Document da88e0gr8MK6MB4BBQqyXVKjq

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT ConAgra Foods Packaged Foods LLC, Darien, Wisconsin Erin DuMontelle, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Supervisor AECAB (MI/WI) File BASIC INFORMATION Facility Name: ConAgra Foods Packaged Foods LLC Facility Location: W8880 County Road X, Darien, WI 53114 Date of Inspection: August 14, 2023 EPA Inspector(s): 1. Erin DuMontelle, Environmental Engineer 2. Sasa Dunovic, Inspector/Enforcement Officer 3. Jason Schenandoah, Environmental Engineer Other Attendees: 1. See Participants List in Attachment A Contact Email Address: Molly Sanders - molly.sanders@conagra.com Purpose of Inspection: Compliance with the prevention of accidental release provisions found in Section 112(r) of the Clean Air Act (CAA), 42 U.S.C. 7414(r) Facility Type: Frozen fruit, juice, and vegetable processing Regulations Central to Inspection: The Chemical Accident Prevention Provisions at 40 C.F.R. Part 68 Arrival Time: 9:50 AM CDT Facility Name: ConAgra Foods Packaged Foods LLC Facility Location: W8880 County Road X, Darien, WI 53114 Date of Inspection: August 14, 2023 Departure Time: 7:20 PM CDT 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: Not a small business Provided CBI warning to facility The following information was obtained verbally from ConAgra unless otherwise noted. Company Ownership: There was a change of ownership on October 26, 2018 from Pinnacle Foods to ConAgra Foods Packaged Foods LLC. Process Description: The ConAgra Foods facility (ConAgra) is a frozen food manufacturing and cold storage facility. It is split into two areas: the first covers processing, and the second covers packing. In processing, there are eight lines that process and freeze produce, noodles, and sauces. In packing, there are ten lines that are divided by two brands. All products are kept in freezer and refrigerated storage before being shipped out. The freezer and refrigerated areas run at temperatures from -15oF up to 45oF. There is approximately 730,000 square feet which is divided equally between the packaging/manufacturing and freezer space. Anhydrous ammonia is used as the refrigerant. There are four ammonia systems ranging from approximately 10,000 lbs to 74,000 lbs of ammonia for a grand total of 131,473 lbs at the facility. Staff Interview: The plant runs 24/7 with approximately 734 employees. The facility opened in 1964, and the process has not changed from packaging and freezing. There were expansions to the facility in 1994, 2003, and 2011. No large changes have been made to the equipment or the process within the last five years. There are four different systems for refrigeration that are separate from one another; each has their own designated Engine Room. Data Collected: Hazard Assessment Off-site Consequence Analyses (OCAs) are completed by a 3rd party using the RMP COMP software. The last OCA was completed in 2019. Page 2 of 8 Facility Name: ConAgra Foods Packaged Foods LLC Facility Location: W8880 County Road X, Darien, WI 53114 Date of Inspection: August 14, 2023 Process Hazard Analysis The most recent PHA was completed on July 11 and 12 of 2023, but the final documentation was not complete, as of the inspection. The previous PHA was completed in 2018 while still under previous management. The 2023 PHA attendees list included three operators and a 3rd party member. Items from the 2018 PHA were migrated to ConAgra's new system database which denotes who is responsible for completing the open item; the system sends email reminders to both the responsible individual, and their supervisor in some cases. Some of the items from the 2018 PHA had completion dates of 2021. Historical PHA records were compiled from 1993, 1996, 1997, 2006, 2007, 2009, and 2013. Operating Procedures All new operating procedures had a creating date of 8/8/2023; employees stated that the SOPs were redone because of updates to the P&IDs. During review, the updated procedures were noted as being "much more robust" than their predecessors. Each of the operators was issued the SOPs for review. Each of the Engine Rooms contain copies of the relevant SOPs to their specific equipment. Annual certifications were missing for two separate years. Training General operator training is provided every three years, but the operating procedure training is new within the last year. Site specific operator training has not been completed for all who require it. ConAgra representatives noted that they discovered a discrepancy in training and are developing a program to address the gaps. Mechanical Integrity Review of the HPR Monthly checks denotes a start date that is three years prior to the completion date. Inspection checklists cover multiple items under one line. Inspection checklists had areas that were not being filled out completely as required by the procedure. There was a matrix within the Mechanical Integrity Policy that defines each piece of MI that needs to be completed, but the responsible party is undefined. Management of Change The written policy procedures for MOCs are developed by corporate and passed down to each site. The last changes made to the corporate MOC policy were in 2019. MOC required documentation is placed in a binder and kept with all other completed MOCs. Page 3 of 8 Facility Name: ConAgra Foods Packaged Foods LLC Facility Location: W8880 County Road X, Darien, WI 53114 Date of Inspection: August 14, 2023 MOC 004 - 22 Condenser 405 was currently open; the SOPs had been written the week prior to the inspection and still needed to be added. MOC 2021.03.24 for an evaporator upgrade contained SOPs that were initially dated 05/05/2023. MOC 2021.03.24 included a Training Sheet that was signed and dated 5/15-16/2022 ConAgra representatives stated to EPA that the previous owner/operator did not actively update their SOPs for new MOCs, but it is now a current practice at the facility. Pre-Startup Safety Review (PSSR) ConAgra representatives stated to EPA that checklists had been created retroactively after discovering that they were missing. Compliance Audits The most recent compliance audit report lacked a list of participants. The most recent compliance audit there was not an individual on the team who was knowledgeable in the specific process; qualifying individuals were interviewed. Incident Investigation Within the previous 5 years of the inspection, there were no catastrophic incidents that had occurred. The facility had an engine shut down in June 2023 due to loading issues caused by a small leak. Emergency Response The most recent revision for the EAP was dated 8/5/2023. There is a HAZMAT team on-site. During large incidents, local and county responders will come. LEPC completed their most recent meeting and walkthrough of the facility in May of 2023. The local Fire Department does a yearly walkthrough. In 2021 and 2022, there was a collective exercise planned and put on that included all Milwaukee area fire. The collective 21/22 exercise included table-top and field exercises with scenarios specific to the facility and its regulated chemical. A recommendations list was created from the 21/22 exercise. ConAgra completes notification testing to local LEPC multiple times per year. TOUR INFORMATION EPA Tour of the Facility: Yes Tour Observations: Engine Room #4A There was extreme ice build-up around the motor shafts near the Low Temperature Receiver (LTR). Page 4 of 8 Facility Name: ConAgra Foods Packaged Foods LLC Facility Location: W8880 County Road X, Darien, WI 53114 Date of Inspection: August 14, 2023 There was corrosion on the piping that was situated between the intercooler and the LTR The doors had turn handles instead of quick exit bars. The E-Stop button was located outside in a control panel that was not locked yet