Kraft Foods, Inc. - Executive Summary |
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EXECUTIVE SUMMARY 1.0 Release Prevention and Emergency Response Policies The Kraft Foods facility in Visalia, California has a very good 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 policies at this facility ensure that there is emergency response coverage 24 hours - 7 days per week by employees with Emergency Response Training. There are also adequate provisions for coordination with outside agencies, such as with the Visalia Fire Department, in the event of an emergency. 2.0 Process Description and Regulated Substances At this location Kraft Foods manufactures or processes dairy products and dairy byproducts. The North American Industry Classificati on System (NAICS) code for the primary process at this facility is 31151 (SIC code 2023). This facility is capable of producing and packaging various dairy products including cottage cheese and sour cream for consumer intake. One area (coldbox) of the plant is refrigerated to preserve the dairy products. The dairy by-products include butter and powder. An on-site dryer produces the powdered milk products. Kraft has one regulated substance under 40 CFR 68, ammonia, at the Visalia, CA plant. 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 20,000 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 quan tities. 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 Visalia 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 the BREEZE HAZ DEGADIS+ air dispersion model at the Kraft facility in Visalia. DEGADIS+, developed by the US Coast Guard, is an EPA approved model as identified in the RMP Offsite Consequence Analysis Document (May 24, 1996). It predicts contaminant movement for heavier-than-air gases for instantaneous and continuous ground level releases. It was selected because of its applicability towards modeling of dense gases (such as ammonia) and use for emergency response planning. 4.0 General Accidental Release Prevention Program and Chemical-Specific Prevention Steps This facility has developed an OSHA Process Safety Management program for their ammonia refrigeration system. There are several aspects of the prevention program that are key: 1. Utility personnel are present on-site and assigned to the ammonia system, 24 hours a day, 7 days a week, all year roun d. 2. There is a plant ammonia detection system which alerts the utility personnel. 3. Most of the ammonia pipe work is located away from employee traffic patterns and machinery to minimize the chance of an ammonia release. 4. The plant maintains good training, certification and employee awareness of operating procedures. 5. The facility has an aggressive PSM meeting schedule. 5.0 Five-year Accident History A review of this facility's accident history includes the following range of dates: June 22, 1994 to June 21, 1999. To date there has been one accidental spill or release of ammonia at the facility as defined by 40CFR Part 68.42(a). The spill took place on 10/16/94 when a hose broke loose during the draining of an oil pot while making an improvement to the system, and less than five pounds of ammonia was released. There was one minor injury to an on-site person, which was reported. There were no impacts to off-site receptors. 6.0 Emergency Response Program As mentione d earlier, this facility has developed an emergency response program in which plant employees are divided into various management and response teams. Five levels of HAZWOPER are trained at the Kraft Visalia facility. There are in plant contacts for an emergency which can be found in the Plant Emergency Action Plan. There are also back-up personnel in the event that the primary incident response personnel cannot be contacted. The on-site emergency response plan includes information about the frequency of employee emergency response training as well as detailed description of the training content. There are also specific procedures to follow in event of a fire or ammonia emergency. An internal Mobile Emergency Command Center, which is completely stocked with emergency response equipment, is utilized for all emergencies. The Incident Commander operates from this trailer at the Kraft Visalia facility. At the discretion of the Incident Commander, the Visalia Fire Department will be called to provide back-up emergency responders and equipment. The Visalia Fire Department responds to all emergencies where fire alarms are used for evacuation in addition to all fire related emergencies. In all cases where the fire department is called, the city HAZMAT Team will be placed on standby and an ambulance will be called to the scene. |