Kraft Foods, Inc. - Louis Rich Co., Newberry SC - Executive Summary

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RISK MANAGEMENT PLAN 
 
 
Executive Summary 
 
 
 
 
 
KRAFT FOODS, Inc. 
 
Newberry, SC 
 
 
 
 
 
 
 
 
Issue date:  September 2, 1998 
 
REVIEWED:                                                                       REVISED: 
                NOVEMBER 12, 1998                                                      NOVEMBER 22, 1998 
                MAY 13,1999                                                                  MAY 15, 1999 
 
 
 
 
TABLE OF CONTENTS 
 
 
EXECUTIVE SUMMARY 
 
1.0 Release Prevention and Emergency Response Policies 
2.0 Process Description and Regulated Substances 
3.0 Worst-Case and Alternative Release Scenarios 
4.0 General Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
5.0 Five-year Accident History 
6.0 Emergency Response Program 
7.0 Planned Changes to Improve Safety 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1.0 Release Prevention and Emergency Response Policies 
 
The Kraft Foods facility in Newberry, SC has a good record in preventing and minimizing releases of anhydrous* ammonia. 
 This facility has a thorough emergency training program for on-site emergency responders.  The facility uses a real time data base 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 per day, 7 days per week by employees with Emergency Response Training.  There are also adequate provisions for coordination with outside agencies, such as with the Friendly Fire Department, City of Newberry Fire Department, National Response Center, South Carolina State Emergency Response Commission and Department of Health & Environmental Control, 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 
 
At this location Kraft Foods processes turkeys.  The North American Industrial Classification System (NAICS) code for the primary process at this fac 
ility is 311615 (SIC code 2015).  This facility is capable of producing and packaging various turkey products including delicatessen type items for consumer intake and de-boned and de-feathered turkey portions to be sent to other Kraft facilities for further processing and packaging.  This facility is equipped to slaughter turkeys.  Many areas of the plant are refrigerated to preserve the meat products.  These include product staging, processing, and storage areas.  Also, this plant employs a blast freezing process in order to adequately preserve portions of processed turkey for shipment to other locations. 
 
Kraft Foods has one regulated substance under 40 CFR 68, at this location.  Ammonia is used as a refrigerant in the refrigeration of the meats in the various areas described above and is also used in the blast freezing process.  
 
 
 
The ammonia threshold for triggering applicability to 40 CFR 68 is 10,000 pounds.  The quantity of ammonia stored on-site is 130,000 pounds.  Thus, 40 C 
FR 68 is applicable to Kraft Foods in Newberry, S.C. 
 
3.0 Worst-Case and Alternative Release Scenarios 
 
The ammonia refrigeration system has associated hazards that can potentially effect on-site employees and the general public off-site if there is a release from the system.  Although the alternative release scenario is more likely, the US EPA requires that one worst-case and one alternative release scenario be reported for each regulated chemical.  Described below are the associated hazards and the worst-case and alternative release scenarios for each regulated chemical. 
 
Ammonia 
 
Ammonia is classified as a Group 2 Refrigerant per ASHRAE Standard 34-1989.  The dominant characteristic of this chemical is its toxicity.  It is a self-alarming chemical by its distinctive pungent odor.  Due to this odor, persons exposed to ammonia vapor will not voluntarily stay in areas of even small concentrations.  Ammonia is flammable in a very narrow and high range of concentration with a high igniti 
on temperature.  It is not poisonous, but it is corrosive to human tissue.  Ammonia is readily absorbed into the moisture of the skin and, at high concentrations, can cause burns. 
 
The risks to persons in an accidental release of ammonia include: 
 
1. Irritation of respiratory tract, 
2. Corrosive attack of skin and other tissue, 
3. Freezing of skin and other body tissue when contacted by liquid ammonia. 
 
