Document dY7ZRBvOyBjvMK8GMxaNwRDwG

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Hudsonville Creamery & Ice Cream LLC Manojkumar P. Patel AECAB (MI/WI) Sarah Marshall, Section Supervisor AECAB (MI/WI) File BASIC INFORMATION Facility Name: Hudsonville Creamery & Ice Cream LLC Facility Location: 345 E. 48th Street, Suite 200, Holland, Michigan 49423 Date of Inspection: May 25 and 26, 2022 EPA Inspector(s): 1. Manojkumar P. Patel Other Attendees: 1. Cody Yazzie, Air Quality Engineer, Michigan Department of Environment, Great Lakes, and Energy (EGLE) 2. Dan DeJonge, Engineering & Facility Manager, Hudsonville Creamery & Ice Cream, LLC 3. Courtney Miller, PSM Co-Ordinator, Hudsonville Creamery & Ice Cream, LLC 4. Mike Hart, Facility Manager, Hudsonville Creamery & Ice Cream, LLC 5. John SeAubin, Director of Engineering, Hudsonville Creamery & Ice Cream, LLC Contact Email Address: dan@hudsonvilleicecream.com Purpose of Inspection: Compliance Inspection for the Chemical Accident Prevention Provisions (CAPP) as a follow up to a complaint about alleged Risk Management Plan (RMP) violations Facility Type: Ice Cream Manufacturing Regulations Central to Inspection: 40 C.F.R. Part 68 Arrival Time: May 25, 2022, at 9:11 AM EST Departure Time: May 26, 2022, at 2:00 PM EST (approximate) Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet. Small Business Resource Information Sheet not provided. Reason: Small Business Category was not determined at the time of the inspection Provided CBI warning to facility The following information was obtained verbally from Hudsonville Creamery & Ice Cream LLC personnel unless otherwise noted. Process Description: Hudsonville Creamery & Ice Cream LLC (Hudsonville) manufactures varieties of ice creams. Hudsonville's covered processes consist of two closed loop ammonia refrigeration systems for products cooling/freezing and storage. The combined operating storage capacity for ammonia is about 50,600 lbs and the maximum intended ammonia storage capacity is about 57,665 lbs. In the ammonia refrigeration process, ammonia gas is condensed in the evaporative condensers and the ammonia liquid drains into the high pressure receiver. The high pressure receiver feeds liquid through to the high temperature recirculator, which feeds liquid to the low temperature and ultra-low temperature recirculator and evaporators. Ammonia gas produced by the evaporators and heat exchanger, and any liquid carryover, is returned to the recirculators. The dry suction gas from the recirculators flows to the compressors. The discharge gas from the compressors is used for hot gas defrost on the evaporators and the remaining discharge gas enters the evaporative condensers, where the gas is condensed to a liquid and the cycle is repeated. Staff Interview: The facility operates in two shifts and employs about 235 people. Hudsonville developed a Program 3 Prevention Program in its RMP to cover both the new closed loop ammonia Page 2 of 8 refrigeration system and an old ammonia refrigeration system at the site. We discussed that a complaint was received alleging the facility is not following the Risk Management Plan (RMP) requirements. However, the manager stated that it was a disgruntle employee who made a compliant and it is not true. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: Management System: The facility did not assign a qualified person for the implementation and integration of the risk management program elements. It simply states that "manager will assign" into the management system. Process Safety Information (PSI): Safe upper and lower limits for temperature, pressure, flows or composition for the old system are not developed. The consequences of deviation did not consider any deviation of the safe upper and lower limits of Process Safety Information (PSI). Ventilation system design and the calculation for the ventilation system for the old and new system were not documented. Information related to the safety system for the old system was not determined or provided. Process Hazards Analysis (PHA): Hudsonville did not establish a procedure to address the PHA team's finding and recommendations on the old system and assure the recommendations are resolved in a timely manner. Hudsonville's PHA team did not update and revalidate the PHA every five years after the completion of the initial PHA. Hudsonville did not retain the PHA and updates/revalidations for each covered process, and resolutions of recommendations for the life of the process. Hudsonville did not develop a written schedule of when the PHA actions will be completed, and left items open with no dur date. Specifically, Item #5.01 Air Unit Evaps, Piping (Item #7.01), Valves (Item #7.14), with no due date - PHA HIC (phase 2 of Expansion Spreadsheet). Hudsonville did not complete the PHA actions as soon as possible. Hudsonville did not assure the recommendations of the PHA were resolved in a timely manner and documented. Page 3 of 8 Operating Procedures: Hudsonville submitted Standard Operating Procedures and provided a document that lists the safety systems but the functionalities are not addressed for the new freezer system. Based on the documents provided to EPA, no annual certification for SOPs were performed in 2021 and 2022 that certified that the operating procedures are current and accurate. While reviewing the SOP for BC-1 Booster Screw Compressor, EPA found that no prestartup checklist activities exist and Mike Hart agreed that it should be included. The operating limits in the SOPs for BC-1 are different than the Safe Upper and Lower Operating Limits Provided to EPA (Document 2.10 Safe Operating Limits and Consequence of Deviation). Hudsonville claimed that all SOPs are readily available to employees who work in or maintained the covered processes. However, Hudsonville stated that it employs only a few employees and most of the work or maintenance performed by contractors. Training: Hudsonville was not able to provide training certificates for employees involved in operating covered processes including the new freezer system. No training documents were provided to EPA that show that employees were initially trained for the newly assigned processes. Hudsonville did not provide EPA initial training that included emphasis on safety and health hazards, emergency operations including shutdown and safe work practices. Hudsonville did not certify in writing that employees involved in covered processes have the required knowledge, skills, and abilities to safely carry out the work responsibilities. No refresher training documents were provided to EPA for employees involved in the covered processes. Mechanical Integrity (MI): Hudsonville was not able to provide EPA a Mechanical Integrity plan that demonstrated that it implemented written procedures to maintain ongoing integrity of the process equipment. Hudsonville's certification documents did not show that it trained every employee to maintain the on-going integrity of the process equipment. Only one employee's certificate was provided. Hudsonville performed inspections and tests for some equipment in or around 2018. All equipment was not tested in 2018. Hudsonville's did not follow recognized and generally accepted good engineering practices including ANSI IIAR 6-2019 for inspections and testing procedures. Hudsonville claimed there is no regular frequency for inspections and tests of process equipments from manufacturers and did not provide any documents to EPA. Page 4 of 8  Hudsonville's 2018 Phase 1 documented each inspection and test results. However, Hudsonville did not document inspection results for Freezer P-2 in 2019 and Freezer P-1 & 2in 2021-22. Management of Change (MOC): Hudsonville did not update the PSI due to changes in 2020-21. Operating Procedures are not updated as of May 25, 2022. The MOC was finalized in or around 2020-21 but the MOC was signed off on May 18, 2022. Pre-startup Safety Review (PSSR): For MOC 2021-1, Training for each employee involved in operating a covered process was not completed. Compliance Audits: In the Compliance Audit Summary Report dated February 17 and 18, 2021, Design Codes and Standards for the Original Ammonia System were not found and Hudsonville waited till May 11, 2022, to assign this task to be completed on May 11, 2022. Hudsonville took almost 15 months to correct deficiencies in the Design Codes and Standards. Contractors: Hudsonville does not explain to its Contractors about the applicable provisions of Emergency Response or Emergency Action Plan requirements. Hudsonville does not have safe work practice standards to control the entrance, presence, and exit of contractors involved in the covered processes. Hudsonville currently does not have a plan to evaluate the performance of contractors. The February 2021 Compliance Audit Findings related to Contractors assigned to Courtney Miller on May 11, 2022, to be completed on May 11, 2023. