Donohue Industries Lufkin Texas Mill - Executive Summary |
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Donohue Industries Inc., Lufkin Texas I. EXECUTIVE SUMMARY Donohue is committed to operating in a manner that is safe for Donohue employees, for the public, and for the environment. As part of this commitment, Donohue has established a system to help ensure safe operation of the processes at this facility. One component of this is a risk management program (RMP) that helps minimize the risks at Donohue and that complies with the requirements of the Environmental Protection Agencys (EPAs) regulation 40 CFR part 68, Accidental Release Prevention requirements: Risk Management Programs ( the RMP rule). One of the requirements of the rule is to submit a risk management plan (RMPlan) describing the risk management program at the Donohue, Lufkin Mill. This document is intended to summarize and communicate the RMP elements for the interested public and satisfy the RMPlan requirement of the RMP rule. 1.1 Accidental Release Prevention and Emergency Response Policies Donohue is commit ted to the safety of employees and the public and the preservation of the environment through the prevention of accidental releases of hazardous chemicals. These controls include: training programs for personnel; programs to help ensure safety in the design, installation, operation, and maintenance of processes at Donohue; and programs to evaluate the hazards at Donohue. In the event of an accidental release, Donohue will control and contain the release in a manner that will be safe for workers and will help prevent injury to the public or the environment. 1.2 Donohues Regulated Substance Donohue is an integrated pulp and paper mill primarily involved in the manufacture of bleached pulp and related finished paper products. Donohue handles chlorine in sufficient quantities to be covered by the RMP rule. Chlorine is an integral part of the paper making process and is used to bleach pulp and disinfect water. 1.3 Offsite Consequence Analysis Worst Case Scenario The Environmental P rotection Agency (EPA) requires a worst-case release scenario analysis and an alternative release scenario analysis for chlorine. The worst-case scenario is intended to provide an estimate of the maximum possible area that might be affected under catastrophic conditions. In other words, the worst-case release is based on EPAs estimate of the worst possible accident that could occur at any given facility. The worst-case scenario at Donohue Lufkin Mill involves one of the railcars that transports chlorine to the site and stores chlorine prior to its use in the bleaching process. The RMP rule requires Donohue to assume that all the contents of the railcar will be released in 10 minutes. The worst-case scenario also assumes that no safety equipment operates properly and no plant personnel respond to contain the leak. The EPA-defined endpoint for this analysis is estimated to be beyond the boundaries of the facility. Donohue does not expect the worst-case scenario to occur. Alternati ve (more-likely ) Release Scenario Although the probability of a release remains small, the alternative release scenario is intended to represent what is more likely to happen in the event there is a release. For the Donohue Lufkin Mill, the alternative release scenario for chlorine involves a 5/16-inch hole in the 1-inch diameter chlorine transfer hose. This analysis was completed using appropriate information concerning physical location, detection methods, equipment layout and expected response time along with the guidelines provided by the EPA. The endpoint concentration would extend slightly beyond the plant boundaries. 1.4 Accidental Release Prevention Programs and Chemical-specific Prevention Steps Donohue complies with the OSHA Process Safety Management Rule (29 CFR 1910.119) and with the EPA RMP rule. The accident prevention programs in place at Donohue include: distribution of safety information, hazard analysis and review, defined operating procedures, training of personn el, proper maintenance of systems, thorough evaluation of process changes and safety checks of new processes. Safety Information - Donohue maintains a variety of technical documents that are used to help ensure safe operation of the Mills processes. Material safety data sheets (MSDSs) document the physical properties of hazardous substances handled at Donohue, including substances regulated under the RMP rule. Hazard Analysis / Hazard Review - Donohue performs and periodically updates hazard reviews of the covered processes to help identify and control possible accidental releases. Operating Procedures - Donohue develops and maintains operating procedures to define how tasks should be safely performed. The operating procedures are used to train employees and to serve as reference guides for appropriate actions to take during both normal operations and process upsets. Training - Donohue trains personnel to safely and effectively perform their assigned tasks. This in cludes initial and refresher training for Operations and Maintenance personnel. Maintenance - The Donohue maintenance program includes (1) procedures to safely guide workers in their maintenance tasks, (2) worker training in maintenance procedures, (3) an inspection and testing program, and (4) a quality assurance program. Managing Change - Donohue evaluates and approves all proposed changes to chemicals, equipment, and procedures for covered processes. Safety consequences of changes are addressed, safety information and procedures are updated, and affected employees are notified of the changes. Pre-startup Safety Review - Donohue performs safety reviews of new or modified covered processes before they are placed into service to help ensure safe operation. Compliance Audit - Donohue performs periodic compliance audits of covered processes to verify that they are operating in compliance with the requirements of the RMP rules. A compliance audit report is prepared after each audit and any deficiencies noted by the audit are corrected in a timely manner. Incident Investigation - Donohue investigates all incidents that could have resulted in serious injury to personnel, the public, or the environment so that future accidents can be prevented. The results of the investigation are documented, recommendations are resolved, and appropriate process improvements are implemented. Employee Participation - Donohue involves Mill personnel in the prevention program activities of all processes at the facility. Hot Work Permits - Donohue has a hot work permit program to control spark or flame producing activities that could result in fires or explosion as outlined in OSHAs fire prevention and protection requirements (29 CFR 1910.252). Contractors - Donohue has a program to help ensure that contractor activities at the Donohue facility are performed in a safe manner. Chemical-Specific Prevention Steps for Chlorine - Industry standards are followed a t Donohue to help ensure safe handling of chlorine. The vendors supply chlorine in Department of Transportation (DOT) approved containers. Workers who perform operations involving chlorine receive training for the safe handling procedures for chlorine. 1.5 Five-Year Accident History The RMP rule requires Donohue to maintain a five-year accident history of all accidental releases from covered processes that resulted in death, injury, significant on-site property damage, off-site property damage, evacuations, shelter-in-place, or off-site environmental damage. The Lufkin Mill has done an excellent job in preventing accidents and in five years there have been only two minor incidents involving chlorine. Both incidents involved a release of less that one pound of chlorine and did not result in any significant injuries. Further, neither of the two releases resulted in any off-site consequences. 1.6 Emergency Response Programs An Emergency Response Plan has been developed for the Lufkin Mill. The response portion of this plan includes: permanent fire protection systems, mobile fire fighting and hazardous material handling equipment, training for employees and emergency responders, a computer modeling program to predict the movement of air-borne materials , and a mutual aid agreement with City of Lufkin Fire Department. Notification capabilities include: alpha-numeric pagers for the emergency response team (personnel assigned to each shift), 24 hour on-site fire/ safety inspectors (EMT certified), and a rotating emergency call list. 1.7 Planned Changes to Improve Safety Donohue is committed to the process of continuous improvement. Improvements in the safety and environmental aspects of the operation are critical components of the commitment. The following changes to improve safety are planned or have recently been completed. 7 The facility is investigating alternative chemicals for bleaching. Chlorine in railcars will not be used after May 2001. 7 There h as been a reduction of chlorine cylinder inventories stored on-site. By reducing the chlorine inventory, the potential consequences of an accidental release were also reduced. 7 Several chlorine monitors and alarms have been added for the cylinder systems to help alert operators of upset conditions. 7 Rollers were added under the chlorine cylinders to help prevent the possibility of a liquid release. |