HP Hood Inc - Executive Summary

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Risk Management Plan 
Executive Summary 
HP Hood Inc 
Winchester, VA 
 
 
A.  Accidental Release Prevention and Emergency Response Policies 
 
HP Hood Inc (Hood) has recently constructed a new milk processing plant in Winchester, Virginia.  This facility has been designed to include an ammonia refrigeration system to chill product and process areas throughout the manufacturing process.  Hood is committed to operating its new milk processing plant in Winchester, Virginia 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.  Hood has also developed and implemented a number of programs that are designed to ensure that if an accidental release were to occur, it will be handled in a manner that minimizes adverse impact to employees, the environme 
nt, the surrounding community and the plant. 
 
Hood views personnel and environmental protection and accident prevention as a continuous process.  Consequently, Hood continuously strives to improve its accident prevention, environmental protection and emergency response programs throughout its facilities.  A recent addition to the overall accident prevention and response program is the development of its Risk Management Program.  The Risk Management Program (RMP) complies with the U.S. Environmental Protection Agency's (USEPA'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 represents the Hood RMP plan and provides information about the processes, accident prevention programs and emergency response planning efforts at the Winchester, VA facility.  Compliance with USEPA's RMP rule includes: 
 
1.    Completion of a hazard assessment in compliance with 40 C.F.R. Part 68, Subpart B, includi 
ng the five-year accidental release history (no history for this new facility); 
 
2.    Implementation of an accident prevention program.  The RMP accident prevention program is coordinated with the Process Safety Management (PSM) program which was developed under similar rules administered by the Occupational Safety and Health Administration (OSHA); and 
 
3.    Implementation of an emergency response plan. 
 
Additional information regarding how Hood addresses each of these requirements is provided below and in the attached RMP plan. 
 
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. 
 
 
B.  RMP Covered Stationary Source and Regulated Substance 
 
The new Hood facility in Winchester, VA is owned and operated by HP Hood Inc of Chelsea, MA.  The facility contains an ammonia refrigeration system that chills milk products.  The refrigeration sys 
tem is new and will be charged with 58,000 pounds of anhydrous ammonia on June 15, 2000.  This amount exceeds both the PSM and the RMP applicable thresholds. 
 
 
C.  Off-site Consequence Analysis 
 
As required by the RMP rule, the Hood off-site consequence analysis included evaluation of a worst-case accidental release for anhydrous ammonia and an alternative-case release also for anhydrous ammonia. 
 
A worst-case release is defined by USEPA 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."  See 40 C.F.R. ? 68.3.  USEPA 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, USEPA requires worst-case models to be run using the hottest recorded temperature of the past 3 years at night with a very slow, steady wind to minimize the release dispersion.  
The models must also assume that the entire contents of the largest vessel, the high-pressure receiver, are completely released at a constant rate over a 10-minute period. 
 
Using the USEPA mandated criteria described above, the worst-case release at the plant (for purposes of RMP) would involve a complete failure of the largest vessel, filled to maximum capacity with ammonia.  If such a release occurred, it would result in a vapor cloud that could impact persons outside the plant's property line.  The probability of a receiver releasing its entire contents in 10 minutes in Winchester, VA on a 102? F night when the wind is blowing at 3.4 miles per hour is extremely low for numerous obvious reasons. 
 
Hood also developed an alternative release scenario that considers more a realistic situation occurring during more common meteorological conditions as part of the RMP standard.  USEPA requires that the modeling of this type of release be shown to reach off-site locations.  After considerin 
g all criteria in the RMP rule, Hood used a liquid release due to a forklift accident for its alternative-case scenario. 
 
 
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 (PSM) standard found at 29 C.F.R. Part 1910.119 and is analogous to RMP requirements found at 40 C.F.R. Part 68, Subpart D.  To comply with RMP, the facility has taken its PSM program and incorporated an additional focus - protection of the public. 
 
The basic elements of the Hood's prevention program are described below: 
 
1.  Employee Participation.  Hood has developed and implemented 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 de 
velopment 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 that helped identify the hazards posed by ammonia, handling of materials, management, storage activities and the refrigeration system in general.  The compilation of process safety information provided the foundation for understanding the hazards involved in the ammonia refrigeration system and was crucial to the development of the PHA (discussed in subsection 3 immediately below).  The required process safety information includes information pertaining to anhydrous ammonia, the technology of the ammonia refrigeration system, and the process equipment.  See 29 C.F.R. ? 1910.119(d). 
 
