Hampton Facility - Executive Summary

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The International Paper, Decorative Products Division, Hampton Facility ("the facility") is committed to operating in a manner that is safe for the facility's employees, the public and the environment.  As part of this commitment, the Hampton Facility has established a system to help ensure safe operation of the processes at this facility.  One component of this system is a risk management program (RMP) that helps manage the risks and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). 
The risk management program includes: 
1.  a hazard assessment to help understand (a) the potential off-site consequences of hypothetical accidental releases and (b) accidents that have occurred during the last five years associated with the use of substances regulated by the RMP rule (regulated substances) - see sections 3 and 5; 
2.  an accidental release prev 
ention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered processes) - see section  4; 
3.  an emergency response program to help respond to accidental releases of regulated substances from covered processes - see section 6. 
Information further describing these elements is provided in this RMPlan. 
Although the risk management program helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety and environmental program at the Hampton Facility.  In fact, the facility has a comprehensive safety and environmental program in place establishing many levels of safeguards against release of hazardous substances, and associated injuries and damage. 
The Hampton Facility limits the use of hazardous substances.  Before using a hazardous substance at the facility, less hazardous alternatives are considered.  When a hazardous substance is used, the fa 
cility considers the potential for this substance to adversely affect the facility's employees, the public and the environment, and takes steps to prevent any such effects. 
The Hampton Facility prevents accidental releases of the hazardous substances used at the facility.  When a hazardous substance is used at the Hampton Facility, the equipment is carefully designed, built and operated to reduce the likelihood of an accidental release.  Industry and government standards are closely adhered to in the design, construction, and operation of the equipment. 
The Hampton Facility limits damage from a release, if such a release occurs.  Workers are trained to respond to an accidental release, reducing the consequences of a release if it occurs.  In addition, the facility works with the local fire department and with the local emergency planning committee (LEPC) to help ensure that injuries and/or environmental damage will not occur if a release does occur. 
The safety and environmental prog 
ram at the Hampton Facility consists of a number of elements, only some of which are required by the RMP rule.  This RMPlan is primarily intended to describe those parts of the safety and environmental program at the Hampton Facility that are required by the RMP rule. 
1.  Accidental Release Prevention and Emergency Response Policies 
The Hampton Facility is committed to the safety of its employees and the public, and the preservation of the environment, through the prevention of accidental releases of hazardous substances.  The facility implements controls to prevent foreseeable releases of hazardous substances.  These controls include training programs for personnel; programs to help ensure safety in the design, installation, operation, and maintenance of processes; and programs to evaluate the hazards at the Hampton Facility. 
In the event of an accidental release, the Hampton Facility controls and contains the release in a manner that will be safe for its employees and will help p 
revent injury to the public or the environment.  The facility provides response training for its personnel, designates an emergency response coordinator to oversee response activities, and coordinates response efforts with the local fire department.  Response activities have also been discussed with the LEPC. 
2.  Regulated Substances 
The Hampton Facility manufactures high pressure decorative and industrial laminates.  As part of this manufacturing process, the facility handles one regulated substance in sufficient quantities to be covered by the RMP rule.  
Process:                       Resin Manufacturing 
Program Level:              3 
Regulated Substance:  Formaldehyde 
Process Quantity:        41,878 gallons 
3.  Off-site Consequences Analysis 
The Hampton Facility performed an off-site consequence analysis to estimate the potential for an accidental release of a regulated substance to affect the public or the environment.  The off site consequence analysis consisted of evaluating  
both the worst-case release scenario and an alternative release scenario, since the Hampton Facility does not expect a worst-case release scenario to ever occur.  The alternative release scenario was selected to help the local emergency planning committee improve the community emergency response plan.  The alternative release scenario represents a release that (1) might occur at a facility like the Hampton Facility and (2) would result in the greatest potential off site consequences if the release occurred. 
The main objective of performing the off site consequence analysis is to determine the distance at which the public might be affected because of an accidental release (called the endpoint distance).  The following effects could occur at the endpoint distance.  At distances less than the endpoint distance, the effects would be greater; at distances greater than the endpoint distance, the effects would be less.  When considering the release of a toxic substance, most people at the en 
dpoint distance would be able to walk away from the exposure without any long-term health consequences, although some short-term consequences (e.g., strong eye or throat irritation) are likely.  Some people who are particularly susceptible to the substance released could be incapacitated. 
The following information summarizes the off site consequence analysis performed by the Hampton Facility. 
3.1  The worst-case release scenario for formaldehyde is the catastrophic failure of one of the storage tanks resulting in a release of 120,000 pounds of aqueous (37%) formaldehyde in 10 minutes.  The release of this quantity of 37% formaldehyde solution will likely form a pool, and the impact of the worst case scenario assumes evaporation of formaldehyde from that pool.  The modeled endpoint for the potential release would impact residences and industrial areas. 
