Pope & Talbot, Inc. Halsey Pulp Mill - Executive Summary |
|
EXECUTIVE SUMMARY POPE & TALBOT Pope & Talbot, Inc. (P&T) is a Kraft pulp mill which produces market pulps. The Pope & Talbot mill is located in Halsey, Oregon. The company is committed to operating in a manner that is safe for P&T workers, the public, and the environment. As part of this commitment, the company has established a system to help ensure safe operation of the processes at the Halsey mill. One component of this system is a risk management program (RMP) that helps manage the risks at P&T and that complies with the requirements of the Environmental Protection Agency's (EPA) regulation 40 CFR 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 (RMPlan) describing the risk management program at P&T. This document is intended to satisfy the RMPlan requirement of the RMP rule and to provide the public with a description of the risk management program at Pope & Talbot. The risk management program consists of three elements: 1. 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. 2. A prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered processes). 3. 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 RMPlan. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Pope & Talbot is committed to the safety of workers and the public, and the preservation of the environment, through the prevention of accidental release of hazardous substances. The facility implements controls to prevent foreseeable releases of hazardous substa nces. These controls include training programs for personnel, programs to help ensure safety in the design, installation, operation and maintenance of processes, and programs to evaluate the hazards. In the event of an accidental release, the facility controls and contains the release in a manner that will be safe for workers and will help prevent injury to the public or the environment. Pope & Talbot provides response training to 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 local emergency planning committee (LEPC). In order to implement these policies, P&T established a management system directed by the Safety Manager to oversee safety-related activities. REGULATED SUBSTANCES Pope & Talbot is a pulp mill primarily involved in the manufacture of bleached and semi-bleached pulp. As part of this manufacturing process, t he facility handles several regulated substances in sufficient quantities to be covered by the RMP rule, as shown in the following list of RMP-covered processes. Process Program Level Regulated Substance Process Quantity Chlorine System 3 Chlorine 720,000 Filter Plant 3 Chlorine 10,000 Secondary Fuel System 2 Propane 506,400 OFFSITE CONSEQUENCE ANALYSIS Pope & Talbot had an air-modeling consultant perform 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 consists of evaluating both worst-case release scenarios and alternative release scenarios. Pope & Talbot does not expect a worst-case release scenario to ever occur. The alternative release scenarios were selected to help local emergency response personnel to improve the community emergency response plan. An alternative release scenario represents a release that is possible but still unlikely to o ccur at the facility and would result in the greatest potential for 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 such as chlorine, 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 likely. When considering explosion of a flammable substance such as propane, people at the endpoint distance are likely to be knocked down by the blast. Windows at a distance could shatter, and the potential for structural damage to buildings exists, although a building collapse is unlikely. When considering the fire hazard of a flammable substance, people at the endpoint distance are likely to receive second-degree burns over the exposed parts of their bodies if they cannot quickly find cover or otherwise escape the heat of the flame. The RMP rule includes specific requirements for the worst-case and alternative case release scenarios. These requirements are: 7 One worst-case release scenario and an alternative release scenario for toxic substances in Program 3 processes (chlorine). 7 One worst-case and one alternative release scenario for the class of flammable substance in Program 2 (propane). The following information summarizes the offsite consequence analysis performed by P&T. Program 3-Chlorine The worst case toxic release at a facility is based on a release of the entire contents of the storage vessel that will result in the greatest distance to the toxic endpoint concentration. The largest chlorine storage vessel at the facility is a 90-ton railcar, in which chlorine is stored as a pressurized liquid. The RMP rule requires that a worst case release of pressurized liquid be modeled as a gaseous release of the entire contents of the vessel over a period of 10 minutes. The release was modeled as a 10-minute release from the railcar using BREEZEb HAZDEGADIS dispersion model. Following the requirements of the RMP rule, the release was modeled at the highest temperature in a three-year period (103 0Fahrenheit) for Eugene, Oregon, and at