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW The following is a list of documents that were provided by Hudsonville prior to the inspection and uploaded to Region 5's OneDrive storage. 1. System Overview - Hudsonville Ice Cream (2021 Freezer NH3 System) Management System Application 2. BFD - Plant MR-R0.2 3. BFD-Freezer 7203-R0.2 Page 5 of 8 4. System Overview - Plant MR (002) 5. Compliance Audit - Feb 2021 6. Compliance Audit Findings - Hudsonville Ice Cream - Feb 2021 7. PHA HIC (Holland, MI) MOC (Phase 2 of Expansion) 7-19-2021 8. PHA HIC (Holland, MI) MOC (Phase 2 of Expansion) 7-19-2021- WORKING COPY 9. 2021 Hudsonville Phase 1 PSSR 10. 2021 Hudsonville Phase 2 PSSR 11. 2021 Hudsonville Phase 3 PSSR 12. 2021-1 MOC Final 13. 2021-2 MOC Final 14. 2021-3 MOC Final The following is a list of documents that were provided during the site visit by electronic mail: 1. LEPC Draft Plan 2. Inventory Calcs - Hudsonville Combined for Freezer 3. Load Calculation for Plant System HVIC 2020 Equipment 4. P & ID of New System (8 pdf files) 5. Employee Training records 6. Ammonia Purchase (4 pdf files) 7. Plant PHA 8. Contractors Qualification 9. Freezer Operator Training records 10. NH3 Sensor calibration 11. RMP 2021 - Freezer (4 pdf files) 12. RDS Investigation Report 13. Electronic Files for MOC Binder 14. ANSI IIAR 6 - 2019 Appendix B 15. Certification Documents 16. RPM Inspection Gap Tracking with EPA Audit Items 17. Mechanical Integrity 18. Compressor BC-1 19. Safe Operating Limits and Consequence of Deviation 20. Pressure Relief 21. Relief Calculation CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: 2018 Compliance Audit Findings - A Full Report 2021 Compliance Audit Finding - A full Report Page 6 of 8 DIGITAL SIGNATURES Patel, Digitally signed by Patel, Manojkumar Date: 2022.07.25 Report Author: _M_a__n_o_jk_u__m_a_r__1_4_:15_:3_8_-0_5'0_0_' ____________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL Date: 2022.07.25 _M_A__R_S__H_A__L_L__1_4_:32_:2_7_-0_5'0_0_' _____________ Page 7 of 8 Facility Name: Hudsonville Creamery and Ice Cream LLC Facility Location: 345 E. 48th Suite 200, Holland, Michigan 49423 Date of Inspection: May 25, 2022 APPENDICES AND ATTACHMENTS 1. Digital Image Log 2. Program Level 3 Checklist Page 8 of 8 Facility Name: Hudsonville Creamery & Ice Cream LLC Facility Location: 345 E. 48th St, Suite 200, Holland, Michigan 49423 Date of Inspection: May 25, 2026 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Manojkumar P. Patel 2. Archival Record Location: Enf_Hudsonville Creamery_MI_22_Inspection Image Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25/26 27 28 29 Description of Image Ammonia Detection Screen on the Display Outside Refrigeration Machinery Room 1 Ammonia Refrigeration Marker Layout detail LS-42 C4 Compressor Display HV-34 V-3 Below Vessel PRV-50 V3 Picture (-350C Accumulator) and LV-3 -350C Recirculator HV-38 V-3 (-350C Recirculator) HV-42 V-3 (-350C Recirculator) Vessel Bolton V-1 Intercooler HV-06 V-3 V-1 Intercooler Line (on the way) Bottom Vessel HV-35 V-5 -400C Accumulator PRV-50 V-5 -400C Accumulator Engine Room - Emergency Shower Inspection Tag PSV-70 HSC2 Tag and High Stage Compressor-2 250 HP Compressor CV-41 V-1 Liquid Feed Intercooler (Next to Vessel 9 Chiller Suction Trap) Liquid Ammonia Feed Line (Blue) No Mark up, Missing Physical State, Flow Direction, Pressure level, HPL Missing PSV-60 LS35 C3 Safety Relief Valve - Replacement Date not Marked PSV-60 HSC4 Safety Relief Valve - Replacement Date Missing and not marked PSV-61 HSC4 Safety Relief Valve - Replacement Date Missing PSV-01 XFER1 / HV-08 XFER1 Assemble, Transfer Bellow Receiver 9TSR1) and Accumulator ACC1 Vessel Bottom of Accumulator ACC1 2 Tags HV-03 V8 and Other Valve covered with ice Engine Room 1 Ventilation Display on Control SF- Supply Fan -3; Exhaust Fans -7; 6 Ammonia Sensors Ammonia Sensor Engine Room C2F-13A, C2F-13B -No replacement date marked on C2F compressor Safety Valve C1F-13A & B - C1F Compressor - Replacement date not marked Ammonia Sensor in the Freezer Engine Room Ventilation Display in the freezer Room Ammonia Sensor Line 6 Calibration Jan 2022 Ammonia Sensor Line 4 Near Production Area #3 Appendices Page 1 of 2 Facility Name: Hudsonville Creamery & Ice Cream LLC Facility Location: 345 E. 48th St, Suite 200, Holland, Michigan 49423 Date of Inspection: May 25, 2026 APPENDIX B: PROGRAM LEVEL 3 CHECKLIST INSERT HERE A PROGRAM LEVEL 3 CHECKLIST Appendices Page 2 of 2 RMP Program Level 3 Process Checklist General Facility Informa tion Faciliry Name: ----------- - Mailing Address (Street. C ity, State, Zip) : --------- --------------- - Physical Address (Street, City, State, Zip): Hudsonville Creamery & lee Cream . LLC -- - ------ -- - ------ - 345 E. 48th St Suite 200 Holland, MJ 49423 --- ------ - -- -------------- - ----------- ------ - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - -----~--- - - - ----- --- 345 E. 48th St Suite 200 Holland, MI 49423 Latitu de!Lon gitude: (Source) 42 .755139 I -86.092644 County : -- RMP Number/ FRS Number: Allegan 100000189271 Facility Contact (Name, Title): Dan Delonge, Facility Manager Facility Contact Phone No: (616)610-2217 Reported NAICS Code(s): IFacility Contact Email: Idan@hudsonvilleicecream.com Inspection Information Inspection Begin Date: AITival Time: Lead Inspector May 25, 2022 Name: Manojkumar P. Patel Cody Yazzie, Air Quality Engineer Inspection End Date: Departure Time: Organization: USEPA Michigan Department of Environment, Great Lakes and Energy (EGLE) May 26, 2022 Phone No./Email: (3 12)353-3565 patel.manojkurnar@ epa.gov (269)312-27 54 YazzieC@michigan.gov Participating Inspectors Page I of 19 Rev 01 /07/2021 RMP Program Level 3 Process Checklist Facility Name: Hudsonville Creamery & I~ Suhpart A - (;cneral f68. 10-15 J (je~eral requ irements followed ~ind impkmentcd as in 40 CFR 68-10-15 ? C\ 1mments: ---- ------------------- Liy General: Applicability 168.101 I. Has th~ owne r or operator of a stationary source that has more than a threshold quantity of a regulated substance in a ON process, as determined under s68. 1 15, complied with the requirements of this part no later than the latest of the following dates [68. lO(a)]: 0 June 21, 1999? [68.lO(a)(l)]; 0 Three years after the date on which a regulated substance is first listed under 68.130? [68. l O(a)(2)]; ~ The date on which a regulated substance is first present above a threshold quantity in a process? [68.1 O(a)(3)); or ~ 'L~ 0 For any revisions to this part, the effective date of the final rule that revises this part? [68.10(a)(4)] O N/A 2. . Has the owner or operator complied with the emergency coordination activities in accordance with 68.93 by September 21 , 20 l 8? [68.1 O(b)] (See Items~ through ~ of Subpart E) 3. Has the owner or operator developed and implemented an emergency response program in accordance with 68.95 within three years of when the owner or operator determined that the stationary source is subject to the emergency response progrnm requirements of 68.95? [68. lO(c)] (See Items Lb.(2) - 1.b.(7) of Subpart E) DY I AJ1y 4. Has the owner or operator dc:veloped plans for conducting emergency response exercises in accordance with 68.96 DY by December 19, 2023? [68.lO(d)] (See Items 1.b.(8)- l.b.(17), ., and 1 of Subpart E) 5. Has the owner or operator complied with the public meeting requirement in 68.210(b) within 90 days of any RMP DY repmtable accident at the stationary source with known offsite impacts specified in 68.42(a), that occurs after March 15, 2021? [68.1 O(e)] (See Item ~ of Subpart H) 6. After December 19, 2024, has the owner or operator repmted in the RMP submission: [68.1 O(f)] DY 0 A public meeting afier an RMP reportable accident under 68.160(b)(21)? [68.JO(f)(l)] ; 0 Emergency response program information under 68.I 80(a)(1 )? [68. l O(f)(2)] ; 0 Emergency response program information under 68.180(a)(2) and (3)? [68.10()(3)]; and, 0 Emergency response program and exercises information under 68. l 80(b), as applicable? Including submittal of the following: [68.10(f)(4)] . 0 Dates of the most recent notification, 0 Dates of field and tabletop exercises in the risk management plan, 0 Dates for exercises completed as required under 68.96 at the time the ri sk management plan is either submitted under 68. I 50(b)(2) or (3), or is updated under 68.190. ON ON/A ON ON/A ON ON/A ON ~/A ON /A Page 2 of19 Rev 01 /07/2021 RMP Program Level J Process Ch eckJist Facility Name: Hudsonville Creamery & 1~ C enual: Program Uigibiliry !6R l O(_g)-(i ) j ------- -- ---- ------ --------------------------- --- -- - -------------- 7. Docs the cmercd r rnccss meet the el igibility requirements of Program l ? Speci1icall y: 168. 1O(g)j I 1r - -----~ D Y ON JNN IA Docs the covered rroccss meet all of the following requirem ents: 0 For the five years prior to th e submiss io n of an RJv1P. the process has not had an accidental release of a regulated ~ubstancc \vhere exposu re to the substance, its rc::iction products. overpress ure generated by an c:xplosi(1n imoh ing the substance. or radiant heat gc:neratcd hy a fire involving the substance led to any of the fo ll owingoffsite? 