Kellogg USA - San Jose - Executive Summary

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The Kellogg Company manufactures a variety of waffles at our facility in San Jose.  We have produced waffles in San Jose since 1962.  We have a strong commitment to operate our facility in a safe and responsible manner. 
Ammonia is used at our facility as the cooling medium in our refrigeration systems.  Similar to the function Freon plays in a home or car air conditioning system, ammonia is used to cool the air in our industrial freezers and product coolers.  The ammonia is contained in a closed loop system; it is designed to remain inside the piping and vessels in our facility.  We believe that ammonia provides the safest and most efficient cooling choice for our operation. 
A. Describe the Accident Release Prevention and Emergency Policies 
Kellogg's takes many precautions to prevent or minimize accidental releases of ammonia from the refrigeration systems.   Any release from the ammonia system is detected by sensors, which automatically start a ventilation system.  The ventilation 
system routes the air into a scrubber, which removes ammonia before exhausting the air into the environment.  Other precautions include safety controls (alarms and automatic shutdown devices) which are designed to identify and prevent potentially unsafe conditions like pressure increases that could cause a system failure.  We also have a preventive maintenance program designed to maintain the on-going integrity of the system, a training program designed to ensure that the system is operated by qualified personnel, and emergency response procedures that enable trained personnel to respond quickly to system upsets. 
The Engineering Manager is responsible for the management of these ammonia safety programs. 
B.   Stationary Source and Regulated Substances Handled 
Kellogg's San Jose produces frozen waffles for sale to the public.    The ammonia inventory for the refrigeration system is approximately 38,000 pounds.   Ammonia is the only substance covered by the Accidental Release Prevent 
ion Regulations handled at the San Jose Plant. 
C.   Summary of Worst-Case and Alternative Release Scenarios 
EPA requires us to define the worst case release scenario from the San Jose plant as the release of 12,400 pounds of ammonia aver a 10-minute period due to the failure of the high pressure receiver.  The 12,400 pounds represents the maximum amount of ammonia that would be contained in the receiver at any time.  We have a written procedure to assure that this is so.  This receiver is located inside a building with a dike underneath it to provide additional containment.  These factors reduced the impact of a release from this vessel.  The EPA also requires us to assume that the weather conditions are such that there is almost no wind and no mixing in the atmosphere.   
The alternative release scenario at the San Jose plant would involve the release of 12,500 pounds of ammonia over a 10-minute period due to product carried by a forklift hitting an overhead ammonia line.  The dura 
tion of the release was estimated by determining the amount of time needed to isolate that section of the ammonia system with our zone isolation equipment.   Also, the release would take place inside a building, which would also reduce the impact of a release in this situation.  Again, EPA required us to estimate the impacts of this release under low wind and stable weather conditions.  
Both of these releases are unlikely for many reasons. Our equipment and system were designed using industry standards for ammonia refrigeration.   We have a scrubber system, designed to remove the ammonia from the air before it is exhausted into the environment.   We have taken precautions to protect our equipment from obvious threats, like unauthorized access.   We have a preventive maintenance program to maintain the on-going integrity of the refrigeration equipment.  Training programs are in place to ensure that qualified personnel operate the systems, and our emergency response procedures allow us  
to respond quickly in the event of an accident.  
D.   Description of the Accidental Release Prevention Program 
The facility has an accident release prevention program that complies with Occupational Safety and Health Act's Process Safety Management Standard and EPA's Risk Management Program Regulation.  The prevention program consists of the following elements: 
- Employee Participation Program  
- Process Safety Information  
- Process Hazard Analysis  
-  Operating Procedures 
-  Training Program 
- Contractor Safety Program 
-  Pre-Startup Safety Review Procedures 
- Mechanical Integrity Program 
-  Hot Work Permit Procedures 
- Management of Change Procedures 
- Incident Investigation Procedures 
- Compliance Audit Procedures 
E.   Five-Year Accident History 
There have been no accidents at the San Jose Plant during the past five years.   
F.   Description of the Emergency Response Program 
An emergency response program has been implemented at the San Jose Plant.  This program contains pr 
ocedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures.   
The plant has an on-site employee response team trained to enter and stop an accidental ammonia release.   This team meets regularly for training and practice drills.  
G. Planned Changes to Improve Safety 
Kellogg's is committed to operating our ammonia refrigeration system in a safe and responsible manner.   We are continually evaluating our equipment and procedures to meet this objective.  Planned improvements include an increased focus on employee ammonia awareness.
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