Below is a description of the release scenarios for ammonia and their off-site consequences: 
 
  Worst-case scenario - The largest potential release of ammonia will occur with a failure of both the connected receivers located in the northwest corner of the plant property approximately 60 feet from the fence line.  Because of interconnecting pipe work and other vessels that can discharge into this pipe work, the amount of ammonia released will be greater than the amount stored in both the receivers.  The connected other vessels include the condensers (ten).  Due to institutional contro 
ls, the maximum amount of ammonia which could be in each receiver is 70% of the receiver capacity.  The ammonia release in pounds is grouped as follows: 
 
 
 
1. Receivers (2) = 42,600 pounds 
2. Condensers (10) = 2,500 pounds 
3. Interconnecting pipe work = 2,000 pounds 
 
Total Ammonia Released = 47,100 pounds 
 
Under Section 68.25(c)(1), a regulated  substance such as ammonia, which is normally a gas at ambient temperature and handled as a liquid under pressure, shall be considered to be released as a gas over a 10 minute period.  Thus, ammonias physical state in the worst-case release is a gas.  Passive mitigation controls were not applicable to the worst-case release at this plant. 
 
The BREEZE HAZ DEGADIS+ air dispersion model was used to model the worst-case scenario at the Kraft facility in Newberry.  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 h 
eavier-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.  DEGADIS+ was used to determine the distance from the facility to an endpoint chemical concentration of 200 ppm.  The distance to the endpoint of 200 ppm was determined to be 1.44 miles. 
 
The endpoint of 200 ppm for ammonia is based on the Emergency Response Planning Guideline, Level 2 (ERPG-2), developed by the American Industrial Hygiene Association.  This level is the concentration to which an individual could be exposed to for up to one hour without suffering from irreversible or other serious health effects that could impair that individuals ability to leave the affected area. 
 
 The estimated affected residential population is 2,000 people.  The types of affected receptors are listed in the Data Elements section. 
 
 Alternative Release Scenario - The worst-case releas 
e is less likely to occur than the following scenario: The alternative release scenario was the US EPAs default scenario as described in the Model Risk Management Program and Plan for Ammonia Refrigeration.  This alternative release scenario would most likely be caused by a gasket rupture or pump seal leak which would result from a 0.25 diameter orifice.  The release rate of ammonia due to leakage through a failed seal or gasket is calculated to be 100 lb./min according to the U.S. EPAs Model Risk Management Program and Plan for Ammonia Refrigeration. 
 
The BREEZE HAZ DEGADIS+ was used to model the alternative case release scenario at the Kraft facility in Newberry.  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 mo 
deling of dense gases (such as ammonia) and use for emergency response planning.  DEGADIS+ was used to determine the distance from the facility to the ERPG endpoint.   The distance to the ERPG endpoint was determined to be 0.16 miles. 
 
 
 The estimated affected residential population is 20 people.  Only residences and the Newberry Municipal Airport would be effected by the alternative release scenario. 
 
 
4.0 General Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
 
This facility 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.  Krafts ammonia PSM program has been reviewed and determined to be complete for the RMP document. 
 
There are several aspects of the prevention program that are key:  
 
1.  Kraft maintains good training 
, certification and employee awareness of operating procedures. 
 
2. Kraft has a PM and inspection program to keep track of maintenance and mechanical supplies that are     needed.    
 
3.  Utility personnel are present on site and assigned to the ammonia system, 24 hrs a day, 7 days a week, all year round. 
 
4. Most of the pipe work is out of the way of people and machinery so there is less chance of an ammonia release. 
 
5. There is an ammonia detection system in the plant which alerts the utility personnel of the presence of ammonia. 
 
 
5.0 Five-year Accident History 
 
A review of this facility's accident history includes the following range of dates: June 7 1994 - June 7, 1999.  There have been no accidental spills or releases of ammonia at the facility as defined by 40 CFR Part 68.42(a). 
 
 
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.  There  
are 15 in-plant contacts for an emergency which can be found in the Emergency Response Plan.  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 or ammonia emergency.   
 
At the discretion of the Incident Commander, the Friendly Fire Department and other local fire departments and emergency services will be called to provide back-up emergency responders and equipment.  The Friendly Fire Department responds to all emergencies where fire alarms are used for evacuation in addition to all fire related emergencies.  Ambulances will be called to the scene if it is deemed necessary. 
 
7.0 Planned Changes to Improve Safety 
 
Based on the PHA completed for ammonia, a list of action items was developed an 
d is being monitored to determine if implementation was accomplished.  There is one example of a safety improvement as result of the PHA results.  This is: 
 
1. Relocate control valves to a ventilated space separate from production areas.  (Completed, 8/22/95)
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