a wind speed of 1.5 meters per second. The model results showed that a worst case release of chlorine from a 90-ton railcar would result in a distance to endpoint of 10.54 miles (16.98 kilometers). The United States Census Bureau indicates that 10,000 people live within this distance from the railcars. The receptors within the distance to impact are an industrial facility (Fort James), schoo ls, the Corvallis Municipal Airport, and the Willamette River (recreational area public receptor). The alternative release scenario for chlorine is a failure of the 3/4-inch inside diameter piping at the connection to a 1 ton chlorine cylinder. The release was modeled from the chlorine cylinder through this piping. The release was modeled using BREEZE. HAZ DEGADIS dispersion model. The meteorological conditions used in the model were based on meteorological data for Eugene, Oregon, from 1992 to 1994, as shown in Table 1. TABLE 1. METEOROLOGICAL DATA USED IN ALTERNATIVE RELEASE MODELING Meteorological Parameter Value Most Frequent Atmospheric Stability Class D Average Temperature (degrees Fahrenheit) 53 Average Relative Humidity (%) 78.5 Most Frequent Non-Calm Wind Speed (m/s) 3.09 The modeling results showed a distance to endpoint of 5.168 kilometers (3.21 miles). The U.S. Census Bureau indicates that 650 people live with this distance from the water treatment plant. Several publ ic receptors are also located within the distance: schools and Fort James (industrial facility). Program 2-Propane The worst case flammable release at a facility is based on a vapor cloud explosion from a release at the storage vessel that will result in the greatest distance to the endpoint overpressure of 1 psi. The largest propane storage vessels at the facility are four 30,000-gallon tanks. The RMP rule allows various acceptable modeling techniques to be used to determine the distance to endpoint from a vapor cloud explosion. A simple technique that is recommended by the U.S. EPA in their Offsite Consequence Analysis (OCA) guidance document is the TNT equivalent method. The modeling consultant used the TNT equivalent method to model a propane release from one of the 30,000-gallon storage tanks. A yield factor of 0.1 was used in the modeling, as required by the RMP rules. The distance to the endpoint overpressure of 1 psi was estimated at 654 meters (0.41 miles). The U.S. Ce nsus Bureau indicates that there is no residential population in the area. The public receptor located within the impact area is Fort James (industrial facility). The alternative release scenario for the propane process is a Boiling Liquid Expanding Vapor Explosion (BLEVE) of a 30,000-gallon propane tank. The radiant heat received by an observer was calculated to determine the distance to the endpoint of 5 kW/m2. The distance to endpoint was estimated at 692 meters (0.43 miles). The U.S. Census Bureau indicates that there is no residential population in the area. The public receptor located within the impact area is Fort James (industrial facility). Please note that this distance is greater than the distance estimated for the "worst case" scenario prescribed by the RMP rule. The reason for this occurrence is that the RMP rule requires that a vapor cloud explosion be modeled for the "worst case" scenario, even though a vapor cloud explosion is not necessarily the scenario that h as the greatest distance to impact. For the Pope & Talbot facility, the greatest distance to impact is from a tank BLEVE, not a vapor cloud explosion. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Since the mill was constructed in 1969, a prevention program has been in place to help prevent accidental releases of hazardous substances. Beginning in 1992, P&T formalized this prevention program for the water treatment plant and the chlorine processes to comply with the 14 elements of the OSHA process safety management (PSM) prevention program. In 1996, the EPA RMP rule established two levels of prevention program requirements: Program 3 - essentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environment. Program 2 - requires simplified versions of 7 of the 12 elements of the Program 3 prevention program. The following sections briefly describe the elements of the prevention program that address the EPA RMP rule prevention program requirements. Program 3 Prevention Program The Program 3 prevention program for chlorine consists of the following 12 elements: Process Safety Information. P&T maintains a variety of technical documents that are used to help ensure safe operation of the processes. These documents address (1) physical properties of chlorine, (2) operating parameters of the equipment, and (3) design basis and configuration of the equipment. These documents are also used (1) to train employees, (2) to perform process hazards analyses, and (3) to help maintain the equipment. P&T ensures that this process safety information is available to all employees, the local emergency personnel, and the fire department. Process Hazard Analysis. P&T performs and periodically updates process hazard analyses (PHA's) of the covered processes to help identify process hazards and generate