S.D. Warren Co. ( Muskegon Mill) - Executive Summary
Risk Management Plan |
S.D. Warren Company
I. Executive Summary
A. Accidental Release Prevention and Emergency Response Policies
S.D. Warren Company is committed to operating its integrated pulp and paper mill in Muskegon, Michigan in an environmentally responsible manner and to providing a safe work place for its employees and the surrounding community. As part of this commitment to environmental stewardship and employee safety, Muskegon has developed and implements numerous environmental and safety programs that are designed to eliminate and/or drastically reduce the potential for accidental releases. S.D. Warren has also developed and implements a number of programs that are designed to ensure that if an accidental release occurs, it will be handled in a manner that minimizes adverse impact to people, the environment and the mill. Many of these programs have been in place since the late 1980s.
S.D. Warren believes that sa
fety, health and environmental protection are essential to responsibly operating its facilities. S.D. Warren views accident prevention, and personnel and environmental protection as a continuous process. Consequently, S.D. Warren continuously strives to improve its accident prevention, environmental protection and emergency response programs. A recent addition to S.D. Warrens overall accident prevention and response program is the development of the Muskegon mills Risk Management Program. Muskegons risk management program complies with the U.S. Environmental Protection Agencys ("EPAs") Chemical Accident Prevention rule found at 40 C.F.R. Part 68. One of the requirements of this rule is to submit a Risk Management Plan (RMP) to the EPA. This document satisfies the requirement by providing the public with information about processes, accident prevention programs and emergency response planning efforts at the Muskegon mill. Muskegons compliance with EPAs RMP rule includes:
1. Completion of a hazard assessment in compliance with 40 C.F.R. Part 68, Subpart B, including the five-year accidental release history--Muskegon has not experienced an RMP reportable release or accident in the last five years.
2. Implementation of an accident prevention program. The mills RMP program to prevent accidental releases of regulated chemicals from covered processes complements the existing Process Safety Management (PSM) program which was developed under similar rules administered by the Occupational Safety and Health Administration "OSHA";
3. Implementation of an emergency response program. As recommended in the RMP rule and by numerous federal response entities, the mill maintains and implements an integrated contingency plan (ICP) that is designed to meet emergency response planning requirements under a number of applicable state and federal emergency response and accident prevention planning laws.
Additional information regarding how S.D. Warren addresses eac
h of these requirements is summarized below and in the attached RMP.
While the RMP program at Muskegon helps ensure that the facility is maintained and operated in a safe and environmentally responsible manner, it is just one component of S.D. Warrens comprehensive safety and environmental programs. Additional components of the RMP include, but are not limited to:
1. Maintenance of a fully equipped and trained emergency response team (ERT).
2. Regular employee/contractor safety training;
3. Participation with and representation on the local emergency planning committee (LEPC);
4. Periodic table-top and full scale safety and emergency response drills;
5. Acquisition and maintenance of emergency response and personnel protective equipment;
6. Development of safe work practices (e.g. confined space, lockout/tagout);
7. Implementation of safe work procedures;
8. New project safety review procedures;
9. Preventive maintenance procedures;
10. Material chemical intake and purchasin
11. Medical emergency response training;
12. Contractor certification;
13. Forklift training; and
14. Coordinated training and drills with the local fire departments.
The mill and all equipment are designed and operated to minimize the possibility of an accidental release. At a minimum, the mill and equipment meet government and industry design and construction standards.
Muskegons commitment to environmental stewardship and providing a safe workplace is illustrated by the fact that it maintains and implements a single, easy to use Integrated Contingency Plan (ICP). The ICP is designed to provide more-effective emergency response guidance and to comply with a number of state and federal emergency response and accident prevention planning laws.
B. RMP Covered Processes and Regulated Substances
As of June 21, 1999, the Muskegon mill is an integrated pulp and paper mill primarily involved in the manufacture of bleached pulp and fine coated papers. The only che
micals present at the mill in sufficient quantities to be regulated by the RMP rule are chlorine and chlorine dioxide. Chlorine and chlorine dioxide are used in the bleaching process and chlorine is used in the water treatment process (collectively referred to as "covered processes"). Chlorine is stored in 90-ton rail cars for the pulp bleaching process. Chlorine is stored in 2000 lb. cylinders in the water treatment process. Chlorine dioxide comprises approximately 1% of a liquid mixture that is stored in two 15,000 gallon tanks that are surrounded by dikes.
The maximum amount of chlorine in a covered process is 360,000 lbs. The maximum amount of chlorine in a single rail car is 180,000 pounds. The maximum amount of chlorine dioxide in a covered process is 2500 pounds. The maximum amount of chlorine dioxide in a single vessel is 1,250 pounds.
