Georgia-Pacific Resins, Inc. - Executive Summary |
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8.1 Executive Summary Georgia-Pacific Resins, Inc. (GPRI), a wholly owned subsidiary of Georgia-Pacific Corporation, owns and operates a synthetic resin manufacturing facility in Elk Grove, CA. The resin plant was originally constructed in 1967 by Union Carbide and it was subsequently purchased by GPRI in 1982. Overall, the facility employs 31 full-time employees. GPRI is committed to operating the Elk Grove, CA plant in a manner that is safe for its workers, the public, and the environment. As part of this commitment, GPRI has established a system to help ensure safe operation of the processes at this facility. One component of this system is a risk management program (RMP) that helps manage the risks at the Elk Grove Plant and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a risk management plan (RMP Plan) describing the risk management program at the Elk Grove Plant. This document is intended to satisfy the RMP Plan requirement of the RMP rule and to provide the public with a description of the risk management program at the Elk Grove Plant. The risk management program at the Elk Grove Plant consists of the following three elements: 7 a hazard assessment to help understand (a) the potential offsite consequences of hypothetical accidental releases and (b) accidents that have occurred during the last five years associated with the use of substances regulated by the RMP rule (regulated substances). 7 a prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered processes). 7 an emergency response program to help respond to accidental releases of regulated substances from covered processes Information further describing these elements is provided in this RMP Plan. Alt hough the risk management program at the Elk Grove Plant helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety program at the Elk Grove Plant. In fact, the Elk Grove Plant has a comprehensive safety program in place establishing many levels of safeguards against release of a hazardous substance and injuries and damage from a release of a hazardous substance. GPRI limits the use of hazardous substances. Before using a hazardous substance at the Elk Grove Plant, less hazardous alternatives are considered. When a hazardous substance is used at the Elk Grove Plant, GPRI considers the potential for this substance to adversely affect plant workers, the public, and the environment and takes steps to prevent any such effects. GPRI prevents releases of the hazardous substances used at the facility. When a hazardous substance is used at the Elk Grove Plant, the equipment is carefully designed, built and operated to redu ce the likelihood of an accidental release. Industry and government standards are closely adhered to in the design, construction, and operation of the equipment. 8-1 8. FEDERAL MANDATED RMP SUBMISSION (Con't) GPRI limits damage from a release, if such a release occurs. GPRI trains its workers to respond to an accidental release, reducing the consequences of a release if it occurs. In addition, GPRI works with the local fire department and with the local emergency planning committee (LEPC) to help prevent injuries and/or environmental damage if a release does occur. The safety program at the Elk Grove Plant consists of a number of elements, only some of which are required by the RMP rule. This RMP Plan is primarily intended to describe those parts of the safety program at the Elk Grove Plant that are required by the RMP rule. 8.1.a Accidental Release Prevention and Emergency Response Policies GPRI is committed to the safety of workers and the public, and the prese rvation of the environment, through the prevention of accidental releases of hazardous substances. GPRI implements reasonable controls to prevent foreseeable releases of hazardous substances. These controls include training programs for personnel, programs to help ensure safety in the design, installation, operation, and maintenance of processes at the Elk Grove Plant; and programs to evaluate the hazards at the plant. In the event of an accidental release, the Elk Grove Plant controls and contains the release in a manner that will be safe for workers and will prevent injury to the public and the environment. GPRI provides response training to its personnel, designates an emergency response coordinator to oversee response activities, and coordinates response efforts with the local fire department. Response activities have also been discussed with the LEPC. In order to effectively implement these policies, GPRI established a management system headed by the Divisional Safety Mana ger to oversee safety-related activities. 8.1.b Regulated Substances Handled The Elk Grove Plant handles one regulated substance in sufficient quantity to be covered by the RMP rule, as shown in the following list of RMP-covered Program Level 3 processes at the plant. Regulated Substance Process Process Quantity*, lbs RMP Threshold, lbs* Formaldehyde Solution (50%) Storage in Unpressurized, Heated Tanks 192,000 15,000 * Process and threshold quantity is the quantity of "pure" chemical, not of the solution 8-2 8. FEDERAL MANDATED RMP SUBMISSION (Con't) 8.1.c Offsite Consequence Analysis The Elk Grove Plant performed an offsite consequence analysis to estimate the potential for an accidental release of a regulated substance to affect the public or the environment. The offsite consequence analysis evaluates a "worst-case release scenario" and an "alternative release scenario". GPRI does not expect a worst-case release scenario to ever occur. The alternative release sc enarios were selected to help the Sacramento County LEPC improve the community emergency response plan. An alternative release scenario represents a release that (1)might occur at a facility like the Elk Grove Plant and (2) would result in the greatest potential offsite consequences if the release occurred. The main objective of performing the offsite consequence analysis is to determine the distance at which certain effects might occur to the public because of an accidental release (called the endpoint distance). The following effects could occur at the endpoint distance. At distances less than the endpoint distance, the effects would be greater; at distances greater than the endpoint distance, the effects would be less. When considering the release of a toxic