Information pertaining to the technology of the ammonia refrigeration system includes: (1) block flow diagrams; (2) process chemistry; (3) maximum intended inventory; (4) safe upp 
er 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. 
 
Equipment information includes: (1) materials of construction; (2) piping and instrumentation 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 as part of the recent expansion. 
 
3.  Process Hazard Analyses.  Hood recently performed a process hazard analysis (PHA) on the refrigeration system.  The PHA is a key component of the Hood's PSM system and RMP accident prevention program.  It provided a thorough, orderly, and systematic approach for identifying, evaluating, and controlling hazards posed by the ammonia refrigeration process.  The PHA utilized methodologies in accordance with 29 C.F.R. ? 1910.119(e) and 4 
0 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. 
 
4.  Operating Procedures.  Hood has developed and implemented 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 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 be 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 implemented safe work practices that provide for the control of hazards during operations.  For example, Hood has programs that govern the following activities: lockout/t 
agout; 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 facility operations, the ammonia refrigeration system, emergency operations including shutdown, and safe work practices applicable to the job tasks of employees. 
 
6.  Contractors.  Hood, as part of the contractor selection process, 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 ammonia refrigeration system; 
B.  Explains to contract employers the applicable provisions of the facility's emergency response 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 ammonia refrigeration system areas. 
 
7.  Pre-startup Safety Review.  Prior to the introduction of anhydrous ammonia to a new or modified portion of the ammonia refrigeration system, Hood confirms the system 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 implemented written procedures to maintain the ongoing integrity of the process equipment listed below.  Hood also requires contractors have appropriate training to maintain the following process equipment: 
 
A.    Pressure vessels and storage tanks; 
B.    Piping systems (including piping components such as valves); 
C.    Relief and vent systems a 
nd devices; 
D.    Emergency shutdown systems; 
E.    Controls (including monitoring devices and sensors, alarms, and interlocks); and 
F.    Pumps. 
 
9.  Hot Work Permit.  Hood implements a hot work permit program for all hot work operations. 
 
10. Management of Change.  Hood has established and implemented written procedures to manage changes to process chemicals, technology, equipment, and procedures associated with the ammonia refrigeration system; 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 has procedures in place to investigate each incident that resulted in, or could reasonably have resulted in, a catastrophic release of an  
anhydrous ammonia.  An incident investigation team is established and consists of at least one person knowledgeable in the process involved, including contractor's 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 emergency response plan that satisfies applicable state and federal emergency response and accident prevention planning requirements. 
 
13. Compliance Audits.  Hood will evaluate the facility's compliance with PSM and RMP standards 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 will be developed after each audit. 
 
14. Trade Secrets.  Hood makes all necessary information available to those persons responsible and makes no claims to trade secrets that would restrict employee's efforts toward t 
he implementation of the elements of PSM and RMP. 
 
 
E.  Five Year Accident History 
 
Hood is a new facility and therefore has never experienced a RMP reportable release. 
 
 
F.  Emergency Response Procedures and Policies 
 
The training programs at Hood comply with 29 C.F.R. ?? 1910.120(q)(2)(ii) (emergency response), 1910.156 (portable fire extinguishers),1910.1200(h) (hazard communication), and 40 C.F.R. ?? 112.7(e)(10) (Oil SPCC).  All employees receive basic emergency response training appropriate to their response responsibilities.  Those employees that work with hazardous materials or could come into contact with them are given specific training, depending on their duties, on the proper handling of hazardous substances and notification procedures in the event of a release.  For example, where appropriate, Hood employees are trained on: safe work practices; security procedures; appropriate use, inspection and maintenance of personal protection equipment and the location thereof; chemic 
al and oil loading and unloading procedures; internal and external reporting procedures; facility evacuation procedures; confined space entry, lock-out tag-out procedures, and area maintenance and housekeeping. 
 
In the event of an accidental release, the plant will depend on the Winchester Police and Fire Departments for outside support depending on the severity of the release.  If additional assistance is determined to be needed, they will contact other local and state emergency response teams. 
 
 
G.  Planned Changes 
 
Hood has recently completely construction of the plant.  Future changes in the form of an expansion are currently planned for the end of 2001.  These changes, as currently planned, would require an increase of ammonia to the refrigeration system, but would not be enough to trigger a RMP resubmittal.
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