difficult to open. Shift-checks were filled out with "OK" oil Level column. Pressure Relief Valve (PRV) with tag PSV-4BC7-16 was dated expired as of 2018. PRV with tag PSV-4BC7-17 was dated expired as of 2018. ConAgra representatives stated that new PRVs have been ordered, but they had not arrived yet. Other PRVs were noted by EPA as having replacement dates as of August 2023. Engine Room #4B Oil level in separator 4-OS-9 was low. Oil level in separator 4-OS-10 was low; a ConAgra representative stated that the sight glass was full, but the ball was at the bottom. Oil level in separator 4-OS-8 was low. Intercooler 4-IC-2 did not have an expiration tag on the PRV of the oil pot. Engine Room #2 Oil level in Compressors 2-BC-8 and 2-BC-7 were low with the sight glasses half full on the bottom glasses while employee stated that the level should be at half full on the top glass. First and Second shifts both noted the levels as "OK". PRV tag for 2-OS-3 was expired. Oil separator VS151 had a tag, but it was not punched to indicate the month and year of the installation. Oil levels in separators 2-OS-7 and 2-OS-8 were low. Engine Room #1 PRV tag for 1-OS-1 was expired as of March of 2018. PRV tag for 1-OS-3 was expired as of June 2015. PRV tag for 1-OS-4 was missing. Compressor 106 1-HSC-6 had no visible oil in the sight glass and the ball float was at the bottom; the shift operators for the shifts previous-to and concurrent with this inspection marked the shift-check form "OK" for oil level. Shift-check forms require the operator to put the oil level (i.e. , , , F), but operators are only marking the forms as "OK". Sensor 3 was calibrated March of 2023. The room did not have an evacuation map. Engine Room #3 3-LTR-1 oil pot had a tag that was not punched with a date indicating a month and a year of the installation. Photos and/or Videos: were taken during the inspection. A digital camera was used to take pictures during the facility tour. Page 5 of 8 Facility Name: ConAgra Foods Packaged Foods LLC Facility Location: W8880 County Road X, Darien, WI 53114 Date of Inspection: August 14, 2023 Field Measurements: were not taken during this inspection. RECORDS REVIEW EPA reviewed documents for the Following RMP Level 3 Requirements: 1. Applicability 2. Management 3. Off-site consequence analysis 4. Worst-case release scenario analysis 5. Alternative release scenario analysis 6. Hazard Assessment Documentation 7. Five-year accident history 8. Process Safety Information (PSI) 9. Process Hazard Analysis (PHA) 10. Mechanical Integrity (MI) 11. Operating Procedures (SOP) 12. Training 13. Management of Change 14. Pre-startup safety review (PSSR) 15. Compliance Audits 16. Incident Investigation 17. Employee Participation 18. Hot Work Permit 19. Contractors 20. Emergency Response 21. Risk Management Plan CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: 2023 PHA Documentation 2018 Incident Investigation - this request was later rescinded in an email sent to ConAgra by EPA on September 6, 2023. Concerns: The inspection team identified and communicated the following areas of concern to the ConAgra representatives: Yearly certifications were missing for multiple operating procedures. The facility training program needed to add training on operating procedures, specifically covering Emergency Operations. There were training records where operators had received refresher training without the Initial Training. Page 6 of 8 Facility Name: ConAgra Foods Packaged Foods LLC Facility Location: W8880 County Road X, Darien, WI 53114 Date of Inspection: August 14, 2023 The inspection checklists were broad in a way to try and cover everything at the facility which did not allow for specific checks to be completed for individualized components. The inspection checklists were not being filled out completely. The compliance audits were only including interviews with persons knowledgeable in the process instead of including them on the auditing team. There were four missing PSSR that were created retroactively as of August 8, 2023. There were Engine Room doors that were equipped with turn handles instead of quick- escape hardware. There were multiple PRVs that had expired tags throughout each of the Engine Rooms. Oil separators level indicator ball floats showed that many of them were low. Shirt-check forms for oil levels were being noted as "OK" instead of noting the amount within the sight glass as directed in the shift-check form. Oil levels marked on the shift-check forms for two compressors were marked "OK" when there was not adequate oil in the system. There was noticeable ice build-up in Engine Room #4A and Engine Room #2. Engine Room #1 did not contain an Evacuation Map. DIGITAL SIGNATURES Digitally signed by ERIN DUMONTELLE Date: 2023.09.27 10:36:32 Report Author: _________________-_0_5'0_0_' ____________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL M___A__R__S__H__A__L_L____-0_5_'0_0_' ____________ Date: 2023.09.27 10:42:05 Page 7 of 8 Facility Name: ConAgra Foods Packaged Foods LLC Facility Location: W8880 County Road X, Darien, WI 53114 Date of Inspection: August 14, 2023 APPENDICES AND ATTACHMENTS 1. Appendix A: Inspection Sign-In Sheet 2. Appendix B: Digital Photo Log 3. Appendix C: RMP Inspection Checklist Page 8 of 8 INSPECTION ATTENDANCE SHEET U.S. ENVIRONMENTAL PROTECTION AGENCY Region 5 Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) 103; Emergency Planning and Community Right-to-Know Act (EPCRA) 302-312; and Clean Air Act 112r General Duty Clause (GDC) and Risk Management Program (RMP) 8/ DATE/TIME: t L-J / 2 3 LEAD INPECTOR NAME: &," Dvmonfelle.. Credentials: Location: 77 W Jackson Blvd., Chicago, IL Phone: Email: FACILITY NAME: Con A ro.. P"ood 5 FACILITY ADDRESS: Lu 8880 Counhf '2.oo.cl )( Do-.<,e.V\ I w 1, '5 \ lL\ NAME AFFILIATlON/TITLE PHONE EMAIL ,1-r,-t,/(_5l <;__y Ci2 r-oeP- 5 , c. O vf E:Y\ g n e...e.r, V\ As..soc ;'+e Lo3o - Lll.{ 1 _ ?..enc:1 o.ob':'i -"-e; e...--+@ c..oAo.,.' .c.c rn ht . r /vs. c \'a)\\' . ((){'v- :s-, 1--=-u;,.""--'------'--'-'-V-JL..!v.- ; =1--------+--..Ll..J..l...- .l..S ----+-3"''-1'--1.=.._S=------.'/-f'-__,Sc...l..::--""-'=S-"--1-"-'--'-'----'--""'-'-'--i---===v fYi? c --=r. Le..,, &.q_ -t e .s u cti;"' "--1 'V\ z 2- -1z-1-3It:[, Appendix A PAGE OF J__ DATE/TIME: E/j 1I /20Z3 NAME /ECK5 _________________ FACILITY NAME: Oyp(O. AFFILIATION/TITLE PHONE 3CS IML 'e,,y'c5( 3/ 3 Z4Z -58W" ____________ EMAIL Secee e( I Ur -O8l ofdi 3 (3! J8 / __________________ Appendix A PAGE OF 2- Facility Name: ConAgra Foods Packaged Foods LLC Facility Location: W6660 County Road X, Darien, WI 53114 Date of Inspection: August 14, 2023 APPENDIX B: DIGITAL IMAGE LOG 1. Inspector Name: Erin DuMontelle, Sasa Dunovic 2. Archival Record Location: Region 5 Electronic Record Center Image Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 File Name IMG_0557.JPG IMG_0558.JPG IMG_0559.JPG IMG_0560.JPG IMG_0561.JPG IMG_0562.JPG IMG_0563.JPG IMG_0564.JPG IMG_0565.JPG IMG_0566.JPG IMG_0567.JPG IMG_0568.JPG IMG_0569.JPG IMG_0570.JPG IMG_0571.JPG IMG_0572.JPG IMG_0573.JPG IMG_0574.JPG Date and Time (CST) 8/14/2023 5:03 PM 8/14/2023 5:04 PM 8/14/2023 5:04 PM 8/14/2023 5:06 PM 8/14/2023 5:23 PM 8/14/2023 5:29 PM 8/14/2023 5:35 PM 8/14/2023 5:41 PM 8/14/2023 5:42 PM 8/14/2023 5:43 PM 8/14/2023 5:46 PM 8/14/2023 5:55 PM 8/14/2023 5:55 PM 8/14/2023 5:58 PM 8/14/2023 6:00 PM 8/14/2023 6:03 PM 8/14/2023 6:04 PM 8/14/2023 6:17 PM Description of Image Ice build-up near motor in ER #4A Corrosion on piping on LT side from Recirculator Recirculator pump piping PRV tag for PRV-OS-7 Oil level sight glasses for 4-OS-10 Ammonia Sensor in ER #4B PRV tag for 2-OS-3 Tag for oil separator VS151 PRV did not have punched holes indicating a month and a year of the installation. Oil level sight glasses for 2-OS-7/8 