Kraft Foods, Inc. - Executive Summary

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(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). 
1.0    Release Prevention and Emergency Response Policies 
The Kraft Foods facility in Walton, New York has an excellent record in preventing and minimizing releases of anhydrous* ammonia. This facility has implemented an electronic preventive maintenance system  This system uses a real time database to track purchase orders, inventory control, work orders, and the Preventative Maintenence program. 
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 Walton Fire Department, the LEPC, and EMS in the event of an e 
*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 cottage cheese, sour cream and flavored dips (dairy products).  The NAICS code for the  primary process at this facility is 311513.  This facility is capable of producing and packaging various cultured products for consumer intake.  Many of the areas of the plant are refrigerated to preserve the dairy products.  Some of these areas include: receiving, processing, packaging and storage areas. 
Kraft Foods has one regulated substance under 40 CFR 68: i.e., ammonia, at this location.  Ammonia is used as a refrigerant in the refrigeration of the various dairy products in the 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 17,818 pounds. 
Ammonia is classified as a Group 2 Refrigeran 
t per ASHRAE Standard 34-1989.  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 potential risks to people 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    Release Scenarios 
Although there are quality and safety systems in place at Kraft's Walton plant, a release from the ammonia refrigeration system could potentially affect employees on-site and the general public offsite.  USEPA requires companies t 
o use models for "worst-case" and "alternative" 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 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 which is identical to the OSHA PSM pr 
ogram.  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 equipment at ground level is guarded against impact 
2.    Critical ammonia equipment is installed above the 100 year flood level 
3.    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. 
4.    The plant  maintains good training, certification and employee awareness of operating procedures). 
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 at this facility. 
6.0    Emergency Response Program 
As mentioned earlier, this facility has developed an emergency response pro 
gram which includes an assisted emergency response plan  for hazardous substance releases.  This combination emergency response plan deals with: 
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, and; 
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 personnel 
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 appro 
priate agencies (like the LEPC and the Walton 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, there was a potential for people to step on small sized nipples on ammonia compressors and other equipment.  The following action item was recommended: Awareness and training was implemented in October 1996.  There are numerous other examples of safety improvements as a result of the PHA results.  These include: 
1.    Observation of a liquid line crossing a pathway in the warehouse that can be     reached by a palette load on a forklift was encapsulated in an I-beam     (accomplished June 1997). 
2.    It was observed that pipes on the roof were not properly labeled.  A program was     put into place and implemented to address this concern (October 1996).
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