Foods facility in Springfield, Missouri 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. This facility has implemented the SAP electronic preventive maintenance system that uses a real time database 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 pe r week. There are also adequate provisions for coordination with outside agencies, such as with the Springfield 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 and processes dairy products. The SIC code for the primary process at this facility is 2023. This facility is capable of producing various dairy products including cheese for consumer intake. Many areas of the plant are refrigerated to preserve the dairy products. Some of these areas include coolers, chillers, storage tanks and some processes. The plant also produces some pasta products. Kraft Foods has one regulated substance under 40 CFR 68, anhydrous ammonia, at this location. Ammonia is used as a cooling agent for the refrigeration of the food products in the various areas described above. The ammonia threshold for triggeri ng applicability to 40 CFR 68 is 10,000 pounds. The quantity of ammonia stored on-site is approximately 115,300 pounds. Thus, 40 CFR 68 is applicable to Kraft Foods in Springfield, MO. 3.0 Worst-case and Alternative Release Scenarios The ammonia refrigeration system has associated hazards that can potentially affect on-site employees and the general public if there is a release from the system. Although the alternative release scenario is more likely, the US EPA requires 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 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 human 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 high pressure receiver located on the northwestern portion of the outside of the plant. The release would occur during system pumpout. Ammonia from the high pressure receiver during pumpout will release a total of 17,725 pounds of ammonia wit hout any administrative controls. It is assumed that all 17,725 pounds is released to the atmosphere in 10 minutes. Under Section 68.25(c)(1), a regulated 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, ammonia's physical state in the worst-case release is a gas. The ammonia worst case scenario was modeled using SLAB (June 1990 version) to obtain the distance to endpoint. The endpoint is defined by the US EPA as the Emergency Response Planning Guideline, Level - 2 (ERPG-2) which was calculated to be 0.53 miles. The ERPG-2 was developed by the American Industrial Hygiene Association and is applicable to human exposures for up to one hour. The ERPG-2 is intended to protect individuals from health threatening or escape impairing injury and is not generally considered fatal. SLAB is a computer model developed (1983) by Lawrence Liver more 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 surface roughness) were used during modeling runs for the Springfield facility in accordance with Appendix W to Part 51- Guidelines on Air Quality Models Section 8.2.8. The estimated affected residential population is 2,690 people. The types of affected receptors are listed in the Data Elements section. Alternative Release Scenario - The worst-case release is less likely to occur than the following scenario: Alternative Release Scena rio Description The alternative release scenario that meets both selection criteria is an ammonia release from the PRV on the high pressure receiver, which is, located approximately 200 ft from the fenceline. The actuation of the PRV will produce a horizontal jet release. There are no applicable administrative controls or passive mitigation associated with the PRVs. Active mitigation is defined as human intervention. It is assumed that the PRV will be deactivated by human intervention 10 minutes after the start of the release. Our calculations showed that the ammonia vapor release rate is 66.9 lb./min. The US EPA Risk Management Program and Plan for Ammonia Refrigeration Table A-1 was used to determine the distance to the ERPG-2 endpoint. Data from the urban column of the table was interpolated to determine the ERPG-2 endpoint. The ammonia vapor cloud will be above 200 ppm on the ground level at a distance of 0.076 miles. The estimated affected residential populat ion is 47 people. 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 stated that if the process is in compliance with OSHA PSM, 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 Utility Service Area design (USA) serves as an excellent safeguard for plant personnel because it greatly reduces the amount of ammonia piping inside occupied rooms. Since most of the pipe work is out of the way of people and the machinery and so there is less of a chance of an ammonia release. 2. The plant maintains good training, certification and employee awareness of operating procedures. 3. An e lectronic control monitoring system is in place for monitoring the entire engine room process. 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. There have been no releases at this facility as defined in 40 CFR Part 68.42(a). 6.0 Emergency Response Program As mentioned earlier, this facility has developed an emergency response in which plant employees are divided into various management and response teams. There are eight in- plant contacts for an emergency, a list of these contacts 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 a fire and ammonia emergency. Response team members participate in a mock ammonia spill cleanup two times a year. All trained ER team members have pagers that can be actuated. At the discretion of the Incident Commander, the Springfield Fire Department will be called to provide emergency responders and equipment. The Springfield Fire Department will also be called for all fire related emergencies. In all cases where an ambulance is called, the fire department is also called to the scene. 7.0 Planned Changes to Improve Safety - Based on the PHA completed for ammonia, a list of action items was developed and is being monitored to determine if implementation was accomplished. The "What-If" method is used for each component of the ammonia system. There are numerous examples of safety improvements as a result of the PSA results. These improvements include: 1. During the ammonia PHA, it was revealed that a 5 year PRV replacement program needed to be instituted to ensure their safe operation. Each section of the ammonia system has since had a 5 year PRV program implemented as of April, 1997. 2. The ammonia PHA revealed that a PM program needed to be established for the inspection and repair of ammonia condenser fans to protect the fans from damage due to a imbalance. A PM program was subsequently implemented November, 1997. 2 March 9, 1999 March 9, 1999 March 9, 1999 7 |