Shift-check sheet for ER #2 Ice build-up near pumps on Low Temp Recirculator in ER #2 PRV tag from 1-OS-1 Blurred photo taken by accident - nothing to note PRV tag from 1-OS-3 Missing tags for PRV on 1-OS-4 Oil levels for Compressor 106 1-HSC-6 Shift-check sheet for Compressor 106 1-HSC-6 Tag for 3-LTR-1 PRV did not have punched holes indicating a month and a year of the installation. Appendix B Page 1 of 1 APPENDIX C: RMP Inspection Checklist General Facility Information Facility Name: ConAgra Foods Packaged Foods LLC Mailing Address (Street, City, State, Zip): W8880 County Road X, Darien, WI 53114 Physical Address (Street, City, State, Zip): W8880 County Road X, Darien, WI 53114 Latitude/Longitude: (Source) 42.589444, -88.736944 County: Walworth RMP Number/ FRS Number: 1000 0007 5303 Facility Contact (Name, Title): David (Dave) Barrett Facility Contact Phone No: 262-724-3162 Facility Contact Email: Dave.Barrett@conagra.com Reported NAICS Code(s): 311411 - Frozen Fruit, Juice, and Vegetable Manufacturing Inspection Information Inspection Begin Date: 8/14/2023 Inspection End Date: 8/14/2023 Arrival Time: 9:45 AM CST Name: Departure Time: Organization: 7:15 PM CST Phone No./Email: Lead Inspector Erin DuMontelle US EPA Region 5 DuMontelle.Erin@epa.gov 312-353-0826 Jason Schenandoah US EPA Region 5 Participating Inspectors Sasa Dunovic US EPA Region 5 Appendix C Page 1 of 19 Rev 01/07/2021 RMP Program Level 3 Process Checklist Facility Name: _C_o_n_A__g_r_a_F__o_o_d_s_P_a_c_k_a_g_e_d__F_o_o_d_s_L__L_C_____ Subpart A - General [68.10-15] General requirements followed and implemented as in 40 CFR 68.10-15? Comments: *HQHUDOApplicability [68.10] 1. Has the owner or operator of a stationary source that has more than a threshold quantity of a regulated substance in a process, as determined under 68.115, complied with the requirements of this part no later than the latest of the following dates [68.10(a)]: June 21, 1999? [68.10(a)(1)]; Three years after the date on which a regulated substance is first listed under 68.130? [68.10(a)(2)]; The date on which a regulated substance is first present above a threshold quantity in a process? [68.10(a)(3)]; or For any revisions to this part, the effective date of the final rule that revises this part? [68.10(a)(4)] 2. Has the owner or operator complied with the emergency coordination activities in accordance with 68.93 by September 21, 2018? [68.10(b)] (See Items 2 through 5 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 program requirements of 68.95? [68.10(c)] (See Items 1.b.(2) - 1.b.(7) of Subpart E) 4. Has the owner or operator developed plans for conducting emergency response exercises in accordance with 68.96 by December 19, 2023? [68.10(d)] (See Items 1.b.(8) - 1.b.(17), 6, and 7 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 reportable accident at the stationary source with known offsite impacts specified in 68.42(a), that occurs after March 15, 2021? [68.10(e)] (See Item 2 of Subpart H) 6. After December 19, 2024, has the owner or operator reported in the RMP submission: [68.10(f)] A public meeting after an RMP reportable accident under 68.160(b)(21)? [68.10(f)(1)]; Emergency response program information under 68.180(a)(1)? [68.10(f)(2)]; Emergency response program information under 68.180(a)(2) and (3)? [68.10(f)(3)]; and, Emergency response program and exercises information under 68.180(b), as applicable? Including submittal of the following: [68.10(f)(4)] Dates of the most recent notification, Dates of field and tabletop exercises in the risk management plan, Dates for exercises completed as required under 68.96 at the time the risk management plan is either submitted under 68.150(b)(2) or (3), or is updated under 68.190. Y N Y N Y N Y N Y N Y N N/A N/A N/A N/A N/A N/A Appendix C Page 2 of 19 Rev 01/07/2021 RMP Program Level 3 Process Checklist Facility Name: _C_o_n_A__g_r_a_F__o_o_d_s_P_a_c_k_a_g_e_d__F_o_o_d_s_L__L_C_____ *HQHUDOProgram Eligibility [68.10(g)-(i)] 7. Does the covered process meet the eligibility requirements of Program 1? Specifically: [68.10(g)] Does the covered process meet all of the following requirements: For the five years prior to the submission of an RMP, the process has not had an accidental release of a regulated substance where exposure to the substance, its reaction products, overpressure generated by an explosion involving the substance, or radiant heat generated by a fire involving the substance led to any of the following offsite? [68.10(g)(1)]; Death; [68.10(g)(1)(i)] Injury; [68.10(g)(1)(ii)] or, Response or restoration activities for an exposure of an environmental receptor; [68.10(g)(1)(iii)] and 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 Emergency response procedures have been coordinated between the stationary source and local emergency planning and response organizations [68.10(g)(3)] 8. Does the covered process meet the eligibility requirements of Program 3? Specifically: [68.10(i)] The process does not meet the eligibility requirements of Program 1. [68.10(i)]; and Is the covered process any of the following NAICS codes: [68.10(i)(1)] 32211, 32411, 32511, 325181, 325188, 325192, 325199, 325211, 325311, or 32532; or Is the process subject to the OSHA process safety management standard, 29 CFR 1910.119? [68.10(i)(2)] Y N N/A Y N N/A 9. Does the covered process fail to meet the eligibility requirements of Program 1 and Program 3 (i.e., is the covered process a Program 2)? [68.10(h)] *HQHUDOManagement [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. Assigned a qualified person or position that has the overall responsibility for the development, implementation, and integration of the risk management program 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)] Subpart B Hazard Assessment [68.20-68.42] Hazard assessment conducted and documented as provided in 40 CFR 68.20-68.42? Comments: Y N N/A Y N N/A Y N N/A Y N N/A Appendix C Page 3 of 19 Rev 01/07/2021 RMP Program Level 3 Process Checklist Facility Name: _C_o_n_A__g_r_a_F__o_o_d_s_P_a_c_k_a_g_e_d__F_o_o_d_s_L__L_C_____ Hazard Assessment: Offsite consequence analysis parameters [68.22] 1. Used the following endpoints for offsite consequence analysis for a worst-case scenario: [68.22(a)] Y For toxics: the endpoints provided in Appendix A of 40 CFR Part 68? [68.22(a)(1)] For flammables: an explosion resulting in an overpressure of 1 psi? [68.22(a)(2)(i)]; or For flammables: a fire resulting in a radiant heat/exposure of 5 kw/m2 for 40 seconds? [68.22(a)(2)(ii)] 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)] 2. Used the following endpoints for offsite consequence analysis for an alternative release scenario: [68.22(a)] Y For toxics: the endpoints provided in Appendix A of 40 CFR Part 68? [68.22(a)(1)] For flammables: an explosion resulting in an overpressure of 1 psi? [68.22(a)(2)(i)] For flammables: a fire resulting in a radiant heat/exposure of 5 kw/m2 for 40 seconds? [68.22(a)(2)(ii)] 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)] Y 4. Used appropriate ambient temperature and humidity values for the release analysis? [68.22(c)] Y 5. Used appropriate values for the height of the release for the release analysis? [68.22(d)] Y 6. Used appropriate surface roughness values for the release analysis? [68.22(e)] Y 7. Do tables and models, used for dispersion analysis of toxic substances, appropriately account for dense or neutrally Y buoyant gases? [68.22(f)] 8. Were liquids, other than gases liquefied by refrigeration only, considered to be released at the highest daily Y maximum temperature, based on data for the previous three years appropriate for a stationary source, or at process temperature, whichever is higher? [68.22(g)] Hazard Assessment: Worst-case release scenario analysis [68.25] 9. Analyzed and reported in the