168.IO(g)(l)j: 0 Death; [68.JO(g)(l)(i)] 0 Injury; [68.1 O(g)(J )(ii)] or, 0 Response or restoration activities for an exposure of an environmental receptor: [68.1 O(g)(J )(iii)] and 0 The distance to a toxic or flammable endpoint for a worst-case release assessment conducted under subpart B and 68.25 is less than the distance to any public receptor, as defined in ~68.3 [68.10(g)(2)] ; and D Emergency response procedures have been coordinated between the stationary source and local emergency planning and response organizations [68. I O(g)(3)l 8. Does the covered process meet the el igibi lity requirements of Program 3? Specifically: [68.IO(i)] D The process does not meet the eligibility requirements of Program 1. [68.lO(i)]; and ~ ON ON/A Js the covered process any of the following NA JCS codes: [68. IO(i)(J )] }?/ 32211,3241 l ,3251 1, 325181 , 325188, 325192,3 25199, 325211 , 325311 ,or32532;or 0 Is the process subject to the OSHA process safety management standard, 29 CFR 1910.119? [68.10(i)(2)] 9. Does the covered process fail to meet the eligibility requirements of Program 1 and Program 3 (i.e., is the covered process a Progran1 2)? [68. IO(h)] DY ON ~/A General: Management [68.15] Has the owner or operator: 10. Developed a management system to oversee the implementation of the risk management program elements? [68.15(a)] 11. Assig11ed a qualified person or position that has the overall responsibility for the development, implementation, and integration of the risk management progran1 elements? [68.15(b)] 12. Documented other persons responsible for implementing individual requirements of the risk management program and defined the lines of authority through an organization chart or similar document? [68.15(c)) ~ ON ON/A DY ) NON/A - DY %N ON/A Subpart B - Hazard Assessment [68.20-68.42] Hazard assessment con ducted and documented as provided in 40 CFR 68.20-68.42? Comments: Page 3of19 Rev 01/07/202 1 RMP Program Level 3 Process Checklist Facility Name: HudsonviJle Creamer y & I~ llaz:ai-d c\ssessment: Offs ite consequence analysis parameters j68.221 J. UscJ lhe following endpoints J(Jr olTs ite consequence anal) :-ii:> for <1 \;\orst-CJ."'e scenario: 168.22(a)I ~For toxics: the endpoints pro\'idcd in Appendix A nf 40 CFR Part 68'! l68.22(a)(l)] 'y}v ON O N/!\ D For fl am mables: an explosion resu lt ing in an overpressure of I psi ? 168.22(a)(2)(i)l; or D For tlam1m1bks : a fire result ing in a radiant heat/ e-.;posure of 5 b\ Im ~ for 40 seconds? l68.22( a)( 2)(ii)] 0 for flammables: a concentration n::sulting in a lower tlammability limit, as provided in NFPA documems or other generally recognized sources? [68.22(a)(2)(iii)] 2. Used the following endpoints for offsite consequence analysis for an alternative release scenario: [68.22(a)] ~ For tox ics : the endpoints provided in Appendix A of 40 CFR Part 68? [68.22(a)(l)] ~ ON ON/A D For flammables: an explosion resulting in an overpressure of 1 psi? [68.22(a)(2)(i)] D For flammables: a fire resulting in a radiant heat/ex posure of 5 bv/m2 for 40 seconds? f68.22(a)(2)(ii)] D For flammables: a concentration resulting in a lower flammability limit, as provided in NFPA documents or other generally recognized sources? (68.22(a)(2)(iii)] 3. Used appropriate wind speeds and stability classes for the release analysis? [68.22(b)] ;bv ON ON/A 4. Used appropriate ambient temperature and humidity values for the release analysis? [68.22(c)] 5. Used appropriate values for the height of the release for the release analysis? [68.22(d)] 6. Used appropriate surface roughness values for the release analysis? [68.22(e)] , ~ ~ ~ ON ON/A ON ON/A ON ON/A 7. Do tables and models, used for dispersion analysis of toxic substances, appropriately account for dense or neutrally buoyant gases? [68.22(f)] DY ON ON/A 8. Were liquids, other than gases liquefied by refrigeration only, considered to be released at the highest daily maximum temperature, based on data for the previous three years appropriate for a stationary source, or at process temperature, whichever is higher? L68.22(g)] DY ON~/A ) Hazard Assessment: Worst-case release scenario analysis [68.25J 9. Analyzed and reported in the RMP one worst-case release scenario estimated to create the greatest distance to an endpoint resulting from an accidental release of a regulated toxic substance from covered processes under worstcase conditions? [68.25(a)(2)(i)] l 0. Analyzed and reported in the RMP one worst-case release scenario estimated to create the greatest distance to an endpoint resulting from an accidental release of a regulated flammable substance from covered processes under worst-case conditions? [68.25(a)(2)(ii)] M DY O N /A DY ON ~IA I I . Analyzed and reported in the RMP additional worst-case release scenarios for a hazard class if the worst-case release from another covered process at the stationary source potentially affects public receptors different from those potentially affected by the worst-case release scenari o developed under 68.25(a)(2)(i) or 68.25(a)(2)(ii)? [68.25(a)(2)(i ii)] DY p I \ 12. Has the owner or operator determined the worst-case release quantity to be the greater of the fo llow ing: r68.25(b)] DY D If released fro m a vessel, the greatest amount held in a singl e vesseL taking into acco unt ad mini strative controls that limit the maximum quantity? f68.25 (b)(J)] 9 D If released from a pipe. the greatest amount he ld in the pipe. taking into account administrative controls that ~ limit the maximum quantity? [68.25(b)(2)J - /\ A,... - y ~~/ c7~~ ~( 0.~ ON EJN/A ON ON/A Page 4 of 19 Rev 01/07/202 1 RMP Program Level 3 Process C hecklist Facility Na me: H udsonville C ream~ry &_I_~--- ! 3.a. l L.is lhe O\Vncr ()f o pcralor l 1)r lo ,i..: suhstallL<.:S rhdl 0 ar..: nonn:.ilh S!.J SC:-. <L( cllllhicm t-:mrcr~!lure Clnd han<l kd JS a ~J:"> ,,r i 1yuiJ undl'.r pressurl'.: 13.a.( J) Assumed the \vhok quantity in till.: vessd o r pipe vvould bl'. rekased as a gas OYl'.r I0 minutes? j 68.25(c)( I )j ON ONi .A I3.a.(2) Assumed the rekase rate to be the total quantity divid ed by I0, if there arc no passi ve m itigaLio n systems in place? [68.25(c)( I)] O N O N /1\ 13 .b. Has the owner or operator fo r toxic gases handkd as refrigerated liquids :it ambient pressure: 13.b.(1) Asswned the substance would be rel eased as a gas in l 0 minutes, if not contained by passive mitigation systems or ifthe contained pool would have a depth of l cm or less? [68.25(c)(2)(i)] 13.b.(2) If released substance would be contained by passive mitigation systems in a pool with a depth > l cm ; 0 Assumed the quantity in the vessel or pipe (as determined per 68 .25(b)) would be spilled instantaneously to form a liquid pool? [68.25(c)(2)(ii)] 0 Calculated the volatility rate at the boiling point of the substance and at the conditions specified in 68.25(d)? (68.25(c)(2)(ii)] DY ON ON/A DY ON ON/A 13.c. Has the owner or operator for toxic substances that are nom1ally liquids at ambient temperature: 13.c.(1) Assumed the quantity in the vessel or pipe would be spilled instantaneously to fo1m a liquid pool? [68.25(d)(l)] DY ON ON/A 13.c.(2) Detem1ined the surface area of the pool by assuming that the liquid spreads to I cm deep, if there is no passive mitigation system in place that would serve to contain the spill and limit the surface area, or if passive mitigation is in place, was the surface area of the contained liquid used to calculate the volatilization rate? [68.25(d)(l )(i)] DY ON ON/A 13.c.(3) Taken into account the actual surface characteristics, if the release would occur onto a surface that is not paved DY ON ON/A or smooth? (68.25(d)( l)(ii)] 13.c.(4) Determined the volatilization rate by accounting for the highest daily maximum temperature in the past three DY ON ON/A years, the temperature of the substance in the vessel, and the concentration of the substance if the liquid spilled is a mixture or solution? [68.25(d)(2)] 13.c.(5) Determined the rate ofrelease to air from the volatilization rate of the liquid pool? [68.25(d)(3)] DY 13.c.(6) Detem1ined the rate of release to air by using the methodology in the RMP Offsite Consequence Analysis Guidance, any other publicly available techniques that account for the modeling conditions and are recognized ,, by industry as applicable as part of current practices, or proprietary models that account for the modeling conditions may be used provided the owner or operator allows the implementing agency access to the model and describes model features and differences from publicly available models to local emergency planners upon request? [68.25(d)(3)] ON ON/A ON ON/A What modeling technique did the owner or operator use? [68.25(g)] 13.d. Has the owner or operator for flammable gases: 13.d.