Kraft Foods, Inc./Oscar Mayer Foods - Executive Summary |
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EXECUTIVE SUMMARY 1.0 Release Prevention and Emergency Response Policies The Kraft Foods facility in Davenport, IA has an excellent record in preventing and minimizing releases of anhydrous* ammonia. The Davenport Plant has implemented an electronic preventive maintenance system that uses weekly batched data to track training and inspection dates and issues reminders to responsible groups. The emergency response policies at this facility ensure that there is emergency response coverage for the plant during the continual 24 hrs and 7 day plant operations. The Davenport Fire Department is contacted in the event of an emergency and is trained in paramedical services. The Davenport Facility also has a thorough emergency training program for on-site emergency responders. Selected employees have completed 24 hours of formal emergency response training. These employees are considered Hazardous Material Technicians. *From this point in the Executive Summary, anhydrous ammonia will be synonymous with ammonia. 2.0 Process Description and Regulated Substances The Kraft Foods Davenport, IA plant manufactures or produces meat products. The NAICS code for the primary process at this facility is 311612. This facility is capable of producing and packaging various Bologna, ham, turkey, chicken, and pork products for consumer intake. Many areas of the plant are equipped with refrigeration systems to preserve the meat products. Some of these areas include: coolers, and chill cells. Kraft Foods has one regulated substance, ammonia, under 40 CFR 68 at the Davenport Plant. Ammonia is used as a refrigerant in the plants cooling systems. The total ammonia charge, at the Davenport Plant, is approximately 100,000 pounds. Thus, 40 CFR 68 is applicable to Kraft Foods in Davenport. 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 off-site public i f there is a release from the ammonia system. Although the alternative release scenario is more likely, 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-case and alternative release scenarios for each regulated chemical. Ammonia 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 rele ase 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: Worst-case scenario - The largest potential release of ammonia will occur with a one inch diameter puncture in the liquid portion of the high pressure receiver located outside on the eastern side of the plant 182 feet from the fence line. Taking the specific definition of the worst-case from 40 CFR 68.25, the largest quantity of ammonia that can be stored in a vessel is in the high pressure receiver during pump-out operations. The total quantity of ammonia that can be stored in the high pressure receivers is 29,824 pounds without administrative controls. It is assumed that all 29,824 pounds is released to the atmosphere in 10 minutes. Under Section 68.25(c)(1), a regulated substance such as ammonia, which i s 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. The ammonia worst case scenario was modeled using SLAB (June 1990 version) to obtain the distance to endpoint. The endpoint is defined by the US EPA as the Emergency Response Planning Guideline, Level 2 (ERPG-2) which was calculated to be 1.03 miles. The ERPG-2 was developed by the American Industrial Hygiene Association and is applicable to human exposures for up to one hour. The ERPG-2 is intended to protect individuals from health threatening or escape impairing injury and is not generally considered fatal. SLAB is a computer model developed (1983) by Lawrence Livermore Laboratories and sponsored by the Department of Energy (DOE) and EPA. SLAB is a dense gas model (also models neutrally-buoyant and includes lofting of a cloud if it becomes lighter than air) fo r various types of releases including a ground-level evaporating pool, an elevated vertical and horizontal jet, and an instantaneous volume source. The model solves the conservation equations of mass, momentum, energy, and species. It can simulate continuous, finite duration, and instantaneous releases. Urban dispersion coefficients (0.9 m surface roughness) were used during modeling runs for the Davenport facility in accordance with Appendix W to Part 51- Guidelines on Air Quality Models Section 8.2.8. The estimated affected residential population within the ERPG-2 endpoint is 11,812 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 that meets both selection criteria is an ammonia release from a dual pressure relief valve (PRV) on the high pressure receiver whi ch is located outside on the eastern side of the plant. This produces a horizontal jet release. There is no applicable administrative controls or passive mitigation. Our calculations showed that the ammonia vapor release rate is 85.32 lb/min. The US EPA Risk Management Program and Plan for Ammonia Refrigeration Table A-1 was used to determine the distance to endpoint. The ammonia vapor cloud will be above 200 ppm on the ground at approximately 0.08 miles. estimated affected residential population is 42 people. A surface roughness coefficient of 0.9 m was used as well as a wind speed of 3 m/s and an atmospheric stability class of D. 4.0 General Accidental Release Prevention Program and Chemical-Specific Prevention Steps The Davenport Plant has established an OSHA PSM Program for the 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 PS M, 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 Utility Service Area (USA) was constructed to house the majority of the most recently installed refrigeration process piping. The USA protects the plant personnel from exposure from a release and reduces the probability of a release as a result of plant personnel and heavy machinery. 2. The Davenport Plant maintains good training, certification and employee awareness of operating procedures. 3. Additional guarding for the ammonia pipelines, located within the facility, has been installed. The guarding consists of concrete retaining curbing to prevent access to piping by machinery. 4. The Davenport, IA plant currently uses an electronic database (MUSCLE) to compile process management tasks every week. The database list contains the completed, activated, and on-g oing tasks at the plant. Each task contains a job description with instructions and parts required to perform the specified maintenance procedures. The electronic database updates the maintenance procedures on a weekly basis if necessary. This prevents confusion for the mechanics and maintenance personnel which results in a greater awareness of the ammonia process which in turn causes a decrease in the amount of accidents. 5. The electronic database, described earlier, also monitors and tracks contractors performance and safety records. This allows plant personnel to identify potential concerns with contractors awareness and knowledge of the ammonia process. 5.0 Five-year Accident History The review of this facility's accident history includes the following range of dates: June 7, 1994 - June 7, 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, in Section 1.0, the Davenport Plant ha s developed an emergency response program. The emergency response program is comprised of three elements: (1) emergency communications, (2) emergency evacuation procedures and (3) an off-site plan. Separate documents, or plans, were produced to define the policies and procedures of the Davenport 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 documents. The emergency communications document is written to establish procedures to notify appropriate agencies (like the Davenport Fire Department) and the 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. The Davenport Fire Department sha ll 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 PHA completed for ammonia, a list of action items was developed and is being monitored to determine if implementation was accomplished. The following examples briefly describe current improved safety measures occurring at the Davenport, IA plant in response to the PHA. 1. Twenty-seven concrete curbs have been installed to protect ammonia process lines from damage caused by human operator error while operating heavy equipment. (6/97) 2. Addition of a plant wide sprinkler system. (12/99) 3. Increased training for ammonia awareness and other safety measures. Training schedule has increased to one class per month on a plant wide basis. Over 3000 hours are spent annually on training of employees on plant safety hazards. |