3.2  The alternative release scenario for formaldehyde is a liquid spill due to a leak in a flange or valve.  This scenario assumes a 
one gallon per minute release of 37 percent aqueous formaldehyde that is discovered and stopped within 30 minutes with spill cleanup occurring within one hour after release is stopped.  The modeled endpoint for the potential release would impact residences and industrial facilities.   
4.  Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
Since International Paper acquired the Hampton Facility from its previous owner in 1995, International Paper has improved the facility's prevention program to help prevent accidental releases of hazardous substances.  The process is covered by the facility's Process Safety Management (PSM) program, and the prevention program for this process consists of the 14 elements of process safety management as required by OSHA 1910.119.  The following summarizes some of the elements. 
4.1.  Process Safety Information.  The Hampton Facility maintains a variety of technical documents that are used to help ensure safe operation of the  
resin manufacturing process.  These documents address (1) physical properties of formaldehyde, (2) operating parameters of the equipment, and (3) design basis and configuration of the equipment.  This process safety information is available to all facility employees, the local emergency planning committee (LEPC), and the local fire department. 
Material safety data sheets (MSDSs) for hazardous substances at the Hampton Facility are available in each process area so that the operators have ready reference to this information.  In addition, MSDSs and related information are provided to the LEPC and the local fire department for use in helping formulate emergency response plans. 
Engineering design documents include the operating parameters and the design basis and configuration of the equipment in each covered process.  Many of the operating parameters are included in the operating procedures to help with the safe operation of the process.  These documents are used (1) to train employees 
, (2) to perform process hazards analyses, and (3) to help maintain the equipment. 
4.2.  Process Hazard Analysis.  The Hampton Facility performs and periodically updates process hazard analyses (PHAs) of the covered processes to help identify process hazards and generate recommendations that might improve the safe operation of the process.  A team composed of personnel with engineering and process operating experience and a leader with process hazard analyses experience is assembled to analyze the hazards of the process.  The Hampton Facility primarily uses the hazard and operability (HAZOP) technique, supplemented with checklists, to perform this analysis.  The PHA team prepares a written report describing the results of the analysis, including a list of recommendations.   Responsibility to resolve the recommendations is assigned to unit personnel and, when appropriate, changes to enhance the safety of the processes are implemented. 
4.3.  Operating Procedures.  The Hampton Facility' 
s process engineers, operators, and supervisors work together to develop and maintain operating procedures to define how tasks related to process operations should be performed safely. These operating procedures cover all phases of operations, including initial startup, normal operations, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations.  The operating procedures are used to train employees and to serve as reference guides for appropriate actions to take during both normal and process upsets.   
4.4.  Training.  Employees at the Hampton Facility are trained to safely and effectively perform their assigned tasks.  The training program includes both initial and refresher training that covers (1) a general overview of the process, (2) the properties and hazards of the substances in the process, and (3) a detailed review of the process operating procedures and safe work practices.  Oral reviews and written tests are used to 
verify that an employee understands the training material before the employee can work in the process. 
4.5.  Mechanical Integrity.  The Hampton Facility maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public, or the environment.  The facility's mechanical integrity program includes (1) an inspection and testing program to help identify equipment deterioration and damage before the equipment fails and (2) a quality assurance program to help ensure that new and replacement equipment meet the design standards required for service in the process.  
4.6.  Management of Change.  The Hampton Facility's management of change program evaluates and approves all proposed changes to chemicals, equipment, and procedures for a covered process to help ensure that the change does not negatively affect safe operations.  Process changes that are determined to be a replacement in kind are allowed without completing the full mana 
gement of change procedure.  All other changes must be confirmed through the full management of change procedure to help ensure that inadvertent consequences of process changes are prevented, safety consequences of changes are addressed, affected process safety information and procedures are updated, and affected employees are notified of the changes. 
4.7.  Pre-startup Review.  The Hampton Facility performs a safety review of a new or modified process before the process is placed into service to help ensure that the process has been prepared to operate safely.  A pre-startup review checklist is completed to document the review and to ensure that appropriate issues have been addressed. 
4.8.  Compliance Audits.  International Paper audits covered processes to be certain that the prevention program is effectively addressing the safety issues of the operations.  International Paper assembles an audit team that includes personnel knowledgeable in the RMP rule, and this team evaluates whet 
her the prevention program satisfies the requirements of the RMP rule and whether the prevention program is sufficient to help ensure safe operation of the process.  The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented. 