(l) Assumed the quantity in a vessel(s) of flammable gas held as a gas or liquid under pressure is released as a gas over 10 minutes resulting in a vapor cloud ex pl osion? [68.25(e)( I )] 13.d.(2) For gas handled as refrigerated liquid that is not contained by passive mitigation systems. assumed the total quanti ty in a vessel(s) of refrigerated liquid is released as a gas over 10 minutes resulting in a vapor cloud explosion? [68.25(e)(2)(i)] 13.d.(3) For gas handled as refrigerated liquid released to a contained area, ass umed the quantity volatilized in 10 minutes results in a vapor cloud? l68.25 (e)(2)(i i)I DY -~ ~ O~/A ON ON/A ON ON/A Page 5 of 19 Re v 01 /07/2021 RMP Program Level 3 Process Checklist Faci lity Name: HudsonvilJe Creamery & 1~ JJ.J.(4) Ass umed a yield fo cror nf 10~~ of rhc availJ.hk cncrg; i::. rck:bc d in the c\.rlo:-.itin for determining the di:-.1ancc ,_~ y u N [J ~ / . \ to the explosion endpoint_ if the modd usi.:::d is based on TNT-cquivalcm method.->? !68.25(c)I 13.e. J-la-..; the O\vner or operator for flammable l i~uid s: I 3.e.( I ) Assumed the entire quantity in the vessel or pipe. taking into accoum administrative controls that lim it the maximum quantity. would be spilled instantaneously to form a li quid pool? 168.25(f)(J )1 DY O N O N /.I\ I 3.e.(2) For liquids at temperatures below their atmos pheri c bo iling point. calculated rhc vo latility rate at the boiling point of the substance and at the conditions specified in 68.25(d) and a:>sumed that the quantity which becomes vapor in the first I 0 minutes is involved in the vapor cloud explosion ? r68 .25(t)(l)-(2)) DY ON O N/A 13 .e.(3) Assumed a yield factor of 10% of the available energy is released in the explosion for determining the distance to the explosion endpoint, if the model used is based on TNT-equivalent methods? [68.25(f)J DY ON ON/A 14. Used the parameters defined in 68.22 to detem1ine distance to the endpoints? j68.25(g)] DY O N ON/A 15. Detennined the rate of release to air by using the methodology in the RMP Offsite Consequence Analysis Guidance, DY ON ON/A any other publicly available techniques that account for the modeling conditions and are recognized by industry as applicable as part of current practices, or proprietary models that account for the modeling conditions may be used provided the owner or operator allows the implementing agency access to the model and describes model features and differences from publicly available models to local emergency planners upon request? [68.25(g)] What modeling technique did the owner or operator use? [68.25(g)] 16. Ensured that the passive mitigation system, if considered, is capable of withstanding the release event triggering the DY ON ON/A scenario and will still function as intended? [68.25(h)] 17. Considered also the following factors in selecting the worst-case release scenarios: [68.25(i)] D Smaller quantities handled at higher process temperature or pressure? [68.25(i)(l)] D Proximity to the boundary of the stationary source? [68.25(i)(2)] DY ON ON/A Hazard Assessment: Alternative release scenario analysis [68.28] 18. Identified and analyzed at least one alternative release scei1ario for each regulated toxic substance held in a covered ~y process(es) and at least one alternative release scenario to represent all flammable substances held in covered / processes? [68.28(a)] ON ON/A 19. Selected a scenario: [68.28(b)] D That is more likely to occur than the worst-case release scenario under 68.25? [68.28(b)(l)(i)] Jv ON ON/A D That will reach an endpoint off-site, unless no such scenario exists? [68.28(b)( I )(ii)] 20. Considered release scenarios which included, but are not limited to, the following: [68.28(b)(2)] 0 Transfer hose releases due to splits or sudden hose uncoupling? f68.28(b)(2)(i)] / 1bv ON ON/A 0 Process piping releases from fa ilures at flanges, joints, welds, valves and valve seals, and drains or bleeds? [68.28 (b)(2)( ii)l 0 Process vessel or pump releases due to cracks, seal fa ilure, or drain, bleed, or plug failure? [68.28(b)(2)(iii)] ~ Vessel overfilling and spill, or overpressurization and venting thro ugh relief valves or rupture dis.ks? [68.28 (b )(2)( iv)] 0 Shipping contai ner mishandling and breakage or puncturing leading to a spill? [68.28(b)(2)(v)] 21. Used the parameters defined in 68.22 to determine distance to the i.::ndpoints? [68.28(c)] jgy ......... ON ON/A Page 6 of 19 Rev OJ /07/202 l RM P Program Level 3 Process C hecklist F aci lity Na m e : Hudso nv ille C ream ery & I~ 22. Determined th e ra re o f rekase LO air hy usi ng thc rn dhoJology in the RM P Offsi tc Co nsc4uc11cc t\n a l ysi~ (lui dancc, any other publicly availabk kc hni qucs that accoun t f()r the model ing conditions and a rc' rc..:co1,!.n izeJ by induslry as applicah le as pan o r cu rren t practices. or propridary model s that account fo r Lhe modd ing con di tions may be used provided the owner Pr opaato r allows the im plementing age ncy access to the model and describes model fra1we~ and differences from publ ic ly arni Iabl e models to local emergency pl aimers upon requ est? [68 .28(c)I What modeling teclu1ique did the owner or operator use? [68.25(g) J 23 . Ens ured that the pass ive anJ activ e mi tigation systems, if considered, are capabl e of withstanding the release event triggering the scenario and will be func tional ? l68.28(d)J Y GN LJ1\J :\ O N O N/A 24. Considered the following factors in selecting the alternative release scenarios: [68.28(e)] D The five-year accident history provided in 68.42? [68.28(e)(l)] Failure scenarios identified under 68.50? l68.28(e)(2)] ON ON/A Hazard Assessment: Defining off-site impacts-Population [68.30J 25. Estimated population that would be included within a circle where its center is the point of the relea<;e and a radius determined by the distance to the endpoint? f68.30(a)] 26. Identified the presence of institutions, parks and recreational areas, major commercial , office, and industrial buildings in the RMP? [68.30(b)] 27. Used most recent Census data, or other updated information to estimate the population? [68.30(c)] 28. Estimated the population to two significant digits? [68.30(d)] Hazard Assessment: Defining off-site impacts-Environment [68:33] 29. Identified environmental receptors within a circle where its center is the point of the release and a radius determined by the distance to the endpoint? [68.33(a)] 30. Relied on information provided on local U.S .G.S . maps, or on any data source containing U.S.G.S. data to identify environmental receptors? [Source may have used LandView to obtain information] [68.33(b)] 7 L. l1v @;[ -- ~y ON O N/A -- ON/A - ON/A -- ON/A O N /A ON/A Hazard Assessment: Review and update [68.36] 31. Reviewed and updated the off-site consequence analyses at least once every five years? [68.36(a)] 32. Completed a revised analysis and submit a revised RMP within six months of a change in processes, quantities DY stored or handled, or any other aspect that might reasonably be expected to increase or decrease the distance to the endpoint by a factor ofn;vo or more? [68.36(b)] Hazard Assessment: Documentation [68.39) 33. Has the owner or operator maintained the followin g records on the offsite consequence analy ses: l 33.a For worst-case scenarios: a description of the vess r i eline and substance selected assumptions and y parameters used, the rational e for selection. and anticipated e ect of the administrative controls andj)aSsive mitigation on the release quantity and rate? f68.39(a)] -1 I 33.b For alternative release scenarios : a description of the scenarios identifi ed, assumptions and parameters used, the ~ rationale for the selection of specifi c scenarios, and anticipated effect of the administrative controls and _9 /\J mitigation on the release quanti ty and rate? [68.39(b)] 33.c Documentation of estimated quan tity released, rel ease rate, ai1d duration ofrel ease? f68.39 (c)] 33.d Methodol ogy used to determine distance to endpoints? [68.39(d)] ON ON/A ON ON/A O N O N/A O N O N/A O N ON/A O N ON/A Page 7of 19 Rev Ol /07/202 I RMP Program Level 3 Process Checklist Facility Name: HudsonviHe Creamery & I~ ..\ )_...: i)ata usc:d tP c:s timalc ptipu lati1rn and cmininment.il receptors pol~ntiul l y aft~ ctc:<l'.' 