Kraft Foods, Inc. - Executive Summary

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(Executive Summary and Data Elements) 
1.0    Release Prevention and Emergency Response Policies 
The Kraft Foods facility in Coshocton, Ohio has a very good record in preventing and minimizing releases of anhydrous* ammonia.  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 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, such as with the Coshocton Fire Department and the Coshocton County Emergency Services and Disaster Agency (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 R 
egulated Substances 
At this location Kraft Foods manufactures meat products.  The NAICS code for the primary process at this facility is (311612).  This facility processes and packages bacon and bacon pieces for consumer intake but is not equipped to slaughter hogs.  Many areas of the plant are refrigerated to store raw materials and finished products.  Some of these areas include: receiving, product staging, belly processing, brine mixing, curing rooms, curing over-flow and other storage areas.  The plant produces smoked bacon in smokehouses located on-site.  
Kraft Foods has one regulated substance, ammonia, under 40 CFR 68. Ammonia is used as a cooling agent in the refrigeration of the meat products in the various areas described above. 
The ammonia threshold for triggering applicability to 40 CFR 68 is 10,000 pounds. The quantity of ammonia stored on-site is approximately 30,000 pounds. Thus, 40 CFR 68 is  applicable to the Coshocton facility. 
3.0    Release Scenarios 
Although the 
re are quality and safety systems in place at Krafts Coshocton plant,  a release from ammonia refrigeration system could potentially affect employees on-site and the general public offsite.  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 alternate scenario would be more likely.  
The ammonia release scenario was modeled using SLAB ( June 1990 versions) 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 serious health effects that could make it difficult for them to leave the affected area.  
4.0    General Accidental Release Prevention Program and Chem 
ical-Specific Prevention Steps 
This facility is regulated under PSM.  The 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.    The majority of the ammonia process pipe work is located in low traffic areas.  This allows for less human interaction with the process and results in a lower probability of an ammonia release.  
2.    The plant maintains good training, certification and employee awareness of operating procedures. 
3.    The ammonia system is monitored through a PLC.   
4.    Ammonia detectors are installed in the main housing unit of the ammonia storage vessels, the engine room. 
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 have been no accidental releases of ammonia at the Coshocton facility. 
6.0    Emergency Response Program  
As mentioned earlier, in Section 1.0, the Coshocton 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 Coshocton Plant. The plans were also written to identify to the plant employees what precautions and steps should 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 docum 
The emergency communications document is written to establish procedures to notify appropriate agencies (like the Coshocton Fire Department) and the three company trained emergency response team members in the event of an emergency. Company response team members can be notified by the use of a pager or phone.  The Coshocton plant has three employees who are trained as emergency responders.  The Coshocton Fire Department shall be notified by the security  personnel 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 site consequences and affected area, including receptors). 
7.0    Planned Changes to Improve Safety  
Based on the "w 
hat 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 list contains examples of the PHA conducted for ammonia at the Coshocton Plant. 
1. A concern for the Coshocton Plant personnel was the possibility of process piping failure due to corrosion.  The preventative measures developed to combat this scenario are: inspection of process piping, replacement of corroded parts, repaint flaky painted surfaces, install PM for yearly inspection. 
2. A PHA was performed for the ammonia compressor.  The scenario for the PHA consisted of the compressor malfunctioning which causes a loss of oil pressure.  The PHA team developed the following preventative measures: yearly inspection of switches, daily inspections of pressure readings, and re-evaluate present settings and modify if necessary. 
3. Several PHA were concerned with the possibility of th 
e wrong valve being opened or closed during maintenance procedures.  The PHA team recognized that the following provisions should be made to ensure a safe working environment: create written maintenance procedures, provide training for personnel involved in maintenance of the ammonia system, label valves to be closed, certification of supervisor responsible for closing/opening valves. 
4. A concern for the Coshocton PHA team were concerned with the possibility of a reportable release and the number of internally trained employees available to respond.  In order to ensure the health and safety of their employees the facility performs a yearly mock exercise. A mock exercise was held with the local HAZMAT team and fire department 1998.
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