substance, most people at the endpoint distance would be able to walk away from the exposure without any long-term health consequences, although some short-term consequences (e.g., strong eye or throat irritation) are possi ble. Some people who are particularly susceptible to the substance released could be incapacitated. The RMP rule includes specific requirements for the worst-case and alternative release scenarios that must be reported by GPRI. These requirements are: 7 one worst-case release scenario for the class of toxic substances in Program 3 processes 7 one alternative release scenario for each of the toxic substances in a Program 3 process The following information summarizes the offsite consequence analysis performed by the Elk Grove Plant: 8.1.c.1. The "worst-case release scenario" for a 50% solution of formaldehyde is the release of the entire contents of a 40,000 gallon (192,000 lbs of pure formaldehyde) storage tank. A concrete diked area contains the released formaldehyde solution which evaporates and forms a vapor cloud. The maximum distance to the toxic endpoint concentration based on modeling is 1.3 mile. The U.S. Census indicates that 304 people live within this distance fr om the location of the storage tank; several public receptors are also located within this distance including nearby residences. No environmental receptors are located within this distance. 8.1.c.2. The "alternative case release scenario" for a 50% solution of formaldehyde is the overfilling of a formaldehyde storage tank and the spillage of 500 gallons (2,400 lbs of pure formaldehyde) of solution into the concrete diked area. Modeling this scenario indicates a toxic endpoint distance of 0.3 mile. There are no nearby residences within this distance from the plant. There are, however, some public receptors within this distance. No environmental receptors are located within this distance. 8-3 8.1.d Administrative Controls - Administrative controls to limit the determination for each reported scenario exists to restrict the amount of regulated chemical released to a minimum, if a release were to occur and preferably to not have a release occur. The administrati ve control is inherent in operational procedures for the regulated chemical system and the training provided to the regulated chemical operators. 8. FEDERAL MANDATED RMP SUBMISSION (Con't) 8.1.e Mitigation Measures Passive mitigation: the formaldehyde storage tank is situated within a concrete, secondary containment structure which has the capacity to contain 100% of the volume of the contents of the storage tank, should it release its contents. Active mitigation: the formaldehyde storage tank has a level readout and a high-level alarm. The plant maintains a standard operating procedure for this tank which requires the operator to manually verify the level of solution in the tank before it is filled with additional raw material. In this way, the tank should not be overfilled. Thickness testing is performed periodically to insure structural integrity and prevent ruptures. 8.1.f General Accidental Release Prevention Program-since 1982, the Elk Grove Plant has used a pre vention program to help prevent accidental releases of hazardous substances. Beginning in 1992, the plant formalized this prevention program for the resin manufacturing process to comply with the 14 elements of the OSHA process safety management (PSM) prevention program. 8.1.g Chemical-Specific Prevention Steps Formaldehyde solution-Industry standards are followed at the plant to help ensure safe handling of formaldehyde. All of the formaldehyde stored in the plant's storage vessel is delivered to the plant by offsite vendors. The formaldehyde vendor supplies formaldehyde solution via a DOT- approved tank truck and follows DOT standards when loading the formaldehyde storage tank. The storage tank's design and construction are consistent with ANSI standards. Workers who perform operations involving formaldehyde receive training emphasizing safe handling procedures for formaldehyde developed by the plant. The storage tank is surrounded by a concrete dike which is large enough to contain 100% of the volume of the tank should its entire contents be spilled. All air emissions from the storage tank are directed to a thermal oxidizer which destroys >95% of the vapors. 8-4 8.1.h Five-Year Accident History The Elk Grove Plant has completed a five year accident history that indicates no off-site releases of regulated substances. Year Number of Reported Accidents Substance Released Consequences 1994 0 None No Offsite Impacts 1995 0 None No Offsite Impacts 1996 0 None No Offsite Impacts 1997 0 None No Offsite Impacts 1998 0 None No Offsite Impacts 8. FEDERAL MANDATED RMP SUBMISSION (Con't) 8.1.i Emergency Response Program-the Elk Grove Plant has established a written emergency response program to help safely respond to accidental releases of hazardous substances. The emergency response plan includes procedures for the following: 7 informing the local fire department and the public about accidental releases that could rea sonably result in offsite consequences 7 providing proper first aid and emergency medical treatment to treat accidental human exposure to hazardous substances at the plant 7 controlling and containing accidental releases of hazardous substances, including the use of emergency response equipment 7 inspecting and maintaining emergency response equipment 7 reviewing and updating the emergency response plan The Elk Grove Plant maintains an emergency response team trained in these emergency response procedures. All plant personnel are trained in evacuation procedures. The plant periodically conducts emergency response drills. The written emergency response plan complies with other federal contingency plan regulations (e.g., the OSHA regulations 29 CFR 1910.38(a), 29 CFR 1910.120(a)) and has communicated to local emergency response officials through the local fire department. The plant maintains a regular dialogue with the local fire chief, and the plant provides appropriate informatio n to the fire chief. A copy of the plant's Emergency Response Plan is contained in Appendix D of this RMP Plan. 8.1.j Planned Changes to Improve Safety The Elk Grove Plant constantly strives to improve the safety of the processes at the facility through both the incident investigation program and a program soliciting safety suggestions from the workers. |