168.J9(c)j Hazard Assessment: Five-year accident history 168.421 34. l-:las the owner or operator included all accidental releases from covered processes that resulted in deaths, injuries. or signific:int property damage on site. or known offsite deaths. injuries. evacuations, sheltering in place. property damage. or environmental damage? f68.42(a)'I 33. Has ihe owner or operator reported the following information for each accidental release: f68.42(b)] 0 Date, time, and approximate duration of the release? [68.42(b)(l)] 0 Chernical(s) released? [68.42(b)(2)] 0 Estimated quantity released in pounds and percentage weight in a mixture (toxics)? [68.42(b)(3)] 0 NAICS code for the process? [68.42(b)(4)] 0 The type ofrelease event and its source? [68.42(b)(5)] 0 Weather conditions (if known)? [68.42(b)(6)] 0 On-site impacts? l68.42(b)(7)] 0 Known offsite impacts? [68.42(b)(8)] 0 Initiating event and contributing factors (if known)? [68.42(b)(9)] 0 Whether offsite responders were notified (if known)? [68.42(b)(I 0)) 0 Operational or process changes that resulted from investigation of the release? l68.42(b)(l 1)] =.J N L, N//\ O N O N/A ON ON/A Subpart D - Program 3 Prevention Program [68.65-68.87) Implemented the Program 3 prevention requirements as provided in 40 CFR 68.48 - 68.60? Comments: Prevention Program: Process safety information l68.65) 1. Has the owner or operator compiled written process safety information, which includes information pe1iaining to the hazards of the regulated substances used or produced by the process, information pertaining to the technology of the process, and information pe1taining to the equipment in the process, before conducting any process hazard analysis required by the rule? [68.65(a)] Does the process safety infonnation contain the following for hazards of the substances: [68.65(b)] \r;:;l /\[ \tJ ~ ~ 1J )q ;:Ji!1 Toxicity information? [68.65(b)(1 )] Permissible exposure limits? [68.65(b)(2)] Physical data? [68.65(b)(3)] Reactivity data? (68.65 (b)(4)J Corrosivity data? [68.65(b)(5)] Thermal and chemical stability data? [68.65(b)(6)] Hazardous effects of inadvertent mixing of materials that could foreseeably occur? [68.65(b)(7)] Note: Safety Data Sheets (SDS) meeting the requirements of the OSHA Hazard Communication Standard [29 CFR 1910.J200(g)] may be used to comply with this requirement to the extent they contain the info1mation required by 68.65(b). Y ON ON/A Page'. 8 of J9 Rev 0J 107/202 l R!\1P Program Levei J Process Checklist Faci lity Name: HudsonviJle Creamery & I~ -~~~~--=~~~~~~ D<lC:\ th e pnK...:ss 'Jkt-: info nnali\ 1n co ntain inkirm<1tion p<::n:1ining Lo Lcchnnlog_y of the process 168.65(cll? LlY 'PNON/;\ D<H:'.:i th e intixrn ation concerni ng the technology of the process include the fo llowing: r68.65(c)(l)J ~loc k lhnv diagram or simplified process flow Jiagram ? j68.65(c)( l )(i)J ~oces:-> chem istry? 168.65(c)( l)(ii)I 'LJ../"l'vhximum int-:.-nded imen tory? l68. 65(c)(l)(iii)I ~ Safe uppa and lmv<::T limits for such ite ms as temperatu res, press ures, flows , or compositions? [68.65(c)( I )(iv)] ~ An evaluation of the consequences of deviation? [68.65(c)(l)(iv)] - i 3. Does the process safety information contain information pertaining to the equipment in the process? [68.65(d)] Does the infonnation pertaining to the equipment in the process include the following: 168.65(d)(l)] ~ Materials of construction? 68.65(d)(l)(i)J ~ Piping and instrumentation diagrams [68.65(d)(l)(ii)] DY ~ Q.-- Electrical classification? [68.65(d)( t)(iii)] R5 Relief system design and design basis? [68.65(d)(l )(iv)] .'!( Ventilation system design? [68.65(d)(l )(v)] ~ Design codes and standards employed? [68.65(d)(l)(vi)] +-r e.st/ ~ Material and energy balances for processes built after .Tune 21, 199~(d)(l)(vii)] )<ti Safety systems? [68.65(d)(l)(viii)] -N 0. (;J ! J.-.!,'/:/:Ve!... I 1.,k .f.J ~ -~4<!. 4. Has the owner or operator documented that equipment complies with recognized and generally accepted good engineering practices? [68.65(d)(2)] I ~ ON O N /A ON/A 5. Has the owner or operator determined and documented that existing equipment, designed and constructed in ~y ON ON/A accordance with codes, standards, or practices that are no longer in general use, is designed, maintained, inspected, tested, and operating in a safe manner? [68.65(d)(3)] Prevention Program: Process hazard analysis [68.67] 6. Has the owner or operator performed an initial process hazard analysis (PHA), and has this analysis identified, evaluated, and controlled the hazards involved in the process? [68.67(a)] I DY ON ON/A 7. Has the owner or operator determined and documented the priority order for conducting PHAs, and was it based on I DY ON ON/A an appropriate rationale? [68.67(a)] 8. Has the owner used one or more of the following teclu1ologies to conduct process PHA: [68.67(b)] ~ What-if? l68.67(b)(l)] IM ON ON/A D Checklist? [68.67(b)(2)] ~ What-i f/Ch ecklist? [68.67(b)(3)) D Hazard and Operability Study (HAZOP) [68.67(b)(4)l D Failure Mode and Effects Analysis (FMEA) [68.67(b)(5)] D Fault Tree Analysis? [68.67(b)(6}1 D An appro priate equivalent methodology? 168.67(b)(7)] Page 9of 19 Rev 0 l/07/202 I RM P Prog.-am Leve l J Process CheckJist Facility Name: Hudsonville Creamery & l~ '-J l)iJ tlk Pl I\ aJJrcs:-. : ~T he ha:;ard s 0f the prt)ccs<.) I68.6 7( c)( J) I ~ fdc ntification or any inciJ~rn that had a likely pOlcntial for calastrophic consequences ? j68.67(c)(2)) X' Engineering mid ad ministrati\e controls appli cable to ha zards and inkrrcJationships?[68.67(c)(3)] /<3y 1_J N )ii/ (\1ns1..'q uences of fail ure 1.)f engineeri ng and aJministrative controls'! j68.67(c)(4)] Jsi:/ Station a ry source s iting? j68.67(c)(5JJ ~ Human factors? [68.67(c)(6)] ~ A qualitati ve evaluation of a range of the possible safety and health effects of failure of controls? [68.67(c)(7)] 10. Was the PHA performed by a team with expertise in engineering and process operations and did the team include at least one employee who bas experience and knowledge specific to the process being evaluated and at least one member of the team who is knowledgeable in the specific process hazard analysis methodology being used?? [68.67(d)) 11. Has the O\vner or operator completed the following: [68.67(e)] ~ Established a system to promptly address the team's findings and recommendations? ~ Assured that the recommendations are resolved in a timely manner and documented? ~y DY ON -4 D Documented what actions are to be taken? D Completed actions as soon as possible? _D Developed a written schedule of when these actions are to be completed? and ~ Communicated the actions to operating, maintenance, and other employees whose work assignments are in the process and who may be affected by the recommendations? 12. Has the PHA been updated and revalidated by a team every five years after the completion of the initial PHA to assme that the PHA is consistent with the current process? [68.67(f)] DY ~N 13 . Has the owner or operator retained PHAs and updates or revalidations for each process covered, as well as the resolution of recommendations for the life of the process? [68.67(g)] DY ~ O N /.A ON/A ON/A ON/A ON/A Prevention Program: Operating procedures [68.69} 14. Has the owner or operator developed and implemented written operating procedures that provide instructions or steps for conducting activities associated with each covered process consistent with the safety information? [68.69(a)] ON ON/A Page JO oC 19 Rev 01107/2021 RM P Program Leve l 3 Process C hecklist Fac ility Name : ~~-~honv~IJ e (~rcamery & l'tt i ). i )o 'h-: r1mccuurl..'.::- <.1JJrcs::- th ..: iu!!\) \\ ing. j{1.X .<i9(.1 i J Stcrs f"nr each o oe raling pha;)-: : l b8 .69(al( l ) I " ry Init ial ~tanup? j68.69(a)( I )(i)j fl \j 1 rL7 \, Nnrm a l (lpe rations? 168 .69(a)( !)( ii)) Tc rnpl)rcH)' o pc:rati o ns) 1_68. 6C)((a)( 1)(iii )! E mergency s hui down inc ludin g the conditions under wh ich eme rgency shu Ldown is requ ired, and the ass ignment of shuidown responsibility to quali fied operators to ensure th at emergency shutdown is executed in a safe and timely manner? [68.69(a)( 1)(iv)] '/J Emergency operations? [68 .69(a )(l)(v)] 'VJ1 ' [[] Norm al shutdown? r68 .68(a)( I )(vi)J ~ Startup following a ttrrnaround, or after emergency shutdown? Operating limit~: [68.69(a)(2)] 'V Consequences of devi ations I68.69(a)(2)(i)] r} Steps required to coJTect or avoid deviati on? [68.69(a)(2)(ii)] [68 .69(a)( 1)(v ii )] ~ ~ D~/1\ Safety and health considerations: [68.69Ca)(3)] V1'.J Properties ot~ and physical hazards presented by, the chemicals used in the process [68.69(a)(3)(i)] l,EJ Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment? [68.69(a)(3)(ii)] \zJ Control measures to be taken if physical contact or airborne exposure occurs? [68.69(a)(3)(iii)] l\;J' Quality control for raw materials and control of hazardous chemical inventory levels? [68.69(a)(3)(iv)] 0l Any special or unique hazards? [68.69(a)(3)(v)] ~ Safety systems and their functions? [68.69(a)(4)] .-0\fo f""1<:+,C-f.; ~ e,c(d/~. 