Kraft Foods, Inc., Garland - Executive Summary
1.0 Release Prevention and Emergency Response Policies |
The Kraft Foods facility in Garland, Texas 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, and a complete preventive maintenance program as part of a Computerized Maintenance Management System.
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 Garland 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 salad dressings and barbecue sauces. The NAICS code for the primary process at this facility is 311941(SIC Code 2035). This facility is capable of producing
and packaging salad dressings and barbecue sauces for consumer intake. The storage and process areas of the plant are refrigerated to preserve the products.
Kraft Foods has one regulated substance under 40 CFR 68 at this location: ammonia. Ammonia is used as a refrigerant in the refrigeration of the raw materials used in making salad dressings.
The ammonia threshold for triggering applicability to 40 CFR 68 is 10,000 pounds. The quantity of ammonia stored on-site is 26,700 pounds. Thus, 40 CFR 68 is applicable to Kraft Foods in Garland.
3.0 Worst-case and Alternative Release Scenarios
The ammonia refrigeration system has associated hazards that can potentially effect on-site employees and the general public off-site if there is a release. Although the alternative release scenario is more probable, the US EPA requires that one worst-case and one alternative release scenario be reported for each regulated chemical. Described below are the associated hazards and the worst-c
ase and alternative release scenarios for each regulated chemical.
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:
t-case scenario - The largest potential release of ammonia will occur with a puncture in the receiver located on the east side of the plant. Because of interconnecting pipe work and other vessels that can discharge into this pipe work, the amount of ammonia released will be greater than the amount stored in the receiver. The connected "other" vessels include the four condensers. The ammonia release in pounds is grouped in the following way:
1. Receiver = 8,700 pounds
2. Condensers #1 - #4 = 1,000 pounds
3. Interconnecting pipe work = 1,300 pounds
Total amount of ammonia that could be released = 11,000 pounds
Under Section 68.25(c)(1), a regulated toxic 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, ammonias physical state in the worst-case release is a gas. Passive mitigation controls were not applicable to the worst-case release at this plant.
The BREEZE HAZ DEGADIS+ air dispersion model was used to model the worst-case scenario at the Kraft facility in Garland. DEGADIS+, developed by the US Coast Guard, is an EPA approved model as identified in the RMP Offsite Consequence Analysis Document (May 24, 1996). It predicts contaminant movement for heavier-than-air gasses for instantaneous and continuous ground level releases. It was selected because of its applicability toward modeling of dense gasses (such as ammonia) and use for emergency response planning. DEGADIS+ was used to determine the distance from the facility to an end point chemical concentration of 200 ppm. The distance to the endpoint of 200 ppm was determined to be 0.81 miles.
The endpoint of 200 ppm for ammonia is based on the Emergency Response Planning Guideline, Level 2 (EPRG-2), d
eveloped by the American Industrial Hygiene Association. This level is the concentration to which an individual could be exposed to for up to one hour without suffering from irreversible or other serious health effects that could impair that individual's ability to leave the affected area.
The estimated affected residential population is 4,000 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 Scenario Description - The alternative release scenario is most likely to be caused by a gasket rupture or pump seal leak which would result from a 0.25" diameter orifice. The release rate of ammonia due to leakage through a failed seal or gasket is calculated to be 100 lb./min.
The BREEZE HAZ DEGADIS+ was used to model the alternative release scenario at the Kraft facility in Garland. DEGADIS+, developed by the US Coast Guard, is a
n EPA approved model as identified in the RMP Offsite Consequence Analysis Document (May 24, 1996). It predicts contaminant movement for heavier-than-air gasses for instantaneous and continuous ground level releases. It was selected because of its applicability toward modeling of dense gasses (such as ammonia) and use for emergency response planning. DEGADIS+ was used to determine the distance from the facility to an end point chemical concentration of 200 ppm. The distance to the endpoint of 200 ppm was determined to be 0.16 miles.
The endpoint of 200 ppm for ammonia is based on the Emergency Response Planning Guideline, Level 2 (EPRG-2), developed by the American Industrial Hygiene Association. This level is the concentration to which an individual could be exposed to for up to one hour without suffering from irreversible or other serious health effects that could impair that individual's ability to leave the affected area.
The estimated effected residential population is 40
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 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. Utility personnel are present on site and assigned to the ammonia system, 24 hrs a day, 7 days a week, all year round.
2. The plant maintains good training, certification, and employee awareness of operating procedures.
3. The plant has an aggressive PSM meeting schedule.
5.0 Five-year Accident History
The review of this facility's accident history includes the following range of dates: June 7, 1994 - June 8, 1999.
There was one accidental release of ammonia at the facility as defined by 40 CFR Part 68.42(a). This accident occurred on September 7, 1994 when there was a release of approximately 400 pounds of ammonia vapor due to loss of electric power to the controls. Emergency procedures involved adjusting cooler temperatures, re-seating the pressure relief valve, and restoring condenser power. The Garland Fire Department, US EPA, Texas Natural Resources Conservation Commission, and Local Emergency Planning Committee were notified.
6.0 Emergency Response Program
As mentioned earlier, this facility has developed an emergency response program in which plant employees are divided into various management and response teams. There are 25 in-plant contacts for an emergency which 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 fr
equency 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.
At the discretion of the Incident Commander, the Garland Fire Department will be called to provide back-up emergency responders and equipment. The Garland 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.
This facility has developed a combination emergency response plan which addresses:
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
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 person
This plan also incorporates the SPCC plan, by reference, which includes 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 the planning, training, response and countermeasures to be taken for location personnel who respond to spills and leaks anywhere on site.
The purpose of this document is to also establish procedures to notify appropriate agencies (like the LEPC and the Garland Fire Department) and company personnel in the event of an emergency.
7.0 Planned Changes to Improve Safety
Based on the what-if" PHA completed for ammonia a list of action items was developed and is being monitored to determine if implementation was accomplished. For example, in the ammonia system, if the control sump tank runs out of water then the system may fail and pressure will build, causing a release. The following action item was recommended: install a water level indicator in t
he sump tank and an alarm. The recommendation was followed and the control sump tank was updated on 10/11/95. Other examples of safety improvements as a result of the PHA program include:
1. Ammonia relief valves need to be raised. (Completed 9/97)
2. Need for safety re-training for forklift operators in hazards associated with compressors. (Re-trained 5/97)
3. Install bumper posts in front of accumulators. (Completed 1996)
4. Dual shut-off valve arrangement need to be replaced, H.P. Receiver. (Completed 1997)
5. New high pressure receiver needed. (Completed 1997)
There are numerous other examples of safety improvements as a result of the PHA.