Kellogg USA - Rossville - Executive Summary |
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The Kellogg Company manufacturers a variety of waffles at our facility in Rossville. We have produced waffles in Rossville since 1988. 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 chillers. 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. These precautions include safety controls (alarms and automatic shutdown devices) which are designed to identify and prev ent 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 systems, a training program designed to ensure that the systems are operated by qualified personnel, and emergency response procedures which 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 Rossville produces frozen waffles for sale to the public. The ammonia inventory for the refrigeration system is approximately 70,000 pounds. Ammonia is the only substance covered by the Accidental Release Prevention Regulations handled at the Rossville Plant. C. Summary of Worst-Case and Alternative Release Scenarios EPA requires us to define the worst case release scenario from the Rossville plant as the release of 12,000 poun ds of ammonia aver a 10 minute period due to the failure of the high pressure receiver. The 12,000 pounds represents the maximum amount of ammonia that would be contained in the receiver at any time. We have written procedures in place to assure that this is so. 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 Rossville plant would involve the release of 2,700 pounds of ammonia over a 5-minute period due to the rupture of a 1/2" receiver sight glass in the refrigeration system. The duration of the release was estimated for the alternative release scenario by estimating the amount of time required to stop the leak. Again, EPA required us to estimate these 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 refrige ration. We have taken precautions to protect our equipment from obvious threats, like vehicular traffic. 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. The weather conditions used in estimating the extent of the releases are uncommon. 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 Proced ures - Mechanical Integrity Program - Hot Work Permit Procedures - Management of Change Procedures - Incident Investigation Procedures - Compliance Audit Procedures E. Five-Year Accident History There has been one accident at the Rossville plant over the past five years. In August of 1997, a pressure transducer developed a hole due to corrosion. This resulted in a 150 pound ammonia release into our product storage freezer. Our emergency response team responded to and contained this release. There were no off-site consequences, and no on site injuries. F. Description of the Emergency Response Program An emergency response program has been implemented at the Rossville Plant. This program contains procedures 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 p ractice 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 the replacement of all pressure safety relief valves. |