16. Are operat\ng procedures readily accessible to employees who are involved in a process? [68.69(b)] l:( 17. Has the owner or operator certified annually that the operating procedures are current and accurate and that procedures have been reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to stationary sources? [68 .69(c)] - h DY bN ON/A DY ON/A 18. Has the owner or operator developed and implemented safe work practices to provide for the control of hazards during specific operations, such as lockouUtagout; confined space entry; opening process eq~ipment or piping; and control over entrance into a stationary source by maintenance, contractor, laboratory , or other support personnel? [68 .69 (d )) DY~ ON/A Preven tion Program: Training l68.71] 19. Has each employee involved in operating a process, and each employee before being involved in operating a newly assigned process, been initi ally trained in an overview of the process and in the operating procedures? [68.7l(a)(1)] 20. Did initial training include emphasis on safety and health hazards, emergency operati ons including shutdown, and safe work practi ces applicabl e to the employee's jo b tas ks? 168.71 (a)( I)] 21 . Jn lieu of ini tial training for those employees already involved in operati ng a process on Ju ne 21, 1999, an owner or operato r may ce rtify in wri ting that the employee has the requi red knowledge, slcills, and abi lities to safely carry out the duties and responsi bil ities as specifi ed in the operating procedures r68. 7 l (a)(2)] ov-f ON/A DY ~ O N/A D Y /.9q ON/A Page I J of 19 Rev 0 1/ 07/2021 RMP Program Level 3 Process Checkl is t Facility Name: Hudsonv ille C reamery & ]~ 22. I l:is refres her trai n1 ng hccn prm idcJ Jl k:a:-.l 1..'h:l".] i.hr..:e; Gih. nr lTH 1rc.: (ilkn if nccc:-.:--.1r;. [,) cJch cmplu}' cc.: involved in operating a process to as:-.ure that the cmplu: cc unJcrstanJs and adheres lll the current npcrm ing procedu res o f th e proccs:;? 168 .7l(h) I 23 . Has owner o r opera tor ascertained and docu mented in record that each e mrloy ee involved in operm in g a process has received and understood the training required? 168. 7 l (c) j 14. Does the pr~:pareJ record contain the identity of the employee:. the date of the training. and the means used lover~ that the empl oyee understood the training? 168. 7J(c) J ' : -_.'I ~~ L.-::;N11\ D Y ~N ON/A DY N O N//\ Prevention Program: Mechanical integrity 168. 73] 25. Has the owner or operator establi shed and implemented written procedures to maintain the on-going integrity of the process equipment li sted in 68. 73(a)? r68 .73(b)] 26. Has the owner or operator trained each employee involved in maintaining the on-going integrity of process _;!) equipment? [68.73(c)] N~ C>.!f\tce-... 27. Has the owner or operator perfom1 ed inspections and tests on process equipment? [68.73(d)( J)1 } I. 28. Has the owner or operator followed recognized and generally accepted good <;ngineering P.ractices for inspections and testing procedures? [68.73(d)(2)) J\<:a/- ctc, (;>l-\6.,>( l ( ::J. f7' l{-S11'7.SJ:- tph..~ ( 29. Has the owner or operator ensured the frequency of inspections and tests of process equipment is consistent with applicable manufacturers' recommendations, good engineering Pfacticp, and prior operating experience? [68.73(d)(3)] /'to ft'~~ ,~ ~1--l~~ J 30. Has the owner or operator documented each inspection and test that h<)d been perfonned on process equipment, and identified the following: [68.73(d)(4)] <PrV" l_o I f-/PA~ ~- ~ The date of the inspection or test? .Q The name of the person who performed the inspection or test? {;:II The serial number or other identifier of the equipment on which the inspection or test was performed? .,0 A description of the inspection or test perfonned? and . v Tbe results of the inspection or test? DY ! / ON/A DY ~ ON/A ~)" ' ~ ON/A DY ~ ON/A DY rfjN ON/A ~y r ON/A rJyJ:- <I(?_<?I "} (/!>~ V<...r7 c.1-1 31. Has the owner or operator corrected deficiencies in equipment that were outside acceptable limits defined by the process safety infonnation before further use or in a safe and timely manner when necessary means were taken to assure safe operation? [68.73 (e)] DY O N _$NIA 32. Has the owner or operator assured that equipment as it was fabricated is suitable for the process application for which it will be used in the construction of new plants and equipment? f68.73(f)(l)] ON ON/A 33 . Has the owner or operator perfonned appropriate checks and inspections to assure that equipment was installe properly and consistent with design specifications and the manufacturer's instructions? [68. 73(f)(2)] 34. Has the owner or operator assured that maintenance materials, spare parts and equipment were suitable for the process application for which they would be used? [68.73 (f)(3)] Prevention Program: Management of change l68. 75] ON ON/A ON ON/A 35. Has the O\;..;ner or operator established and implemented written procedmes to manage changes to process chemicals, I DY technology, equipment, and procedures, and changes to stationary sources that affect a covered process? [68.75(a)] ON ON/A Page 12of19 Rev 0 1/07/2021 RM P Program Level 3 Process C hecklist F'acility Name : Hudsonvi~_:5reamcry & J~ 36. Do p rocedu res assure that rhc fo llmv i11g consiJcraiion:; circ ~1ddrc.-.::-cd pri11r 10 J.ny ...:hJngc: !oX. 7.:'i(bij c;Y The technical basis for rhe proposed ch3nge? 168.75\ b)( 1)1 yv L. J'\i jZl Jn1pact of change on sakty and health? l68.75(b)(2)l ~ Modifications to operating procedures? 168.75(b)(3)1 B Necessary time period fo r the change? f68 .75( b)(-+JJ D ~ Authori zation requirements 1(J r the proposed change? [68 .75(b)(5)l 37. Were employees, involved in operating a process and maintenance, and contract employees. whose job tasks would be affected by a change in the process, infonned ot: and trained in , the change prior to start-up of the process or affected parts of the process? [68.75(c)] 38. If a change resulted in a change in the process safety infomrntion. was such information updated accordingly? l68.75(d)] 39. If a change resulted in a change in the operating procedures or practices. had such procedures or practices been updated accordingly? [68.75(e)] ~ ON DY ~ DY~ '....~ ,\i ; ON/A ON/A ON/A Prevention Program: Pre-startup safety review [68.77J 40. Has the owner or operator perfom1ed a pre-startup safety review for new stationary sources and for modified stationary sources when the modification is significant enough to require a change in the process safety information? [68.77(a)] y ON ON/A 41. Does the pre-startup safety review confinn the following prior to the introduction of a regulated substance to a process: [68.77(b)] DY~ D Construction and equipment was in accordance with design specifications? [68.77(b)(l)] 0 Safety, operating, maintenance, and emergency procedures were in place and were adequate? [68.77(b)(2)] 0 For new stationary sources, a process hazard analysis had been performed and recommendations had been resolved or implemented before startup? [68. 77(b)(3)] D Modified stationary sources meet the requirements contained in management of change? [68.77(b)(3)] ~ Training of each employee involved in operating a process had been completed? [68.77(b)(4)] f\Ao(_ i_(f4l --( O N /A Prevention P rogram: Compliance audits [68.79] 42. Has the owner or operator certified that the stationary source has evaluated compliance with the provisions of the prevention program at least every three years to verify that the developed procedures and practices are adequate and being followed? [68.79(a)] y ON ON/A 43. Has the audit been conducted by at least one person knowledgeable in the process? [68.79(b)] 44. Are the audit findings documented in a repo1i? [68.79(c)] --S..'fY'..Q..d~ U ~ (f)-~v o( / 45 . Has the owner or operator promptly detem1ined and documented an appropriate response to each of the findings of the audit and documented that deficiencies had been corrected? [68.79(d)] 46. Has the owner or operator retained the two most recent compliance repo1ts? [68.79(e)] y ON ON/A ON ON/A 'f ON/A ON ON/A Prevention Program: Incident investigation [68.81] 47. Has the owner or operator investigated each incident that resulted in, or could reasonably have resulted in a catastrophic release ofa regulated subs~an ce? [68 .81(a)J DY O N IA Page l3of1 9 Rev 01 /07/2021 R1'\t1 P Program Level 3 Process Checklist Facility Name: HudsonvilJe C ream ery & I~ 48. W..:, re al l incident investigations initiated not later th an 48 h\>urs foll owing the inc iJem? 168.:\ l (b)j DY 49. Was an ~ccident i~vcsti~atio n team established a?d diJ_ it ~onsi~t of at kast one ~ason kno wkdgeabk in the ~y process mvolved, mcludmg a co ntract employee 1f the 1nc1dent involved work ot a contractor, and other pasons with appropriate knowledge and experience to thoroughly investigate and analyze the incident? f68 .8l(c) I C >>J ~/;\ ON ON//1 50. Was a report pn.:pared at the conclusion of every inwstigation? l68.8l (d)l D Y O N _AJ NIA 51. Does every report include: 168.8J (d)I 0 Date of incident? [68.8J(d)(l)] 0 Date investigation began? (68.81 (d)(2)] 0 A description of the incident? (68.8l (d)(3)) 0 The factors that contributed to the incident? [68.8l(d)(4)] 0 Any recommendations resulting from the investigation? [68.8l(d)(5)] D Y O N )/JN/A 52. Has the owner or operator established a system to promptly address and resolve the incident report findings and recommendations; and are the.resolutions and corrective actions documented? [68.8J(e)] DY O N }JJ N/A 53. Was the report reviewed with all affected personnel whose job tasks are relevant to the incident findings including contract