Kraft Foods, Inc. - Executive Summary

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1.0    Release Prevention and Emergency Response Policies 
The Kraft Foods facility in Columbia, Missouri, 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 - 7 days per week.  There are also adequate provisions for coordination with outside agencies, such as with the Columbia Fire Department in the event of an emergency. 
2.0    Process Description and Regulated Substances 
At this location Kraft Foods processes meat products. The North American Industry Classification System (NAICS) code for the primary process at this facility is (2013).  This facility is capable  
of producing and packaging various meat products including hot dogs, beef franks, and turkey franks for consumer intake.  The plant is not equipped to slaughter hogs; boxed trimmings are shipped to the plant.  Many areas of the plant are refrigerated to preserve the meat products.  Some of these areas include: receiving, raw material cooler, pre-blend, preparation/stuffing, stripping, packaging, palletizing, finished product coolers, and other storage areas.  The plant produces smoked hot dogs in smokehouses located on-site. 
The ammonia threshold for triggering applicability to 40 CFR 68 is 10,000 pounds. The quantity of ammonia stored on-site is 48,000 lbs. 
   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 tiss 
ue.  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 Krafts Columbia 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 the 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 distanc 
e 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 its  ammonia refrigeration system. 
There are several key aspects of the prevention program: 
1.    Utility personnel are present on site and assigned to the ammonia system, 24 hours a day, 7 days a week, all year round. 
2.    In remote areas there is a ammonia detection system which alerts the utility personnel of the trouble area and starts automatic ventilation. 
3.    Most of the ammonia pipe work is located away from employee traffic patterns and machinery to minimize the c 
hance of an ammonia release. 
4.    The plant maintains good training, certification and employee awareness of operating procedures (monthly drills with the emergency response team and an annual drill with the Columbia Fire Department. 
5.    A preventive maintenance program is in place and mechanical integreity inspections have been done on they system. 
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 this facility. 
6.0    Emergency Response Program 
As mentioned earlier, this facility has developed an emergency response program in which plant employees are divided into various management and response teams. The Emergency Response Plan contains a list of employees who should be contacted in the event of an emergency.  There are also back-up personnel in the event that the primary incident response personnel cannot  
be contacted.  The emergency response plan includes information about the frequency of employee emergency response training as well as a detailed description of the training content.   There are also specific procedures to follow in the event of a fire and ammonia emergency.   
At the discretion of the Incident Commander, the Columbia Fire Department will be called to provide back-up emergency responders and equipment.   The Columbia Fire Department will be called for all fire related emergencies.  In all cases where an ambulance is notified of an emergency the fire department will be notified via the Joint Communication Center. 
As mentioned earlier, this facility has developed an emergency response plan, including, but 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 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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