recommendations that might improve the safe operation of the process. A team composed of operating and engineering personnel with process operating experience and a leader with process hazard analyses experience is assembled to analyze the hazards of the process. Pope & Talbot uses the hazard and operability (HAZOP) technique supplemented with checklists, to perform this analysis. The team prepares a written report describing the results of the analyses, including a list of recommendations. Responsibility to resolve the recommendations is assigned to the process supervisory personnel and, when appropriate, changes to enhance the safety of the process are implemented. Operating Procedures. P&T personnel develop and maintain operating procedures that cover all phases of operations, including startup, normal operations, normal shutdown, and emergency shutdown. The operating procedures (1) are used to train employees and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets. Operating procedures include: 7 Steps for safely conducting activities 7 Applicable process safety information, such as safe operating limits and consequences of process deviations 7 Safety and health considerations, such as chemical hazards, personal protective equipment requirements, and actions to take if exposure to a hazardous substance occurs. Training. P&T trains workers to safely and effectively perform assigned tasks. The P&T training program includes both initial and refresher training that covers (1) a general overview of the process, (2) the properties and hazards of the substances in the process, and (3) a detailed review of the process operating procedures and safe work practices. Written tests are used to verify that an employee understands the training material before the employee can resume work in the process. Mechanical Integrity. Pope & Talbot maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public, or the environment. The mechanica l integrity program includes (1) an inspection and testing program to help identify equipment deterioration and damage before the equipment fails and (2) a quality assurance program to help ensure that new and replacement equipment meet the design standards required for service in the covered processes. The mechanical integrity program includes: 7 Specifications for inspection and testing of process equipment. 7 Specifications for replacement parts and equipment 7 Procedures for inspecting, testing and maintaining process equipment 7 Procedures for safe work practices such as lockout/tagout, hot work, confined space entry, and line or equipment opening 7 Training of maintenance personnel 7 Documentation of maintenance activities Management of Change. The management of change program evaluates and approves all proposed changes to chemicals, equipment and procedures for a covered process to help ensure that the change does not negatively affect safe operations. Process changes that are determined to be a replacement in kind (e.g., replacing a valve with an identical valve) are allowed without completing a full management of change program. All other changes must be confirmed through the full management of change program to help ensure that inadvertent consequences of process changes are prevented, safety consequences of changes are addressed, affected process safety information and procedures are updated, and affected employees are notified of the changes. Pre-Startup Review. The company performs a safety review of a new or modified process before the process is placed into service to help ensure that the process has been prepared to operate safely. This review confirms that: 7 Construction and equipment are in accordance with design specifications 7 Safety, operating, maintenance and emergency procedures are in place 7 Employee training has been completed 7 A process hazard analysis has been performed if the process is new or management of change requiremen ts have been completed if an existing process has been modified Compliance Audit. Pope & Talbot audits covered processes to be certain that the prevention program is effectively addressing the safety issues. P&T assembles an audit team that includes personnel knowledgeable in OSHA's Process Safety Management, RMP rule and in the process. This team evaluates whether the prevention program satisfies the requirements of the OSHA rule and the RMP rule and whether the prevention program is sufficient to help ensure safe operation of the process. The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented. Incident Investigation. P&T investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment so that similar accidents can be prevented. P&T trains employees to identify and report any incident requiring investigation. An investigation te am is assembled, and the investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved, and appropriate process enhancements are implemented. Employee Participation. P&T has a written employee participation program for covered processes to help ensure that the safety concerns of workers are addressed. P&T encourages active participation of personnel in the prevention program activities of