Kraft Foods, Inc. - Executive Summary

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1.0 Release Prevention and Emergency Response Policies 
The Kraft Foods facility in Beaver Dam, Wisconsin has an excellent record in preventing and minimizing releases of anhydrous* ammonia. The facility has implemented an electronic preventive maintenance system.  One of the features of this system is that it uses a real time database to track training and inspection dates and issue reminders to responsible groups. 
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 Beaver Dam Fire Department, 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 Foods manufactures cream cheese and premium dips at the Beaver Dam facility.  The North American Industry Classification System ( 
NAICS) code for the primary process at this facility is (311513).   
Kraft Foods has one regulated substance under 40 CFR 68 at the Beaver Dam 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 decates. 
The ammonia threshold for triggering applicability to 40 CFR 68 is 10,000 pounds. The quantity of ammonia stored on-site is approximately 31,720 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 acciden 
tal 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 Beaver Dam 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 is regulated under PSM and 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: 
(a) All relief valves and the majority of piping are located on the roof of the facility.  This allows for most of the pipe work to remain out of the way of people and machinery, thereby decreasin 
g the chance for an ammonia release.   
(b) The plant maintains good training, certification and employee awareness of operating procedures. 
(c) The entire ammonia system is currently being upgraded and isolated in an area that contains state of the art warning and control devices.  
(d) Process equipment are protected by concrete guards. 
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 the Beaver Dam facility.  
6.0 Emergency Response Program  
The Beaver Dam facility developed an emergency response plan in which plant employees are divided into various management and response teams. The emergency response plan is made up of several different components.  The two main objectives of the plan is to ensure that the facility operations are in compliance with OSHA and to avoid pollution of the environment.  The plan 
describes operating procedures during natural and plant emergencies.  Natural emergencies include tornado and thunder storms while plant emergencies include fire and a chemical release.  The plan includes a list of phone numbers for each plant specific emergency.  Plant contacts with their corresponding phone numbers and pager numbers are listed.  The emergency response plan contains an on-site contingency plan.  The on-site contingency plan was submitted to the Dodge County Board of Supervisors, and the Local Emergency Planning Committee, for review.  The on-site contingency plan contains information about the frequency of employee personnel response training, training requirements, spill prevention techniques, an evacuation plan for the general public, MSDS sheets for ammonia, confined space entry procedures, to name a few.  
During any incident, the Beaver Dam Fire Department will be called automatically to provide back-up emergency responders and equipment.  The Beaver Dam Fire De 
partment will be called for all fire-related emergencies.
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