C. Off-site Consequence Analysis
An off-site consequence analysis is required by the RMP rule to estimate potential impacts to the com
munity. As required by RMP, Muskegons off-site consequence analysis included evaluation of a worst-case accidental release for all toxic chemicals and an alternative release for each covered chemical.
A worst-case release is defined by EPA as "a release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to an endpoint defined in ' 68.22." 40 C.F.R. ' 68.3. EPA requires the worst-case accidental release to be modeled using highly conservative meteorological data designed to result in the maximum possible adverse impact. For example, EPA requires worst-case models to be based on the hottest day of the year, occurring at night with a very slow, steady wind which would not disperse a release very effectively. Further, the model assumes that the entire contents of the largest vessel is released instantaneously. According to the chlorine institute, no 90-ton rail car has ever instantaneously released its conten
ts, and the chances of such an event occurring on Lake Michigan on a 980F night when the wind is blowing at 3.4 miles per hour is extremely remote.
Under the EPA mandated scenario described above, the worst-case release at the mill (for purposes of RMP) would result in a vapor cloud that could extend beyond the mills property line.
Muskegon developed alternative scenarios for chlorine and chlorine dioxide which focus on more realistic release scenarios occurring during more common meteorological conditions. However, EPA requires modeling of a release which could impact off-site locations. After considering all criteria in the RMP rule, the process hazard analyses ("PHAs") performed on covered processes, and all past releases from covered processes, Muskegon chose the following three alternative release scenarios:
1. A gasket failure in the chlorine liquid line from the 90-ton rail car to the vaporizer building;
2. The failure of a valve whip; and
3. The insufficient supply o
f water to the chlorine absorption tower.
Each of these release scenarios could result in a vapor cloud that could extend beyond the mills property line.
D. Accident Release Prevention Program
Muskegon has developed an accidental release prevention program that is designed and implemented to drastically reduce the possibility of an accidental catastrophic release. The program complies with the requirements of OSHAs Process Safety Management rule found at 29 C.F.R. Part 1910.119 and analogous RMP requirements found at 40 C.F.R. Part 68, Subpart D. To comply with the RMP rule, the mill has taken its existing PSM program and incorporated an additional focusprotection of the public.
The basic elements of Muskegons prevention program are described below:
1. Employee Participation. Muskegon has developed and implements a written plan of action regarding employee participation in the safety and accident prevention process. The plan describes how employees are: (A) cons
ulted and what input they will have in the development of Process Hazard Analysis (PHA) and other PSM and RMP safety elements; and (B) given access to PSM and RMP information at the mill.
2. Process Safety Information. In accordance with applicable requirements, Muskegon has compiled and maintains process safety information about the design, installation, maintenance, and operations of its covered processes. This ensures that information remains current.
3. Process Hazard Analyses. Muskegon performed process hazard analyses (PHA) on its PSM/RMP covered processes. The PHA is a key component of the process safety management system and Muskegons RMP accident prevention program. It is a thorough, orderly, systematic approach for identifying, evaluating, and addressing potential hazards posed by the covered processes.
Specifically, the PHA addressed: (1) hazards of the process; (2) engineering and administrative controls applicable to the hazards and their interrelationsh
ips such as appropriate application of detection methodologies to provide early warning of releases (e.g., process monitoring and control instrumentation with alarms); (3) consequences of failure of engineering and administrative controls; (4) facility siting; (5) human factors (human error); and (6) a qualitative evaluation of a range of the possible safety and health effects of failure of controls on the employees in the work place.
4.Operating Procedures. Muskegon has developed and implements written operating procedures that provide clear instructions for safely operating the covered processes. These procedures are consistent with the process safety information described earlier and include:
B. Normal operations;
D. 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 timel
E. Emergency Operations;
F. Normal shutdown;
G. Startup following a turnaround, or after an emergency shutdown;
H. Consequences of deviation from operating limits;
I. Steps required to correct or avoid deviation;
J. Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment;
K. Control measures to be taken if physical contact or airborne exposure occurs;
L. Quality control for raw materials and control of hazardous chemical inventory levels; and
M. Safety systems and their functions.
Muskegon has also developed and implements safe work practices that provide for the control of hazards during operations. For example, Muskegon has programs that govern the following activities: lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into PSM and RMP covered process areas of the mill by maintenance, contractor or other support personnel.
5. Training. Mus
kegon provides employees, contractors and visitors with training that
focuses on the special safety and health hazards posed by the mills operations, RMP and PSM covered processes, emergency operations including shutdown, and safe work practices
applicable to the employees job tasks. Muskegon confirms that employees and contractors involved in operating covered processes have successfully completed the required periodic training. Muskegon documents that covered employees and contractors have received and
understood the required training. Documentation, at a minimum, includes the identity of
the employee or contract employee, the date of training, and the means used to verify that
the employee understood the training.
