Kraft Foods, Inc. - Executive Summary

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1.0 Release Prevention and Emergency Response Policies 
The Kraft Foods facility in Madison, Wisconsin, 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 procedures at this facility ensure emergency response coverage 24 hours a day, seven days a week.  There are also adequate provisions for coordination with outside agencies, such as with the City of Madison Fire Department and Dane County Local Emergency Planning Committee (LEPC), in the event of an emergency. 
2.0 Process Description and Regulated Substances 
At this location Kraft Foods processes meats.  The North American Industrial Classification System (NAICS) code for the prim 
ary process at this facility is 311612.  This facility is capable of producing and packaging various meat products including hot dogs, bologna, cold cuts, etc. for consumer intake but the plant is not equipped to slaughter animals.  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  239,255 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 concentrat 
ions, can cause  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 Worst Case and Alternative Release Scenarios 
Although there are quality and safety systems in place at Kraft's Madison plant, a release from the 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 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, w 
as 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 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 aspects of the prevention program that are key: 
1. Personnel assigned to the ammonia system are on site 24 hours a day, seven days a week. 
2. Major pieces of refrigeration equipment have automatic det 
ection, alarm, and shut down controls. 
3. The emergency response cart is on the third floor along with the training suits and all the HAZMAT equipment needed to isolate a leak (if one were to happen). 
4. Most of the pipe work is out of the way of people and the machinery (on the ceiling), and so there is less of a chance of an ammonia release. 
5. The plant maintains good training, certification and employee awareness programs. 
5.0 Five-year Accident History 
The review of this facility's accident history includes the following range of dates: June 11, 1994 - June 11, 1999.  According to 40 CFR Part 68.42(a), there have been no accidental releases at this facility. 
6.0 Emergency Response Program 
This facility has 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.   The three above mentioned documents, combined, form a very comprehensiv 
e and thorough Emergency Response Program document for the Madison plant.  It includes, but is not limited to, steps to address the following topics: 
accidental discharge of hazardous substances and hazardous waste into the environment 
the measures to be taken to prevent an accident 
countermeasures to be taken in the event of an emergency, and; 
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 
Our comprehensive emergency response plan is designed to protect our employees, environment and the community and, among other things, requires that: 
All nonessential personnel immediately exit the area affected by the release; 
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 precaut 
ions 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.
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