Kraft Pizza Company - Executive Summary

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1.0 Release Prevention and Emergency Response Policies 
The Kraft Foods facility in Sussex, 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 hour per day - 7 days per week.  There are also adequate provisions for coordination with outside agencies, such as with the Sussex Fire Department, in the event of an emergency. 
2.0 Process Description and Regulated Substances 
Kraft manufactures frozen pizzas at the Sussex, Wisconsin plant.  The North American Industrial Classification System (NAICS) code for the primary process at this facility is 311412.   Kraft  
has one regulated substance under 40 CFR 68 at the, Sussex, Wisconsin plant  ammonia.  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 65,000 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 Worst-case and Alternative Release Scenarios 
Although there are quality and safety systems in place at Kraft's Sussex 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, 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 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 program requirement. 
There are several key aspects of the prevention program: 
(a). The majority of the ammonia piping systems are installed in an attic area or on the roof of the plant. 
(b). The plant maintains good training, certification and employee awareness of operating procedures via the emergency response team and conducts periodic drills with the Sussex, Wisconsin 
fire department and the Waukesha LEPC. 
5.0 Five-year Accident History 
The review of this facility's accident history includes the following range of dates: June 10, 1994 - June 10, 1999.  To date, there have been no releases at this facility as defined in 40CFR Part 68.42(a). 
6.0 Emergency Response Program 
As mentioned earlier, this facility has developed an emergency response plan, including, but not limited to, steps to address the following topics: 
(a). accidental discharge of hazardous substances and hazardous waste into the environment 
(b). the measures to be taken to prevent an accident 
(c). countermeasures to be taken in the event of an emergency, and; 
(d). 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 thi 
ngs, requires that: 
(a). All nonessential personnel immediately exit the area affected by the release; 
(b). 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 precautions 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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