4.9.  Incident Investigation.  The Hampton Facility investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment so that similar accidents can be prevented.  An investigation team is assembled, and the investigation is initiated within forty-eight (48) hours of the incident.  The results of the investigation are documented, recommendations are resolved, and appropriate process enhancements are implemented. 
4.10.  Employee Participation.  The Hampton Facility developed a written employee participation program for covered processes to help ensure that the safety concerns of its workers are addressed.  The Hampton Fac 
ility encourages active participation of personnel in the prevention program activities at the facility.  Employees are consulted on and informed about all aspects of the RMP rule prevention program, including PHAs and operating procedures. 
4.11.  Hot Work Permits.  The Hampton Facility's hot work permit program is designed to control spark- or flame-producing activities that could result in fires or explosions.  International Paper created a Hot Work Permit Form to comply with OSHA's fire prevention and protection requirements in 29CFR 1910.252(a) and insurance requirements .  Personnel who are to perform hot work are required to obtain a Hot Work Permit prior to work being performed.  Training in the use of the Hot Work Permit is conducted for all affected employees at the facility. 
4.12.  Contractors.  The Hampton Facility established a program to help ensure that contractor activities at the facility are performed in a safe manner.  The safety  record of contractors is reviewed   
to help ensure that the facility only hires contractors who can safely perform the desired job tasks.  The facility explains to the contractors the hazards of the process on which they will work, the facility's safe work practices, and the facility's emergency response procedures.  The facility periodically audits the work performance of the contractor to ensure that safe practices are followed. 
In addition to the required prevention program elements, the Hampton Facility has implemented safety features specific to formaldehyde.  Industry standards are followed at the Hampton Facility to help ensure safe handling of formaldehyde.  The formaldehyde is delivered to the facility from the neighboring Georgia Pacific Plant.  A double-walled pipe is used to transport the formaldehyde between the two facilities, thus reducing the potential for leaks.  The formaldehyde is stored in tanks inside the Hampton Facility's tank farm.  The tank farm is constructed with a concrete base and surrounded 
by a concrete wall.  This wall serves as secondary containment and is configured to hold the capacity of the largest tank inside the tank farm. 
5.  Five-Year Accident History 
The Hampton Facility experienced one release of formaldehyde that went off site over the past five (5) years.  On October 5, 1995, a resin manufacturing kettle over pressurized.  This over pressurization resulted in the release of resin to the ambient air via a safety vent.  The release came in contact with two neighboring manufacturing facilities.  Small drops of resin were observed on parked cars, building structures, and storage tanks.  International Paper hired a contractor to cleanup the drops of resin.  Four employees of one of the neighboring facilities came in contact with the resin during the release.  Three employees were sent to the local hospital for examinations.  No injuries were noted from the release.  The South Carolina Department of Health and Environmental Control (DHEC) responded to the rele 
The Hampton Facility conducted an incident investigation and implemented operating procedural changes to the manufacturing of resins to enhance the safety of this process.  A receiving tank was also installed.     
6.  Emergency Response Program 
The Hampton Facility's written emergency response plan complies with other federal contingency plan regulations [e.g., OSHA regulations 29 CFR 1910.38(a), 29 CFR 1910.120(a)] and has been communicated to local emergency response officials.  The facility maintains an emergency response team, and facility personnel are trained in evacuation procedures.  The facility periodically conducts emergency response drills, including annual meetings with the local fire department. 
7.  Planned Changes to Improve Safety 
The Hampton Facility constantly strives to improve the safety of its processes through both the incident investigation program and a program soliciting safety suggestions from the employees.  
A Facility Safety Committee has been est 
ablished that consists of nine employees.  Each of the nine members will be a Team Leader for one of nine subcommittees.  The subcommittees will have the following responsibilities. 
 Confined Space/Zero Energy State (ZES) 
 Hazard Communication 
 Ergonomics/Personal Protective Equipment (PPE) 
 Emergency Response/Fire & Spill Response 
 Equipment Guarding/Moving Equipment 
 Process Safety Management (PSM)/Contractor Safety 
 Incident Investigation/Workers' Compensation 
 Safe Behavior/Periodic Inspections 
 Material Handling/Movable Equipment 
The nine subcommittees will include hourly and salaried employees from a cross-section of the facility and will meet on a regular basis.  Each subcommittee will develop projects to assist the facility in complying with OSHA and Corporate Requirements, develop management systems to maintain compliance, assist in the annual Key Element Surveys, lay the foundation for a High Performance Organization and OSHA's Voluntary Protection Program, and pro 
mote safety awareness, ownership and accountability. 
Other safety teams are established as necessary to address particular areas of concern, such as hoist inspections.
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