6. Contractors. As part of Muskegons contractor selection process it obtains and evaluates information regarding contract employers safety performance and programs. 29 C.F.R. ' 1910.119(h). Muskegon also:
A. Informs contract employers of the known pot
ential fire, explosion, or toxic release hazards related to the contractors work and the covered processes;
B. Explains to contract employers the applicable provisions of the facilitys integrated contingency plan (discussed below); and
C. Controls the entrance, presence and exit of contract employers and contract employees in covered process areas.
7. Pre-startup Safety Review. As required, following modifications to a covered process, a pre-startup review is conducted to ensure that the process is constructed and the equipment is designed in accordance with specifications; and that appropriate safety, operating, maintenance, and emergency procedures are in place to adequately protect the health and safety of employees and the nearby public.
8. Mechanical Integrity. Muskegon has developed and implements written procedures to maintain the ongoing integrity of the process equipment listed below. Muskegon also trains employees to maintain the following process equipment:
ure vessels and storage tanks;
B. Piping systems (including piping components such as valves);
C. Relief and vent systems and devices;
D. Emergency shutdown systems;
E. Controls (including monitoring devices and sensors, alarms, and interlocks); and
9.Hot Work Permit. As part of its overall fire protection program, Muskegon implements a hot work permit program for all hot work operations (e.g., welding, soldering, etc.) conducted on or near covered processes.
10. Management of Change. Muskegon has established and implements a procedure to authorize and document changes in covered processes. This procedure ensures that all required considerations are addressed prior to any change being implemented.
11. Incident Investigation. Muskegon investigates each incident which resulted in, or could reasonably have resulted in, a significant release of a highly hazardous chemical in the workplace. An incident investigation team is established and consists of at least one pe
rson knowledgeable in the process involved, including a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident.
12. Emergency Planning and Response. Muskegon has developed an integrated contingency plan that satisfies all applicable state and federal emergency response and accidental prevention planning requirements (described under emergency response policies below).
13. Compliance Audits. Muskegon has evaluated its compliance with OSHAs PSM Standard at least every three years to verify that the procedures and practices it has developed are adequate and being followed. A similar schedule for RMP will be established.
14. Trade Secrets. Muskegon makes all necessary information available to those persons responsible for compiling process safety information and those assisting in the development of the process hazard analysis.
E. Five Year Accident Histor
The Muskegon mill has not experienced an RMP reportable incident from a covered process during the last five years.
F. Emergency Response Procedures and Policies
Muskegon maintains a fully trained emergency response team (ERT) that is on-site 365 days a year, 24 hours a day. These teams are capable of minimizing the adverse impact from reasonably foreseeable accidental releases that may occur.
In the unlikely event that an accidental release occurs that is beyond the capabilities of Muskegons Hazardous Material Response Team and Fire Brigade, the mill has entered into informal mutual aid agreements with the Muskegon Fire and Police Departments, Mercy Hospital, Muskegon General Hospital, North Ottawa Hospital (Grand haven), and several private response providers. These entities are available to respond to emergencies at the Muskegon mill upon request by Muskegon. The Muskegon Fire Department operates under a mutual aid agreement with the Fire Departments of Norton Shores, Mus
kegon Heights, and Muskegon Township to ensure that additional emergency response personnel and equipment are available to respond to a significant release at the mill.
Muskegon has also adopted and implements an Integrated Contingency Plan that meets the regulatory requirements of the following federal and state response planning and prevention laws:
7 OSHA Emergency Response Plan (29 C.F.R. 1910.120(q));
7 OSHA Process Safety Management emergency response requirements (29 C.F.R. ' 1910.119(n));
7 OSHA Hazard Communication Plan (29 C.F.R. ' 1910.1200(h));
7 EPA Risk Management Plan Emergency Response Program (40 C.F.R. ' 68.95);
7 EPA Hazardous Waste Contingency Plan (40 C.F.R. ' 264.51-.56);
7 EPA Oil Spill Prevention Control and Countermeasure Plan (40 C.F.R. ' 112.7);
7 EPA Best Management Practices Plan (40 C.F.R. ' 112.104(b)); and
7 Michigan Pollution Incident Prevention Plan (245 M.R.S.A. ' 5).
The ICP includes, among other things:
7 Procedures for notifying the publi
c and the local emergency responders;
7 Arrangements for first-aid procedures and emergency medical treatment procedures for exposure to chlorine and chlorine dioxide;
7 Emergency response and incident termination procedures;
7 Procedures for using, inspecting and testing emergency response equipment;
7 Employee training procedures; and
7 Procedures to amend the ICP plan.
G. Planned Changes
The Muskegon mill is committed to continuing to evaluate opportunities to substitute more hazardous chemicals with less hazardous chemicals. For example, the Muskegon mill plans to decrease the quantity and/or use of elemental chlorine in the future.