RMP one worst-case release scenario estimated to create the greatest distance to an Y endpoint resulting from an accidental release of a regulated toxic substance from covered processes under worst- case conditions? [68.25(a)(2)(i)] 10. Analyzed and reported in the RMP one worst-case release scenario estimated to create the greatest distance to an Y endpoint resulting from an accidental release of a regulated flammable substance from covered processes under worst-case conditions? [68.25(a)(2)(ii)] 11. Analyzed and reported in the RMP additional worst-case release scenarios for a hazard class if the worst-case Y release from another covered process at the stationary source potentially affects public receptors different from those potentially affected by the worst-case release scenario developed under 68.25(a)(2)(i) or 68.25(a)(2)(ii)? [68.25(a)(2)(iii)] 12. Has the owner or operator determined the worst-case release quantity to be the greater of the following: [68.25(b)] Y If released from a vessel, the greatest amount held in a single vessel, taking into account administrative controls that limit the maximum quantity? [68.25(b)(1)] If released from a pipe, the greatest amount held in the pipe, taking into account administrative controls that limit the maximum quantity? [68.25(b)(2)] N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A Appendix C Page 4 of 19 Rev 01/07/2021 RMP Program Level 3 Process Checklist Facility Name: _C_o_n_A__g_r_a_F__o_o_d_s_P_a_c_k_a_g_e_d__F_o_o_d_s_L__L_C_____ 13.a. Has the owner or operator for toxic substances that are normally gases at ambient temperature and handled as a gas or liquid under pressure: 13.a.(1) Assumed the whole quantity in the vessel or pipe would be released as a gas over 10 minutes? [68.25(c)(1)] Y N N/A 13.a.(2) Assumed the release rate to be the total quantity divided by 10, if there are no passive mitigation systems in place? [68.25(c)(1)] Y N N/A 13.b. Has the owner or operator for toxic gases handled as refrigerated liquids at ambient pressure: 13.b.(1) Assumed the substance would be released as a gas in 10 minutes, if not contained by passive mitigation systems or if the contained pool would have a depth of 1 cm or less? [68.25(c)(2)(i)] Y N N/A 13.b.(2) If released substance would be contained by passive mitigation systems in a pool with a depth > 1 cm; 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)] 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)] Y N N/A 13.c. Has the owner or operator for toxic substances that are normally liquids at ambient temperature: 13.c.(1) Assumed the quantity in the vessel or pipe would be spilled instantaneously to form a liquid pool? [68.25(d)(1)] Y N N/A 13.c.(2) Determined the surface area of the pool by assuming that the liquid spreads to 1 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)(1)(i)] Y N N/A 13.c.(3) Taken into account the actual surface characteristics, if the release would occur onto a surface that is not paved Y N N/A or smooth? [68.25(d)(1)(ii)] 13.c.(4) Determined the volatilization rate by accounting for the highest daily maximum temperature in the past three Y N N/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 of release to air from the volatilization rate of the liquid pool? [68.25(d)(3)] Y N N/A 13.c.(6) Determined 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 Y N N/A 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)] What modeling technique did the owner or operator use? [68.25(g)] ______________________ 13.d. Has the owner or operator for flammable gases: 13.d.(1) Assumed the quantity in a vessel(s) of flammable gas held as a gas or liquid under pressure is released as a gas Y N N/A over 10 minutes resulting in a vapor cloud explosion? [68.25(e)(1)] 13.d.(2) For gas handled as refrigerated liquid that is not contained by passive mitigation systems, assumed the total quantity 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)] Y N N/A 13.d.(3) For gas handled as refrigerated liquid released to a contained area, assumed the quantity volatilized in 10 minutes results in a vapor cloud? [68.25(e)(2)(ii)] Y N N/A Appendix C Page 5 of 19 Rev 01/07/2021 RMP Program Level 3 Process Checklist Facility Name: _C_o_n_A__g_r_a_F__o_o_d_s_P_a_c_k_a_g_e_d__F_o_o_d_s_L__L_C_____ 13.d.(4) Assumed a yield factor of 10% of the available energy is released in the explosion for determining the distance Y to the explosion endpoint, if the model used is based on TNT-equivalent methods? [68.25(e)] 13.e. Has the owner or operator for flammable liquids: 13.e.(1) Assumed the entire quantity in the vessel or pipe, taking into account administrative controls that limit the Y maximum quantity, would be spilled instantaneously to form a liquid pool? [68.25(f)(1)] 13.e.(2) For liquids at temperatures below their atmospheric boiling point, calculated the volatility rate at the boiling Y point of the substance and at the conditions specified in 68.25(d) and assumed that the quantity which becomes vapor in the first 10 minutes is involved in the vapor cloud explosion? [68.25(f)(1)-(2)] 13.e.(3) Assumed a yield factor of 10% of the available energy is released in the explosion for determining the distance Y to the explosion endpoint, if the model used is based on TNT-equivalent methods? [68.25(f)] 14. Used the parameters defined in 68.22 to determine distance to the endpoints? [68.25(g)] Y 15. Determined the rate of release to air by using the methodology in the RMP Offsite Consequence Analysis Guidance, Y 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 Y 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)] Y Smaller quantities handled at higher process temperature or pressure? [68.25(i)(1)] Proximity to the boundary of the stationary source? [68.25(i)(2)] Hazard Assessment: Alternative release scenario analysis [68.28] 18. Identified and analyzed at least one alternative release scenario 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)] 19. Selected a scenario: [68.28(b)] Y That is more likely to occur than the worst-case release scenario under 68.25? [68.28(b)(1)(i)] That will reach an endpoint off-site, unless no such scenario exists? [68.28(b)(1)(ii)] 20. Considered release scenarios which included, but are not limited to, the following: [68.28(b)(2)] Y Transfer hose releases due to splits or sudden hose uncoupling? [68.28(b)(2)(i)] Process piping releases from failures at flanges, joints, welds, valves and valve seals, and drains or bleeds? [68.28(b)(2)(ii)] Process vessel or pump releases due to cracks, seal failure, or drain, bleed, or plug failure? [68.28(b)(2)(iii)] Vessel overfilling and spill, or overpressurization and venting through relief valves or rupture disks? [68.28(b)(2)(iv)] Shipping container 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 endpoints? [68.28(c)] Y N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A Appendix C Page 6 of 19 Rev 01/07/2021 RMP Program Level 3 Process Checklist Facility Name: _C_o_n_A__g_r_a_F__o_o_d_s_P_a_c_k_a_g_e_d__F_o_o_d_s_L__L_C_____ 22. Determined the rate of release to air by using the methodology in the RMP Offsite Consequence Analysis Guidance, Y 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? [68.28(c)] What modeling technique did the owner or operator use? [68.25(g)] ____________________ 23. Ensured that the passive and active mitigation systems, if considered, are capable of withstanding the release event Y triggering the scenario and will be functional? [68.28(d)] 24. Considered the following factors in selecting the alternative release scenarios: [68.28(e)] Y The five-year accident history provided in 68.42? [68.28(e)(1)] Failure scenarios identified under 68.50? [68.28(e)(2)] Hazard Assessment: Defining off-site impacts-Population [68.30] 25. Estimated population that would