H.P. Hood, Inc. - Executive Summary
Risk Management Plan |
H.P. Hood, Inc.
I. Executive Summary
A. Accidental Release Prevention and Emergency Response Policies
H.P. Hood, Inc. is committed to operating its milk processing plant in Oneida, New York in an environmentally responsible manner and to providing a safe work place for its employees and the surrounding community. As part of this commitment, Hood has developed and implemented numerous safety programs that are designed to eliminate and/or drastically reduce the potential for accidental releases of ammonia used in the refrigeration system. Hood has also developed and implemented a number of programs that are designed to ensure that if an accidental release occurs, it will be handled in a manner that minimizes adverse impact to people, the environment and the plant. Many of these programs have been in place for some time.
Hood views accident prevention, and personnel and environmental protection as a never-ending process. Cons
equently, Hood continuously strives to improve its accident prevention, environmental protection and emergency response programs. A recent addition to Hood's overall accident prevention and response program is the development of its Risk Management Program. Hood's Risk Management Program (RMP) complies with the U.S. Environmental Protection Agency's ("EPA's") Chemical Accident Prevention rule found at 40 C.F.R. Part 68. One of the requirements of this rule is to submit a Risk Management Plan. This document is Hood's RMP plan and provides the public with information about Hood's processes, accident prevention programs and emergency response planning efforts. Hood's compliance with EPA's RMP rule includes:
1. Completion of a hazard assessment in compliance with 40 C.F.R. Part 68, Subpart B, including the five-year accidental release history--Hood has never experienced an RMP reportable release or accident at its Oneida plant.
2. Implementation of a accident prevention program.
The plant's RMP accident prevention program is coordinated with the plant's Process Safety Management (PSM) program which was developed under similar rules administered by the Occupational Safety and Health Administration "OSHA";
3. Implementation of an emergency response program. As recommended in the RMP rule and by numerous federal response entities, the plant has developed a single Integrated Contingency Plan (ICP) that is designed to meet the emergency response planning requirements applicable to the plant under a number of federal and state emergency response and accident prevention planning laws.
Additional information regarding how Hood addresses each of these requirements is provided below and in the attached RMP plan.
While the RMP program at Hood helps ensure that the facility is maintained and operated in a safe and environmentally responsible manner, it is just one component of Hood's comprehensive safety programs. Additional components that are beyond the scope of t
he RMP include, but are not limited to: regular employee/contractor safety training, periodic table-top safety and emergency response drills, acquisition and maintenance of emergency response and personnel protective equipment, development of safe work practices (confined space, lockout/tagout, hot work), implementation of safe work procedures, new project safety review procedures, preventive maintenance and regular inspections of all tanks and equipment that contain hazardous chemicals, chemical control and purchasing procedures, medical emergency response training, contractor certification, etc.
The plant and all equipment is designed and operated to minimize the possibility of an accidental release. At a minimum, the plant and equipment meet government and industry design and construction standards.
The following most recent safety initiative demonstrate Hood's commitment to providing a safe workplace:
1. In 1999, Hood integrated all of its emergency response and accident p
revention plan into a single, easy to use Integrated Contingency Plan (ICP). The ICP is designed to provide more-effective emergency response guidance and to comply with a number of state and federal laws.
2. In 1999, Hood substantially upgraded its accident prevention and safety management program.
B. RMP Covered Stationary Source and Regulated Substance
The H.P. Hood plant in Oneida, NY is owned and operated by Catamount Dairy Holdings. The plant processes milk. Ammonia is the only chemical present at the plant in sufficient quantity to be regulated by the chemical accident prevention rule. Ammonia is used in the refrigeration system used to process and store milk and other dairy products.
Ammonia is stored in two tanks outside of the H.P. Hood facility. The larger of the tanks has a capacity of 4,415 gallons. The total maximum amount of ammonia used at any one time in the refrigeration process is 23,000 lbs.
C. Off-site Consequence Analysis
As required by the RMP ru
le, Hood's off-site consequence analysis included evaluation of a worst-case accidental release for all toxic chemicals (ammonia) and an alternative release for each covered chemical (ammonia).
A worst-case release is defined by EPA as "a release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to an endpoint defined in ' 68.22." 40 C.F.R. ' 68.3. EPA requires the worst-case accidental release to be modeled using highly conservative meteorological data designed to result in the maximum possible adverse impact. For example, EPA requires worst-case models to be based on the hottest day of the year, occurring at night with a very slow, steady wind which would not disperse a release very effectively. Further, the model assumes that the entire contents of the largest vessel is released in ten minutes. The probability of a 23,000 lb. tank of ammonia releasing its entire contents in ten minutes in New York on a 9
40F night when the wind is blowing at 3.4 miles per hour is extremely low.
