Kraft Foods, Inc - Executive Summary |
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EXECUTIVE SUMMARY: 1.0 Release Prevention and Emergency Response Policies The Kraft Foods facility in Melrose, Minnesota 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 database to track preventive maintenance, 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/emergency response companies including the Melrose Fire Department, Earth Tech, Cura, and Stearns County Emergency Service in the event of an emergency. 2.0 Process Description and Regulated Substances Kraft manufactures bulk cheese and whey at the Melrose, Minnesota plant. The North American Industrial Cl assification System (NAICS) code for the primary process at this facility is 311513. Kraft has one regulated substance under 40 CFR 68 at the Melrose, Minnesota 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 29,460 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 peopl e 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 Worst-case and Alternative Release Scenarios Although there are quality and safety systems in place at Kraft's Melrose 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 has developed an OSHA PSM program for their ammonia refrigeration system. Ammonia falls under the RMP Program 3 prevention program 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 key aspects of the prevention program: (a). Utility personnel are present on site and assigned to the ammonia system, 24 hours a day, 7 days a week, all year round. (b). Most of the ammonia pipe work is located away from employee traffic patterns and mac hinery to minimize the chance of an ammonia release. (c). The plant maintains good training, certification and employee awareness of operating procedures, periodic drills with the emergency response team and an annual drill with the city fire department. (d). About 50% of the entire ammonia system has been replaced within the last 36 months to further improve the safety and efficiency of the plant. (e). Computer process control system for the compressor equipment. This system conserves energy to optimize refrigeration. (f). The plant maintains good training, certification and employee awareness of operating procedures). (g). The plant has installed an emergency shutdown system. 5.0 Five-year Accident History The review of this facility's accident history includes the following range of dates: June 10, 1994 - June 10, 1999. To date, there have been no accidental spills or releases of ammonia at the facility. 6.0 Emergency Response Program As mentioned earlier, this facility ha s developed an emergency response program in which emergency communications, emergency evacuation procedures and an off-site plan in the event of a hazardous substance release are addressed in detail. There is a HAZMAT team at the plant. The purpose of the emergency communications document is to establish procedures to notify appropriate agencies, Melrose Fire Department, Earth Tech, Stearns County Emergency Service, and company personnel in the event of an emergency. The purpose of the emergency evacuation procedures document is to provide an orderly, effective plan of action for protecting employees in emergency situations when an evacuation is necessary The facilities' SPCC plan identifies the hazardous chemicals on-site (and the quantities), the HAZMAT team members, site drawings, support available at/from the facility, support from outside the facility, as well as a hazard analysis (off-site consequences and affected area, including receptors). The plan provides response and handling procedures for all hazardous chemicals on-site. The aforementioned documents, combined, form a very comprehensive and thorough Emergency Response Program designed to protect our employees, environment and the community and, among other things, requires that: (a) All nonessential personnel immediately exit the area affected by the release; (b) 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 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 and the ventilation system turned off. |