be included within a circle where its center is the point of the release and a radius Y determined by the distance to the endpoint? [68.30(a)] 26. Identified the presence of institutions, parks and recreational areas, major commercial, office, and industrial Y buildings in the RMP? [68.30(b)] 27. Used most recent Census data, or other updated information to estimate the population? [68.30(c)] Y 28. Estimated the population to two significant digits? [68.30(d)] Y 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 Y 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 Y environmental receptors? [Source may have used LandView to obtain information] [68.33(b)] 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)] Y 32. Completed a revised analysis and submit a revised RMP within six months of a change in processes, quantities Y stored or handled, or any other aspect that might reasonably be expected to increase or decrease the distance to the endpoint by a factor of two or more? [68.36(b)] Hazard Assessment: Documentation [68.39] 33. Has the owner or operator maintained the following records on the offsite consequence analyses: 33.a For worst-case scenarios: a description of the vessel or pipeline and substance selected, assumptions and Y parameters used, the rationale for selection, and anticipated effect of the administrative controls and passive mitigation on the release quantity and rate? [68.39(a)] 33.b For alternative release scenarios: a description of the scenarios identified, assumptions and parameters used, the Y rationale for the selection of specific scenarios, and anticipated effect of the administrative controls and mitigation on the release quantity and rate? [68.39(b)] 33.c Documentation of estimated quantity released, release rate, and duration of release? [68.39(c)] Y 33.d Methodology used to determine distance to endpoints? [68.39(d)] Y N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A Appendix C Page 7 of 19 Rev 01/07/2021 RMP Program Level 3 Process Checklist Facility Name: _C_o_n_A__g_r_a_F__o_o_d_s_P_a_c_k_a_g_e_d__F_o_o_d_s_L__L_C_____ 33.e Data used to estimate population and environmental receptors potentially affected? [68.39(e)] Y Hazard Assessment: Five-year accident history [68.42] 34. Has the owner or operator included all accidental releases from covered processes that resulted in deaths, injuries, or Y significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage? [68.42(a)] 35. Has the owner or operator reported the following information for each accidental release: [68.42(b)] Y Date, time, and approximate duration of the release? [68.42(b)(1)] Chemical(s) released? [68.42(b)(2)] Estimated quantity released in pounds and percentage weight in a mixture (toxics)? [68.42(b)(3)] NAICS code for the process? [68.42(b)(4)] The type of release event and its source? [68.42(b)(5)] Weather conditions (if known)? [68.42(b)(6)] On-site impacts? [68.42(b)(7)] Known offsite impacts? [68.42(b)(8)] Initiating event and contributing factors (if known)? [68.42(b)(9)] Whether offsite responders were notified (if known)? [68.42(b)(10)] Operational or process changes that resulted from investigation of the release? [68.42(b)(11)] 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 [68.65] 1. Has the owner or operator compiled written process safety information, which includes information pertaining to the Y hazards of the regulated substances used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process, before conducting any process hazard analysis required by the rule? [68.65(a)] Does the process safety information contain the following for hazards of the substances: [68.65(b)] 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)] 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)] N N/A N N/A N N/A N N/A Note: Safety Data Sheets (SDS) meeting the requirements of the OSHA Hazard Communication Standard [29 CFR 1910.1200(g)] may be used to comply with this requirement to the extent they contain the information required by 68.65(b). Appendix C Page 8 of 19 Rev 01/07/2021 RMP Program Level 3 Process Checklist Facility Name: _C_o_n_A__g_r_a_F__o_o_d_s_P_a_c_k_a_g_e_d__F_o_o_d_s_L__L_C_____ 2. Does the process safety information contain information pertaining to technology of the process [68.65(c)]? Does the information concerning the technology of the process include the following: [68.65(c)(1)] Y N N/A A block flow diagram or simplified process flow diagram? [68.65(c)(1)(i)] Process chemistry? [68.65(c)(1)(ii)] Maximum intended inventory? [68.65(c)(1)(iii)] Safe upper and lower limits for such items as temperatures, pressures, flows, or compositions? [68.65(c)(1)(iv)] An evaluation of the consequences of deviation? [68.65(c)(1)(iv)] 3. Does the process safety information contain information pertaining to the equipment in the process? [68.65(d)] Does the information pertaining to the equipment in the process include the following: [68.65(d)(1)] Materials of construction? 68.65(d)(1)(i)] Piping and instrumentation diagrams [68.65(d)(1)(ii)] Electrical classification? [68.65(d)(1)(iii)] Relief system design and design basis? [68.65(d)(1)(iv)] Ventilation system design? [68.65(d)(1)(v)] Design codes and standards employed? [68.65(d)(1)(vi)] Material and energy balances for processes built after June 21, 1999? [68.65(d)(1)(vii)] Safety systems? [68.65(d)(1)(viii)] Y N N/A 4. Has the owner or operator documented that equipment complies with recognized and generally accepted good engineering practices? [68.65(d)(2)] Y N N/A 5. Has the owner or operator determined and documented that existing equipment, designed and constructed in 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)] Y N N/A 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)] Y N N/A 7. Has the owner or operator determined and documented the priority order for conducting PHAs, and was it based on Y N N/A an appropriate rationale? [68.67(a)] 8. Has the owner used one or more of the following technologies to conduct process PHA: [68.67(b)] What-if? [68.67(b)(1)] Checklist? [68.67(b)(2)] What-if/Checklist? [68.67(b)(3)] Hazard and Operability Study (HAZOP) [68.67(b)(4)] Failure Mode and Effects Analysis (FMEA) [68.67(b)(5)] Fault Tree Analysis? [68.67(b)(6)] An appropriate equivalent methodology? [68.67(b)(7)] Y N N/A Appendix C Page 9 of 19 Rev 01/07/2021 RMP Program Level 3 Process Checklist Facility Name: _C_o_n_A__g_r_a_F__o_o_d_s_P_a_c_k_a_g_e_d__F_o_o_d_s_L__L_C_____ 9. Did the PHA address: The hazards of the process? [68.67(c)(1)] Identification of any incident that had a likely potential for catastrophic consequences? [68.67(c)(2)] Engineering and administrative controls applicable to hazards and interrelationships?[68.67(c)(3)] Consequences of failure of engineering and administrative controls? [68.67(c)(4)] Stationary source siting? [68.67(c)(5)] Human factors? [68.67(c)(6)] A qualitative evaluation of a range of the possible safety and health effects of failure of controls? [68.67(c)(7)] Y N N/A 10. Was the PHA performed by a team with expertise in engineering and process operations and did the team include at Y N N/A least one employee who has 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 owner 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? Documented what actions are to be taken? Completed actions as soon as possible? 