Using the EPA mandated criteria described above, the worst-case release at the plant (for purposes of RMP) would involve a complete failure of the largest storage tank, filled to maximum capacity with 23,000 lbs. of ammonia. If such a release occurred, it would result in a vapor cloud that could impact persons outside of the plant's property line.
Hood developed an alternative release of ammonia that focuses on a more realistic release scenario occurring during more common meteorological conditions. EPA requires modeling of a release which could impact off-site locations. Alternative release modeling of the most realistic scenario resulted in off-site impacts. This release did not, however, impact residences, recreation areas, schools, hospitals, prisons or any environmental receptors. Accordingly, after considering all criteria in the RMP rule, the Process Hazard Analysis performed on the refrigeration
process, and all past releases, Hood used a gas line rupture for its alternative release. The rupture would result in a release of 9.8 pounds in five minutes. More realistic meteorological conditions were used to generate a more realistic toxic endpoint distance.
D. Accident Release Prevention Program
Hood has developed an accidental release prevention program that is designed and implemented to drastically reduce the possibility of an accidental catastrophic release. The program complies with the requirements of OSHA's Process Safety Management rule found at 29 C.F.R. Part 1910.119 and analagous to RMP requirements found at 40 C.F.R. Part 68, Subpart D. The program has been very successful as evidenced by the fact that the plant has never experienced an accidental release that requires reporting under EPA's RMP rule. See 40 C.F.R. ' 68.42. To comply with the RMP rule, the plant has taken its existing PSM program and incorporated an additional focus-protection of the public.
The basic elements of Hood's prevention program are described below:
1. Employee Participation. Hood has developed and implements a written plan of action regarding employee participation in the safety and accident prevention process. The plan describes how employees are: (A) consulted and what input they will have in the development of process hazard analysis (PHA) and other PSM and RMP safety elements; and (B) given access to PSM and RMP information at the plant.
2. Process Safety Information. Hood has compiled written process safety information which helped identify the hazards posed by ammonia, handling of materials, management, storage activities and the refrigeration process in general. The compilation of process safety information provided the foundation for understanding the hazards involved in the refrigeration process and was crucial to the development of a complete and thorough process hazard analyses (discussed in subsection 3 immediately below). The requir
ed process safety information includes information pertaining to the hazardous chemicals (e.g. ammonia), the technology of the process, and the process equipment. 29 C.F.R. ' 1910.119(d).
The type of information pertaining to the technology of the process includes: (1) block flow diagrams; (2) process chemistry; (3) maximum intended inventory; (4) safe upper and lower limits for temperature, pressure, flow and composition; and (5) an evaluation of the consequences of deviations, including those affecting the safety and health of employees and the nearby public.
The equipment information includes: (1) materials of construction; (2) piping and instrument diagrams (P&IDs); (3) electrical classification; (4) relief system design and design basis; (5) ventilation system design; (6) design codes and standards employed; and (7) material and energy balances for processes built after May 26, 1992.
3. Process Hazard Analyses. Hood performed its most recent process hazard analysis (PHA)
on the refrigeration system in 1999. The PHA is a key component of the process safety management system and Hood's RMP accident prevention program. It provided a thorough, orderly, systematic approach for identifying, evaluating, and controlling hazards posed by the refrigeration process. The PHA utilized the what-if/PHA methodology in accordance with 29 C.F.R. ' 1910.119(e) and 40 C.F.R. ' 68.67.
The PHA addressed: (1) hazards of the process; (2) engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases (e.g., process monitoring and control instrumentation with alarms); (3) consequences of failure of engineering and administrative controls; (4) facility siting; (5) human factors (human error); and (6) a qualitative evaluation of a range of the possible safety and health effects of failure of controls on the employees in the work place.
ng Procedures. Hood has developed and implements written operating procedures that provide clear instructions for safely conducting activities involved in the refrigeration process. These procedures are consistent with the process safety information described in subtask 2, above, and cover, where appropriate and applicable:
A. Initial startup;
B. Normal operations;
C. Temporary operations;
D. Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner;
E. Emergency Operations;
F. Normal shutdown;
G. Startup following a turnaround or after an emergency shutdown;
H. Consequences of deviation from operating limits;
I. Steps required to correct or avoid deviation;
J. Precautions necessary to prevent exposure, including engineering and administrative controls, and personal protective equipment;
K. Control measures to b
e taken if physical contact or airborne exposure occurs;
L. Quality control for raw materials and control of hazardous chemical inventory levels; and
M. Safety systems and their functions.
Hood has also developed and implements safe work practices that provide for the control of hazards during operations. For example, Hood has programs that govern the following activities: lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into PSM and RMP covered portions of the plant by maintenance, contractor or other support personnel.
5. Training. Hood provides employees, contractors and visitors with training that focuses
on the special safety and health hazards posed by the plant operations, the RMP and PSM
covered process, emergency operations including shutdown, and safe work practices
applicable to the employees job tasks. Hood confirms that employees and contractors
involved in operating a covered process
have successfully completed the required training.
