Kraft Foods. Inc. - Executive Summary |
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EXECUTIVE SUMMARY 1.0 Release Prevention and Emergency Response Policies The Kraft Foods facility at Campbell, New York has a very good record in preventing and minimizing releases of anhydrous* ammonia. This facility has a thorough emergency training program for on-site emergency responders. 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 Campbell Fire Department and First Responders, 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 Kraft manufactures Italian cheese (string cheese, ricotta, mozzarella, etc). at the Campbell, New York facility. The North American Industrial Classification System (NAICS) code for the primary process at this facility is 311513. Kraft has one regu lated substance under 40 CFR 68 at the Campbell, New York plant - ammonia. The chillers and storage 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 17,945 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 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 Campbell 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 our 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 key aspects of the prevention program: 1. Pro-active program in vibration analyses and infrared scanning. Most of the pipe work is located away from employee traffic patterns and machinery to minimize the chance of an ammonia release. 2. The plant maintains good training, certification and employee awareness of operating procedures. Drills are conducted with the on-site emergency response team and annual drills are held with the Campbell Fire Department and LEPC. 3. Utility personnel are present on site and assigned to the ammonia system, 24 hours a day, 7 days a week, all year round. 4. There is an ammonia detection system, which alerts the utility personnel and they are staffed continuously. 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. There have been no releases at this facility as defined in 40 CFR Part 68.42(a). 6.0 Emergency Response Program As mentioned earlier, this facility has developed an emergency response plan in which plant employees are divided into various management and response teams. This program will refer to and require the use of other Kraft Programs for its implementation (i.e. Evacuation Plan, Spill Control Plan, Medical Administration, etc.). There are 5 in-plant contacts for the report of an emergenc y. They 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. There are also specific procedures to follow in the event of a fire and ammonia emergency. During any incident, the Campbell Fire Department will be called automatically to provide back-up emergency responders and equipment. The Campbell 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. As mentioned earlier, this facility has developed an emergency response plan, including, but not limited to, steps to address the following topics: Measures to be taken to prevent an accident: 7 Our entire facility, including ammonia, is inspected daily by trained personnel 7 we have an extensive Process Safety Management Plan 7 continuous upgrades to our facility to maintain highest standards of quality & safety Acciden tal discharges of hazardous substances and/or waste into the environment: 7 many of our employees are specifically trained to deal with hazardous emergencies 7 employee drills are conducted to keep emergency response skills always improving 7 drills are conducted with local Steuben County Emergency teams 7 contingency plans are maintained on how to properly clean up and dispose of hazardous substances 7 a Risk Management Plan has been developed to keep the community as well as our own employees safe during an accidental discharge Our comprehensive emergency response plan is designed to protect our employees, environment and the community and, among other things, requires that: 7 All nonessential personnel exit the area affected by the release 7 Kraft will 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 not ify neighbors so that appropriate safety precautions could be taken. If ammonia is in the outside atmosphere, the safest place to be is indoors with the windows and doors shut and any ventilation systems turned off. 7.0 Planned Changes To Improve Safety 7 New controllers and alarming system were added to improve our ammonia system 7 Ventilation systems have been installed 7 An ice builder was replaced |