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? Y N N/A 12. Has the PHA been updated and revalidated by a team every five years after the completion of the initial PHA to assure that the PHA is consistent with the current process? [68.67(f)] Y N N/A 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)] Y N N/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)] Y N N/A Appendix C Page 10 of 19 Rev 01/07/2021 RMP Program Level 3 Process Checklist Facility Name: _C_o_n_A__g_r_a_F__o_o_d_s_P_a_c_k_a_g_e_d__F_o_o_d_s_L__L_C_____ 15 Do the procedures address the following: [68.69(a)] Steps for each operating phase: [68.69(a)(1)] Initial Startup? [68.69(a)(1)(i)] Normal operations? [68.69(a)(1)(ii)] Temporary operations? [68.69((a)(1)(iii)] Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner? [68.69(a)(1)(iv)] Emergency operations? [68.69(a)(1)(v)] Normal shutdown? [68.68(a)(1)(vi)] Startup following a turnaround, or after emergency shutdown? [68.69(a)(1)(vii)] Operating limits: [68.69(a)(2)] Consequences of deviations [68.69(a)(2)(i)] Steps required to correct or avoid deviation? [68.69(a)(2)(ii)] Safety and health considerations: [68.69(a)(3)] Properties of, and physical hazards presented by, the chemicals used in the process [68.69(a)(3)(i)] Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment? [68.69(a)(3)(ii)] Control measures to be taken if physical contact or airborne exposure occurs? [68.69(a)(3)(iii)] Quality control for raw materials and control of hazardous chemical inventory levels? [68.69(a)(3)(iv)] Any special or unique hazards? [68.69(a)(3)(v)] Safety systems and their functions? [68.69(a)(4)] Y N N/A 16. Are operating procedures readily accessible to employees who are involved in a process? [68.69(b)] Y N N/A 17. Has the owner or operator certified annually that the operating procedures are current and accurate and that Y N N/A 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)] 18. Has the owner or operator developed and implemented safe work practices to provide for the control of hazards during specific operations, such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a stationary source by maintenance, contractor, laboratory, or other support personnel? [68.69(d)] Y N N/A Prevention Program Training [68.71] 19 Has each employee involved in operating a process, and each employee before being involved in operating a newly Y N N/A assigned process, been initially trained in an overview of the process and in the operating procedures? [68.71(a)(1)] 20. Did initial training include emphasis on safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks? [68.71(a)(1)] Y N N/A 21. In lieu of initial training for those employees already involved in operating a process on June 21, 1999, an owner or Y N N/A operator may certify in writing that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures [68.71(a)(2)] Appendix C Page 11 of 19 Rev 01/07/2021 RMP Program Level 3 Process Checklist Facility Name: _C_o_n_A__g_r_a_F__o_o_d_s_P_a_c_k_a_g_e_d__F_o_o_d_s_L__L_C_____ 22. Has refresher training been provided at least every three years, or more often if necessary, to each employee Y involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process? [68.71(b)] 23. Has owner or operator ascertained and documented in record that each employee involved in operating a process Y has received and understood the training required? [68.71(c)] 24. Does the prepared record contain the identity of the employee, the date of the training, and the means used to verify Y that the employee understood the training? [68.71(c)] Prevention Program Mechanical integrity [68.73] 25. Has the owner or operator established and implemented written procedures to maintain the on-going integrity of the Y process equipment listed in 68.73(a)? [68.73(b)] 26. Has the owner or operator trained each employee involved in maintaining the on-going integrity of process Y equipment? [68.73(c)] 27. Has the owner or operator performed inspections and tests on process equipment? [68.73(d)(1)] Y 28. Has the owner or operator followed recognized and generally accepted good engineering practices for inspections Y and testing procedures? [68.73(d)(2)] 29. Has the owner or operator ensured the frequency of inspections and tests of process equipment is consistent with Y applicable manufacturers' recommendations, good engineering practices, and prior operating experience? [68.73(d)(3)] 30. Has the owner or operator documented each inspection and test that had been performed on process equipment, and Y identified the following: [68.73(d)(4)] The date of the inspection or test? The name of the person who performed the inspection or test? The serial number or other identifier of the equipment on which the inspection or test was performed? A description of the inspection or test performed? and The results of the inspection or test? 31. Has the owner or operator corrected deficiencies in equipment that were outside acceptable limits defined by the Y process safety information before further use or in a safe and timely manner when necessary means were taken to assure safe operation? [68.73(e)] 32. Has the owner or operator assured that equipment as it was fabricated is suitable for the process application for Y which it will be used in the construction of new plants and equipment? [68.73(f)(1)] 33. Has the owner or operator performed appropriate checks and inspections to assure that equipment was installed Y 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 Y process application for which they would be used? [68.73(f)(3)] Prevention Program Management of change [68.75] 35. Has the owner or operator established and implemented written procedures to manage changes to process chemicals, Y technology, equipment, and procedures, and changes to stationary sources that affect a covered process? [68.75(a)] N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A Appendix C Page 12 of 19 Rev 01/07/2021 RMP Program Level 3 Process Checklist Facility Name: _C_o_n_A__g_r_a_F__o_o_d_s_P_a_c_k_a_g_e_d__F_o_o_d_s_L__L_C_____ 36. Do procedures assure that the following considerations are addressed prior to any change: [68.75(b)] The technical basis for the proposed change? [68.75(b)(1)] Impact of change on safety and health? [68.75(b)(2)] Modifications to operating procedures? [68.75(b)(3)] Necessary time period for the change? [68.75(b)(4)] Authorization requirements for the proposed change? [68.75(b)(5)] Y N N/A 37. Were employees, involved in operating a process and maintenance, and contract employees, whose job tasks would Y N N/A be affected by a change in the process, informed of, 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 information, was such information updated accordingly? [68.75(d)] Y N N/A 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)] Y N N/A Prevention Program Pre-startup safety review [68.77] 40. Has the owner or operator performed 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 N N/A 41. Does the pre-startup safety review confirm the following prior to the introduction of a regulated substance to a process: [68.77(b)] Construction and equipment was in accordance with design specifications? [68.77(b)(1)] Safety, operating, maintenance, and emergency procedures were in place and were adequate? [68.77(b)(2)] For new stationary sources, a process hazard analysis had been performed and recommendations had been resolved or implemented before startup? [68.77(b)(3)] 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)] Y N N/A Prevention Program Compliance audits [68.79] 42. Has the owner or operator certified that the stationary source has evaluated compliance with the provisions of the Y N N/A prevention program at least every three years to verify that the developed procedures and practices are adequate and being followed? [68.79(a)] 43. Has the audit been conducted by at least one person knowledgeable in the process? [68.79(b)] Y N N/A 44. Are the audit findings documented in a report? [68.79(c)] Y N N/A 45. Has the owner or operator promptly determined and documented an appropriate response to each of the findings of the audit and documented that deficiencies had been corrected? [68.79(d)] Y N N/A 46. Has the owner or operator retained the two most recent