Hood documents that covered employees and contractors have received and
understood the required training. Documentation, at a minimum, includes the identity of
the employee or contract employee, the date of training, and the means used to verify that
the employee understood the training.
6. Contractors. As part of Hood's contractor selection process it obtains and evaluates
information regarding contract employer's safety performance and programs. (29 C.F.R. '
1910.119(h) Hood also:
A. Informs contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process;
B. Explains to contract employers the applicable provisions of the facility's integrated contingency plan (discussed below); and
C. Develops and implements safe work practices to control the entrance, presence and exit of contract employers and contract
employees in covered process areas.
7. Pre-startup Safety Review. Prior to the introduction of highly hazardous chemicals to a new or existing RMP/PSM covered process, Hood confirms the process is constructed and the equipment is designed in accordance with specifications; and that appropriate safety, operating, maintenance, and emergency procedures are in place to adequately protect the health and safety of employees and the nearby public.
8. Mechanical Integrity. Hood has developed and implements written procedures to maintain the ongoing integrity of the process equipment listed below. Hood also trains employees to maintain the following process equipment:
A. Pressure vessel's and storage tanks;
B. Piping systems (including piping components such as valves);
C. Relief and vent systems and devices;
D. Emergency shutdown systems;
E. Controls (including monitoring devices and sensors, alarms, and interlocks); and
9. Hot Work Permit. Hood implements a hot work permit
program for all hot work operations (e.g., welding, soldering) conducted on or near any of the components involved in the refrigeration process.
10. Management of Change. Hood has established and implements written procedures to manage changes to process chemicals, technology, equipment, and procedures associated with the refrigeration process; and, changes to facilities that affect this process. These procedures ensure that the following considerations are addressed prior to any change:
A. The technical basis for the proposed change;
B. Impact of change on safety and health;
C. Modifications to operating procedures;
D. Necessary time period for the change; and
E. Authorization requirements for the proposed change.
11. Incident Investigation. Hood investigates each incident which resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical in the workplace. An incident investigation team is established and consists of at least one pers
on knowledgeable in the process involved, including a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident.
12. Emergency Planning and Response. Hood has developed an integrated contingency plan that satisfies all applicable state and federal emergency response and accident prevention planning requirements (described under emergency response policies below).
13. Compliance Audits. Hood evaluates the plant's compliance with the PSM Standard and the RMP rule at least every three years to verify that the procedures and practices it has developed are adequate and being followed. RMP and PSM audit findings reports are developed.
14. Trade Secrets. Hood makes all necessary information available to those persons responsible for compiling process safety information and those assisting in the development of the process hazard analysis.
E. Five Year Accident Hi
The Oneida plant has never experienced a RMP reportable release.
F. Emergency Response Procedures and Policies
Certain Hood employees at the Oneida plant have been trained to respond to small ammonia releases and other incidental spills and leaks. Employees have also been trained on confined space entry procedures and the proper use of personal protection equipment (PPE). In the event of small fires, plant employees have been trained in the use of fire extinguishers. Personnel have also been trained to notify the plant manager in the event of more extensive accidental releases. The plant manager is responsible for assessing the extent of releases, internal notification of releases and determinations of whether or not outside responders are needed. During an emergency, Hood employees have been trained to evacuate to a predesignated muster point.
In the event that an accidental release occurs that is beyond the capabilities of the plant employees to control, the plant dep
ends on the Oneida Fire and Police Departments for outside support. When the Oneida Fire Department determines additional assistance is needed, it will contact other local and state emergency response teams.
Hood has also adopted and implements an Integrated Contingency Plan that meets the regulatory requirements of the following federal and state response planning and prevention laws:
7 OSHA Emergency Response Plan (29 C.F.R. 1910.120(q))
7 OSHA Process Safety Management emergency response requirements (29 C.F.R. ' 1910.119(n))
7 OSHA Hazard Communication Plan (29 C.F.R. ' 1910.1200(h))
7 EPA Risk Management Plan Emergency Response Program (40 C.F.R. ' 68.95)
7 EPA Oil Spill Prevention Control and Countermeasure Plan (40 C.F.R. ' 112.7)
7 New York Spill Prevention (6 NYCRR Part 598)
7 Oil Spill Prevention and Control (17 NYCRR ' 32)
The ICP includes, among other things:
7 Procedures for notifying the public and the local emergency planning committee
7 Arrangements for first-a
id procedures and emergency medical treatment procedures for exposure to ammonia
7 Emergency response and incident termination procedures
7 Procedures for using, inspecting and testing emergency response equipment
7 Employee training procedures
7 Procedures to amend the ICP plan
G. Planned Changes
There are no planned changes to note.