employees where applicable? [68.8l(f)] 54. Has the owner or operator retained incident investigation reports for at least five years? [68.81(g)] DY -~ ON )4'N IA ON ON/A Prevention Program: Employee participation 168.83) 55. Has the owner or operator developed a written plan of action regarding the implementation of the employee participation required by this section? [68.83(a)] 56. Has the owner or operator consulted with employees and their representatives on the conduct and development of process hazards analyses and on the development of the other elements of process safety management in chemical accident prevention provisions? [68.83(b)] ~y ON ON/A ;By ON ON/A 57. Has the owner or operator provided to employees and their representatives access to process hazards analyses and to-hlJ.Y all other information required to be developed under the chemical accident prevention rule? [68.83(c)] ILJ ON ON/A Prevention Program: Hot work permit (68.85) 58. Has the owner or operator issued a hot work permit for each hot work operation conducted on or near a covered process? [68.85(a)] 59. Does the permit document that the fire prevention and protection requirements in 29CFR 1910.252(a) have been implemented prior to beginning the hot work operations? [68.85(b)) 60. Does the permit indicate the date(s) authorized for hot work and the object(s) upon which hot work is to be performed? [68.85(b)] 61. Are the pennits being kept on file until completion of the hot work operations? [68.85(b)] Prevention Program: Contractors [68.87} 62. Has the owner or operator obtained and evaluated information regarding the contract owner or operator's safety perfonnance and programs when selecting a contractor? [68.87(b)(1)) 63. Has the owner or operator informed contract owner or operator of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process? l68.87(b)(2)] ~y ~ -- rby -- -~y ----- ~ ON ON/A ON ON/A ON ON/A ON ON/A ON ON/A L ON ON/A Page l4 of 19 Re, 0l 107/2021 RM P Program Level 3 Process Checklist F acility Name: HudsonviHe Creamery & l<t'.j 6-L JlJs ihc O\>\ner 1lr operator e-xplaincu to th t: con tract o wner o r opa~Hor [he applic<.1bk provision~ of rhe cmcrgerH.:y respon se or the emergen cy action program ? l68 .87(b)(3) I 65. Has the O \>\ ncr or operato r developed and implemented sa fe work practices con sistent with ~68.69(d), to co ntrol the entrance, prese nce\ anJ exit of the contract owner or operator and contract employees in the covered process areas? 168 .87(b)(4 ) l 66. Periodi cally evalu ated the perfom1;:ince of the co ntract owner or operator in fulfillin g their obl igations (as described at 68.87(c)(1 )-- (c)(5))? r68.87(b)(5 ) 1 ~~ DY )f DY &.; LJ N /J\ O N/A O N/A Subpart E - Emergency Response [68.90 - 68.96) Developed and implemented an emergency response program as provided in 40 CFR 68.90-68.96? Comments: J. ls the fac ility designated as a ..responding stationary source"? DY ,,.qN ON/A La. If the facility is not a responding stationary source, it need not comply with 68.95 if the following conditions are met: La.( l) For stationary sources with any regulated substances held in a process above threshold quantities, is the source included in the commw1ity emergency response plan developed w1der 42 U.S.C. 11003? [68.90(b)(l)] AJY ON ON/A l.a.(2) For stationary sources with only regulated :flammable substances held in a process above threshold quantities, has the owner or operator coordinated response actions with the local fire department? [68.90(b)(2)] l.a(3) l.a.(4) ------- --- Are appropriate mechanisms in place to notify emergency responders when there is need for a response? [68. 90(b)(3 )] As of September 21, 2018, has the owner or operator performed th nual emergency response coordination activities required under 68.93? [68.90(b)(4)] (See Items. througl:i ~ l.a.(5) Has the owner or operator performed the annual notification exercises required under 68.96(a) before December 19, 2024? [68.90(b)(5)] (See Items Q and 1) DY ON ~IA ftJr ON ON/A -- DY ON ON/A DY~ ON/A For non-responding stationary sources where 1.a.(1)-(5) are all marked as 'Y', proceed to Subpart E Item l l .b. If the facility is a responding stationary somce: J.b.(l) Has the owner or operator developed and implemented an emergency response program that includes the elements required in 68.95(a)(l -4)? f68.95(a)] (See Items l.b.(2)- l.b.(5)) ON ON/A l.b.(2). An emergency response plan is maintained at the stationary source and contains the following? [68.95(a)(1 )] ~ Proce?ures for inf~rming th~ public and r:ie appr?priate Federal, statp, and local emer15ency response agencies about accidental releases? [68.9)(a)(1)(1)] ~N?J ~"- ~ '67 <.....L ~, ~ EJ Docwnentation of proper first-aid and emergency medical treatment necessary to treat accidental hwnan exposures? [68.95(a)(l )(ii)l D Procedures and measmes for emergency response after an accidental release of a regulated substance? [68.95(a)(l )(iii)] 1.b.(3) Does the emergency response program contains procedures for the use of emergency response equipment and for its inspection , testing, and maintenance? [68.95(a)(2)] ~N ON/A DY~ ON/A 1.b.(4) Does the emergency response program include training for all employees in relevant procedures? [68.95(a)(3)] ON ON/A l.b.(5) Does the emergency response progran1 include procedures to review and update, as appropriate, the emergency response plan to reflect changes at the stationary source and ensure that employees are info rm ed of changes? l68 .95(a)(4)] ON O N/A Page 15 of 19 Rev 0 l/07/2021 RM P Program Level 3 Process Checkl ist Facility Name : HudsonviJJe Creamery & 1~ I _b_(6) 1.h.(7) -- l .b.(8) rfi v f)<._lCS the cm crgc:ncy rc:-. pon:-.c program include a wriltcn ~' Ian Lhat complies \v i1h other 1:- etkra l comingc:ncy plan,.. rcgulatinns l'r is co nsisknt with the approach in the Nmion al Response Team's Jntegrated Con tingency Plan Clu idance rOne Plan'.) '? Jfso, does the plan include the e lements provided in paragraph (a) of68.9.5 , and also comp lies with paragraph (c) of 68.95 ? r68.95(h)j ? Has the cmergcncy response plan been coordi n~ with the community emergency response plan developed ,r_ undcr EPCRA? !68.9.5(c)! _ 1\1.ei.d tlf/ 2..J, t(! -- --- - - --- - - ---- -- --- --- ---- -- -- -- ------- - - -- - - - - - - - ---- -- ---- ----- ------------ DY -- -- ---- l fa<; the owner or operator devdoped and implemented an exercise program for its emergency res ponse DY program, including the emergency plan required under 68.95(a)(I)? [68.96(b)J O N O NiA ON ON/A ------ ----- -- ---- ON ON/A ] .b.(9) Do the exercises involve facility emergency response personnel and, as appropriate, emergency response contractors? [68.96(b)] ~ '7hfr 2 c.S\..il,J,v /}l~C - l.b.(l 0) When planning emergency response field and tabletop exercises, has the owner or operator coordinated with local public emergency response officials and invite them to participate in the exercise? [68.96(b)] l.b.(11) Does the emergency response exercise program include: [68.96(b)] )rpy ON ON/A DY )GrN ON/A DY ON ON/A 0 Emergency response field exercises? l68.96(b)( l)] 0 Tabletop exercises? 168.96(b)(2)] 0 Documentation? [68.96(b)(3)] 1.b.(12) As part of coordination with local emergency response officials, has the owner or operator consulted with these officials to establish an appropriate frequency for field exercises? [68.96(b)(l)(i)] DY ~ ON/A l.b.(13) Field exercises shall invol ve tests of the source' s emergency response plan, including deployment of emergency DY ON ON/A response personnel and equipment Do field exercises include: [68.96(b)(l)(ii)] 0 Tests of procedures to notify the public and the appropriate Federal, state, and local emergency response agencies about an accidental release? 0 Tests of procedures and measmes for emergency response actions including evacuations and medical treatment? 0 Tests of communications systems? 0 Mobilization of facility emergency response personnel, including contractors, as appropriate? 0 Coordination with local emergency responders? 0 Emergency response equipment deployment? 0 Any other action identified in the emergency response progran1, as appropriate? 1.b.(14) As part of coordination with local emergency response officials, has the owner or operator consulted with these officials to establish an appropriate frequency for tabletop exercises and conducted a tabletop exercise before December 21, 2026 and at a minimum of at least once every three years thereafter? [68.96(b)(2)(i)] 1.b.(15) Tabletop exercises shall involve discussions of the source's emergency response plan. Do the exercises include discussions of: [68.96(b)(2)(ii)] 0 Procedures to notify the public and the appropriate Federal, state, and local emergency response agencies? DY~ ON/A rDY ON/A 0 Procedures and measures for emergency response including evacuations and medical treatment? 0 Identification of facility emergency response personnel and/or contractors and their responsibilities ? 