compliance reports? [68.79(e)] Y N N/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 of a regulated substance? [68.81(a)] Y N N/A Appendix C Page 13 of 19 Rev 01/07/2021 RMP Program Level 3 Process Checklist Facility Name: _C_o_n_A__g_r_a_F__o_o_d_s_P_a_c_k_a_g_e_d__F_o_o_d_s_L__L_C_____ 48. Were all incident investigations initiated not later than 48 hours following the incident? [68.81(b)] Y N N/A 49. Was an accident investigation team established and did it consist of at least one person knowledgeable in the process involved, including a contract employee if the incident involved work of a contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident? [68.81(c)] Y N N/A 50. Was a report prepared at the conclusion of every investigation? [68.81(d)] Y N N/A 51. Does every report include: [68.81(d)] Date of incident? [68.81(d)(1)] Date investigation began? [68.81(d)(2)] A description of the incident? [68.81(d)(3)] The factors that contributed to the incident? [68.81(d)(4)] Any recommendations resulting from the investigation? [68.81(d)(5)] Y N N/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? [68.81(e)] Y N 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? [68.81(f)] Y N N/A 54. Has the owner or operator retained incident investigation reports for at least five years? [68.81(g)] Y N N/A Prevention Program Employee participation [68.83] 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)] Y N N/A . 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 N N/A . Has the owner or operator provided to employees and their representatives access to process hazards analyses and to Y all other information required to be developed under the chemical accident prevention rule? [68.83(c)] N N/A Prevention Program Hot work permit [68.85] . 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)] Y N N/A . 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)] Y N N/A . 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)] Y N N/A . Are the permits being kept on file until completion of the hot work operations? [68.85(b)@ Y N N/A Prevention Program Contractors [68.87] . Has the owner or operator obtained and evaluated information regarding the contract owner or operator's safety performance and programs when selecting a contractor? [68.87(b)(1)] Y N N/A . 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? [68.87(b)(2)] Y N N/A Appendix C Page 14 of 19 Rev 01/07/2021 RMP Program Level 3 Process Checklist Facility Name: _C_o_n_A__g_r_a_F__o_o_d_s_P_a_c_k_a_g_e_d__F_o_o_d_s_L__L_C_____ . Has the owner or operator explained to the contract owner or operator the applicable provisions of the emergency Y response or the emergency action program? [68.87(b)(3)] . Has the owner or operator developed and implemented safe work practices consistent with 68.69(d), to control the Y entrance, presence, and exit of the contract owner or operator and contract employees in the covered process areas? [68.87(b)(4)] . Periodically evaluated the performance of the contract owner or operator in fulfilling their obligations (as described Y at 68.87(c)(1) - (c)(5))? [68.87(b)(5)] 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: 1. Is the facility designated as a "responding stationary source"? Y 1.a. If the facility is not a responding stationary source, it need not comply with 68.95 if the following conditions are met: 1.a.(1) For stationary sources with any regulated substances held in a process above threshold quantities, is the source Y included in the community emergency response plan developed under 42 U.S.C. 11003? [68.90(b)(1)] 1.a.(2) For stationary sources with only regulated flammable substances held in a process above threshold quantities, Y has the owner or operator coordinated response actions with the local fire department? [68.90(b)(2)] 1.a.(3) Are appropriate mechanisms in place to notify emergency responders when there is need for a response? Y [68.90(b)(3)] 1.a.(4) As of September 21, 2018, has the owner or operator performed the annual emergency response coordination Y activities required under 68.93? [68.90(b)(4)] (See Items 2 through 5) 1.a.(5) Has the owner or operator performed the annual notification exercises required under 68.96(a) before Y December 19, 2024? [68.90(b)(5)] (See Items 6 and 7) For non-responding stationary sources where 1.a.(1)-(5) are all marked as `Y', proceed to Subpart E Item 2 1.b. If the facility is a responding stationary source: 1.b.(1) Has the owner or operator developed and implemented an emergency response program that includes the Y elements required in 68.95(a)(1-4)? [68.95(a)] (See Items 1.b.(2) - 1.b.(5)) N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A 1.b.(2). An emergency response plan is maintained at the stationary source and contains the following? [68.95(a)(1)] Y N N/A s Procedures for informing the public and the appropriate Federal, state, and local emergency response agencies about accidental releases? [68.95(a)(1)(i)] s Documentation of proper first-aid and emergency medical treatment necessary to treat accidental human exposures? [68.95(a)(1)(ii)] s Procedures and measures for emergency response after an accidental release of a regulated substance? [68.95(a)(1)(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)] Y N N/A 1.b.(4) Does the emergency response program include training for all employees in relevant procedures? [68.95(a)(3)] Y N N/A 1.b.(5) Does the emergency response program include procedures to review and update, as appropriate, the emergency Y N N/A response plan to reflect changes at the stationary source and ensure that employees are informed of changes? [68.95(a)(4)] Appendix C Page 15 of 19 Rev 01/07/2021 RMP Program Level 3 Process Checklist Facility Name: _C_o_n_A__g_r_a_F__o_o_d_s_P_a_c_k_a_g_e_d__F_o_o_d_s_L__L_C_____ 1.b.(6) Does the emergency response program include a written plan that complies with other Federal contingency plan Y regulations or is consistent with the approach in the National Response Team's Integrated Contingency Plan Guidance (``One Plan'')? If so, does the plan include the elements provided in paragraph (a) of 68.95, and also complies with paragraph (c) of 68.95? [68.95(b)] 1.b.(7) Has the emergency response plan been coordinated with the community emergency response plan developed Y under EPCRA? [68.95(c)] 1.b.(8) Has the owner or operator developed and implemented an exercise program for its emergency response Y program, including the emergency plan required under 68.95(a)(1)? [68.96(b)] 1.b.(9) Do the exercises involve facility emergency response personnel and, as appropriate, emergency response Y contractors? [68.96(b)] 1.b.(10) When planning emergency response field and tabletop exercises, has the owner or operator coordinated with Y local public emergency response officials and invite them to participate in the exercise? [68.96(b)] 1.b.(11) Does the emergency response exercise program include: [68.96(b)] Y Emergency response field exercises? [68.96(b)(1)] Tabletop exercises? [68.96(b)(2)] Documentation? [68.96(b)(3)] 1.b.(12) As part of coordination with local emergency response officials, has the owner or operator consulted with Y these officials to establish an appropriate frequency for field exercises? [68.96(b)(1)(i)] 1.b.(13) Field exercises shall involve tests of the source's emergency response plan, including deployment of emergency Y response personnel and equipment. Do field exercises include: [68.96(b)(1)(ii)] Tests of procedures to notify the public and the appropriate Federal, state, and local emergency response agencies about an accidental release? Tests of procedures and measures for emergency response actions including evacuations and medical treatment? Tests of communications systems? Mobilization of facility emergency response personnel, including contractors, as appropriate? Coordination with local emergency responders? Emergency response equipment deployment? Any other action identified in the emergency response program, as appropriate? 1.b.(14) As part of coordination with local emergency response officials, has the owner or operator consulted with Y 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 Y discussions of: [68.96(b)(2)(ii)] Procedures to notify the public and the appropriate Federal, state, and local emergency response agencies? Procedures and measures for emergency response including evacuations and medical treatment? Identification of facility emergency response personnel and/or contractors and their responsibilities? Coordination with local emergency responders? Procedures for emergency response equipment deployment? Any other action identified in the emergency response plan, as appropriate? N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A Appendix C Page 16 of 19 Rev 01/07/2021 RMP Program Level 3 Process Checklist Facility Name: _C_o_n_A__g_r_a_F__o_o_d_s_P_a_c_k_a_g_e_d__F_o_o_d_s_L__L_C_____ 1.b.(16) Has the owner or operator prepared an evaluation report within 90 days of each field and tabletop exercise, which included: [68.96(b)(3)] A description of the exercise scenario? Names and organizations of each participant? An evaluation of the exercise results including lessons learned? Recommendations for improvement or revisions to the emergency response exercise program and emergency response program, and a schedule to promptly address and resolve recommendations? Y N N/A 1.b.(17) Has the owner or operator satisfied the requirement to conduct notification, field and/or tabletop exercises through alternative means such as: [68.96(c)] Exercises conducted to meet other Federal, state, or local exercise requirements, provided the exercise meets the requirements of paragraphs (a) and/or (b) of this section, as appropriate. [68.96(c)(1)] 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 required in paragraph (b)(3) of this section, within 90 days of the incident. [68.96(c)(2)] Y N N/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 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)] Y N N/A 3. Has coordination occurred at least annually, and more frequently if necessary, to address changes: At the stationary source; in the stationary source's emergency response and/or emergency action plan; and/or in the community emergency response plan? [68.93(a)] Y N N/A 4. Has coordination included providing to the local emergency planning and response organizations? [68.93(b)] s The stationary source's emergency response plan if one exists? s Emergency action plan? s Updated emergency contact information? Other information necessary for developing and implementing the local emergency response plan? 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 1.b.(8), 1.b.(10), 1.b.(12), and 1.b.(14)) Y N N/A 5. As of September 21, 2018, has the owner or operator documented coordination with local authorities, including: [68.93(c)] s The names of individuals involved and their contact information (phone number, email address, and organizational affiliations)? s Dates of coordination activities? s Nature of coordination activities? Y N N/A 6. Has the owner or operator of a stationary source with any Program 2 or Program 3 process conducted an exercise of Y N N/A the stationary source's emergency response notification mechanisms before December 19, 2024 and annually thereafter? [68.96(a)] (Owners or operators of responding stationary sources may perform the notification exercise as part of the tabletop and field exercises) Appendix C Page 17 of 19 Rev 01/07/2021 RMP Program Level 3 Process Checklist Facility Name: _C_o_n_A__g_r_a_F__o_o_d_s_P_a_c_k_a_g_e_d__F_o_o_d_s_L__L_C_____ 7. Has the owner/operator maintained a written record of each notification exercise conducted over the last five years? Y N N/A [68.96(a)] Subpart G - Risk Management Plan [40 CFR 68.150 - 68.195] Documented a Risk Management Plan as provided in 40 CFR 68.150-68.195? Comments: 1. Does the single registration form include, for each covered process: [68.160(b)(7)] s The name and CAS number of each regulated substance held above the threshold quantity in the process? s The maximum quantity of each regulated substance or mixture in the process (in pounds) to two significant digits? s The five- or six-digit NAICS code that most closely corresponds to the process? s The correct program level of the process? 2. Does the registration form include whether a public meeting has been held following an RMP reportable accident, pursuant to 68.210(b)? [68.160(b)(21)] Y N N/A Y N N/A 3. Does the owner or operator provide in the RMP: [68.180(a)] Y N N/A s 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? [68.180(a)(1)] s The date of the most recent coordination with the local emergency response organizations, pursuant to 68.93? [68.180(a)(2)] s 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: [68.180(b)(1)] 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, pursuant to 68.90(b)(1)? [68.180(b)(1)(i)] 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)? [68.180(b)(1)(ii)] 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)] The date of the most recent notification exercise, as required in 68.96(a)? [68.180(b)(1)(iv)] Y N N/A 5. For responding stationary sources, does the owner or operator identify the date of the most recent: [68.180(b)(2)] s Review and update of the emergency response plan, pursuant to 68.95(a)(4)? [68.180(b)(2)(i)] s Notification exercise, as required in 68.96(a)? [68.180(b)(2)(ii)] s Field exercise, as required in 68.96(b)(1)? [68.180(b)(2)(iii)] s Tabletop exercise, as required in 68.96(b)(2)? [68.180(b)(2)(iv)] Y N N/A Appendix C Page 18 of 19 Rev 01/07/2021 RMP Program Level 3 Process Checklist Facility Name: _C_o_n_A__g_r_a_F__o_o_d_s_P_a_c_k_a_g_e_d__F_o_o_d_s_L__L_C_____ 6. Has the owner or operator reviewed and updated the RMP and submitted it to EPA for the following: [68.190(a)]? Five-year update. [68.190(b)(1)] Within three years of a newly regulated substance listing. [68.190(b)(2)] At the time a new regulated substance is first present in an already regulated process above threshold quantities. [68.190(b)(3)] At the time a regulated substance is first present in an new process above threshold quantities. [68.190(b)(4)] Within six months of a change requiring revised PHA or hazard review. [68.190(b)(5)] Within six months of a change requiring a revised OCA as provided in 68.36. [68.190(b)(6)] Within six months of a change that alters the Program level that applies to any covered process. [68.190(b)(7)] 7. If the owner or operator experienced an accidental release that met the five-year accident history reporting criteria (as described at 68.42) subsequent to April 9, 2004, did the owner or operator submit the information required at 68.168, 68.170(j) and 68.175(l) within six months of the release or by the time the RMP was updated as required at 68.190, whichever was earlier. [68.195(a)] 8. If the emergency contact information required at 68.160(b)(6) has changed since June 21, 2004, did the owner or operator submit corrected information within thirty days of the change? [68.195(b)] Subpart H - Other Requirements [40 CFR 68.200 - 68.210] Y N N/A Y N N/A Y N N/A Implemented Other Requirements as provided in 40 CFR 68.200-68.210? Comments: 1. Has the owner or operator maintained records supporting the implementation of this part at the stationary source for Y N N/A five years, unless otherwise provided in Subpart D: Program 3 Prevention Program? [68.200] 2. Did the owner or operator hold a public meeting to provide information 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)] Y N N/A Appendix C Page 19 of 19 Rev 01/07/2021