0 Coordination with local emergency responders? 0 Procedures for emergency response equipment deployment? 0 Any other action identifi ed in the emergency response plan, as appropriate? Page 16of19 Rev 01 /07/2021 RM P Program Level 3 Process C hecklis t Facility Name: Hudsonville Creamery & J~ ~~~----"-~~~~~- l _))_; Ih) I !J:'> die t)\\ ncr 1)r nrcr:llnf rrcpJ.rcJ 'u I c: v al uatinn rcp\l.rt \!y j rh j n 90 JJ._v::. u ! C J Ch field ;JJJJ L;.iblctnp exe rcise_ \\ bich included: j68.96(h)(.> )j n A Jcscriptil)fl of the ex ercise sccn ari1) ? D Names and organizations of each participant'.' 0 An evaluation of the exercise: results including lessons learned '! [J Rcco mmc:ndations frlf improvemc:nl or reYision s to the emergency n.:sponsc exercise program and emergency r~spons~ program_ and a schedule 10 prompll) address and n::solve recommenda tion s? I.b.(17) Has the owner or operator satisfied the requirement to conduct notification, field and/or tabletop exercises through alternative means such as: f68 .96(c)] D Exercises conduckd to meet other Federal, state, or local exercise requirements, provided the exercise meets the requirements of paragraphs (a) and/or Cb) of this section, as appropriate. [68.96(c)( l)] D Response to an accidental release, provided the response includes the actions indicated in paragraphs (a) and/or (b) of this section. as appropriate. When used to meet field and/or tabletop exercise requirements, the owner or operator shall prepare an after-action report comparable to the exercise evaluation report re_q1,1ired in paragraph (b)(3) of this section, within 90 days of the incident. [68.96(c)(2)] C~ Y :JN O N/A DY ON ON/A .For all responding and non-responding stationary sources: 2. Has the owner or operator of a stationary source coordinated response needs with local emergency planning and DY response organizations to determine how the stationary source is addressed in the community emergency response plan and to ensure that local response organizations are aware of the regulated substances at the stationary source, their quantities, the risks presented by covered processes, and the resources and capabilities at the stationary source to respond to an accidental release of a regulated substance? [68.93(a)] 3. Has coordination occuned at least annually , and more frequently if necessary, to address changes: At the stationary DY source; in the stationary source's emergency response and/or emergency action plan; and/or in the community emergency response plan? [68.93(a)] 4. Has coordination included providing to the local emergency planning and response organizations? [68.93(b)J DY D The stationary source's emergency response plan if one exists? D Emergency action plan? D Updated emergency contact inforniation? D Other info1111ation necessary for developing and implementing the local emergency response plan? D For responding stationary sources, has facility consulted with local emergency response officials to establish appropriate schedules and plans for field and tabletop exercises required under 68.96(b)? (See Items l.b.(8), Lb.(10), l.b.( 12), and l.b.04)) 5. As of September 21 , 2018, has the owner or operator documented coordination with local authorities, including: DY [68.93(c)] D The names of individuals involved and their contact information (phone number, email address, and organizational affiliarions)? D Dates of coordination activities? D Nature of coordination activi ties? 6. Has the owner or operator of a stationary source with any Program 2 or Program 3 process conducted an exercise of I DY the stationary source's emergency response notification mechanisms before December 19, 2024 and annually thereafter? [68.96(a)J ON ON/A ON ON/A ON ON/A ON ON/A ON ON/A (Owners or operators of responding srntionary sources may perform the notification exercise as part of the tabletop and field exercises) Page 17 of 19 Rev 0 l/07/202 I RM P Prngr-am Level 3 Process Checkl ist Facihty Name: H udsonvme Creamery & I~ --- ---- ' l L..1.:-; lhe O\\fh: ri operawr 111aimc1i11eL1 ;..i. \Hillen r...:co ru vf c.Kh 11llll fi c:.ni1in c>. crci~ c '-:(induLtcJ d\cr 1h.:'. last live years.' '__:y ~jj'\ ~'\).';\ !68 .96 (a)! Su bpart G -Risk Management Plan f40 CfR 68.150-68.1951 Documented a Risk" Managemem Plan as rrov ided in 40 CFR 68 .150-68 . l 95? Co mm ems : l . Does the ::;ingk reg istration fo rm include. fo r each coverc:d process: 168. J6 0(b)(7)l D The name and CAS number of each regulated substance held above the threshold quanti ty in the process? D The ma'l'.imum quamity of each regulated substance or mi xture in the process (in pounds) to t\vo significant digits? D The five- or six-digit NAICS code that most closely conesponds to the process? D The correct program level of the process? rf ON O N /A 2. Does the registration form include whether a public meeting ha'> been held following an RMP reportable accident. pursuant to 68.2 lO(b)? [68.160(b)(21 )] DY ON ~ NIA 3. Does the owner or operator provide in the RMP: [68.180(a)] D Name, phone number and email address of local emergency planning and response organizations with which the stationary source last coordinated emergency response efforts, pursuant to 68.10(g)(3) or 68.93? [68. l 80(a)(l )] j v ON ON/A D The date of the most recent coordination with the local emergency response organi zations, pursuant to 68.93 ? [68.180(a)(2)] D A list of Federal or state emergency plan requirements to which the stationary source is subject? [68.180(a)(3)] 4. For non-responding stationary sources, does the owner or operator identify: f68.180(b)(l )] D For stationary sources with any regulated toxic substance held in a process above the threshold quantity, whether the stationary source is included in the community emergency response plan developed under 42 U.S.C. 11003, pw-suant to 68.90(b)(J)? [68.180(b)(l)(i)] D For stationary sources with only regulated flammable substances held in a process above the threshold quantity, the date of the most recent coordination with the local fire department, pursuant to 68.90(b)(2)? [68. l 80(b)(1 )(ii)] D What mechanisms are in place to notify the public and emergency responders when there is a need for emergency response? [68. 180(b)( 1)(iii)] D The date of the most recent notification exercise, as required in 68.96(a)? [68.l 80(b)(J )(iv)] ON ON/A 5. For responding stationary sources, does the owner or operator identify the date of the most recent: [68.180(b)(2)] D Review and update of the emergency response plan, pursuant to 68.95(a)(4)? [68.180(b)(2)(i)] D Notification exercise, as required in 68.96(a)? [68. l80(b)(2)(i i)] D Field exercise, as required in 68.96(b)(l)? f68.180 (b)(2)(iii)J D Tabletop exercise, as required in 68 .96(b)(2)? f68.180 (b)(2)(iv)] DY ON Page 18 of 19 Re\' 01107/2021 RMP Program Level 3 Process C hecklist Fa c ility Na m e: Hudson vi!Je Crea_mery & l~ __ _ __ 6. Has the 1Jwn...:r o r 11pcr<:lk1r re' ic\ \ cu ;:ind up<l;_Hc<l rh c- R_'Vl P anJ c'Ub m ill..:J 1L h> L:Y \ f()r thl'. t; >IJm\ i ng: j 6 8. l 9 (J( a 1j'! D Fi ve-year update:. [68. I 90(b)( l )l }\r ON LJ~~/; D Within three y ears ora newl y reg ul atcd subsLancl'. listing.. l68. 190(h )(2JJ D At the time a new regul ated substance is lirsl present in an al ready regu lated process above threshold quantities. f6 8.l 90(b)(3) 1 D At the time a regul ak d substance is fi rst present in an new process above threshold qu:mlitics. [68. 190(b)(4) 1 D Within six months of a change requiring revised PHA or hazard review. (68. l90(b)(5)] D Within six months of a change requiring a revised OCA as provided in 68.36. 168. J90(b)(6)] D Within six months of a change that alters the Program level that applies to any covered process. [68.l 90(b)(7)] 7. If the owner or operator experienced an accidental release that met the five-year accident history reporting criteria DY (as described at 68.42) subsequent to April 9, 2004, did the owner or operator submit the information required at 68.168, 68. l 70(j) and 68.175(1) within six months of the release or by the time the RMP was updated asrequired at 68.190, whichever was earlier. [68. l 95(a)] 8. If the emergency contact information required at 68. I60(b)(6) has changed since June 21 , 2004, did the owner or operator submit corrected information within thi1ty days of the change? [68.195(b)J ~y ON ~NIA ON O N/A Subpart H - Other Requirements [40 CFR 68.200 - 68.210) Implemented Other Requirements as provided in 40 CFR 68.200-68.210? Comments: l. Has the owner or operator maintained records supporting the implementation of this part at the stationary somce for five years, unless otherwise provided in Subpart D: Progrnm 3 Prevention Program? [68.200] 2. Did the owner or operator hold a public meeting to provide infonnation required under 68.42(b), no later than 90 days after any RMP reportable accident at the stationary source with any known offsite impact specified in 68.42(a)? [68.210(b)] I~y I ')O y ON ON/A ON ON/A Page I 9of 19 Rev 01/0 7/2021