all processes at the facility. Employees are consulted on and informed about all aspects of the prevention program, including process hazard analyses and operating procedures. Hot Work Permits. P&T has a hot work permit program to control spark or flame producing activities that could result in fires or explosions in covered processes at the Halsey mill. The mill reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a) and created a Hot Work Permit Form to comply with these requirements. Person nel who are to perform hot work are required to fill out the Hot Work Permit form. The Shift Supervisor reviews the completed form before work can begin. Training in the use of the Hot Work Permit Form is included in the P&T safe work practices orientation. Contractors. Pope & Talbot has a program to help ensure that contractor activities at the Halsey mill are performed in a safe manner. The program reviews the safety record of all contractors to help ensure that only contractors who can safely perform the desired job tasks are hired. P&T explains to the contract supervisors the hazards of the process on which they and their employees will work, P&T safe work practices, and P&T emergency response procedures. P&T requires that the contractor supervisors train each of their employees who will work at the mill before that worker begins work at the Halsey mill. P&T periodically reviews contractors' training documents and work performance to help ensure that safe work practices are followed. Program 2 Prevention Program The P&T Program 2 prevention program, which applies to the Propane Storage process, consists of the following seven elements: Safety Information. P&T maintains technical documents for the Propane Storage process similar to those described in the process safety information element of the Program 3 prevention program section. Hazard Review. P&T performs and periodically updates hazard reviews of the Propane Storage process to help identify and control process hazards. The hazard review was conducted using the HAZOP technique similar to the Program 3 process hazard analysis. Operating Procedures. P&T develops and maintains operating procedures for the Propane Storage process similar to those described in the operating procedures element of the Program 3 prevention program section. Training. P&T trains workers to safely and effectively perform assigned tasks. The P&T training program includes both initial and on the job training that cover s (1) a general overview of the process, (2) the properties and hazards of the substances in the process, and (3) a detailed review of the process operating procedures and safe work practices. Maintenance. The propane storage tanks are maintained and serviced by the propane vendor. Compliance Audits. P&T performs periodic compliance audits of the propane system to verify that it is operating in compliance with the requirements of the RMP rule. A compliance audit report is prepared after each audit, and any deficiencies noted by the audit are corrected in a timely manner. Incident Investigations. The incident investigation element of the P&T Program 3 prevention program is also used for the Propane Storage process. CHEMICAL-SPECIFIC PREVENTION STEPS In addition to the required prevention program elements, P&T has implemented safety features specific to the hazardous substances used at P&T. The following paragraphs describe some of these safety features. Chlorine. Chlorine i s supplied in DOT-approved 90-ton railcars and 1-ton cylinders. Chlorine is used in pulp bleaching and in water treatment. For the water treatment, chlorine is fed through piping to an eductor, where it is absorbed into process water for use in the water treatment unit. The length of piping containing chlorine is kept to a minimum to reduce the likelihood of a release. There is an area sensor that will close the valve to the 1-ton cylinder if high chlorine leaks are detected. In the pulp mill where the chlorine is processed from the railcars, there are chlorine detectors and alarms. A release in this area can be mitigated through the use of a blow down tank, sensors in the tank and monitoring the temperature and pressure of the chlorine gas as it vaporizes. If one of the operating parameters drops below the minimum operating level, control valves close the line to the Cl2 rail car. Propane. Industry standards concerning propane are followed to help ensure safe handling of prop ane. The propane vendor supplies propane via a DOT-approved tank truck and follows DOT standards when loading the propane storage tank. The storage tanks design, construction and location are consistent with NFPA 58 code. The propane storage tanks are equipped with pressure relief valves to prevent over pressurization. FIVE YEAR ACCIDENT HISTORY Pope & Talbot has completed a five-year accident history for propane and chlorine. There have been no propane accidents and only one minor accident at the Fort James facility with chlorine that resulted from a 7-lb. release in the past five years. Year Number of Reported Accidents Substance Released Consequences 1994 None 1995 None 1996 None 1997 None 1998 1 Chlorine On September 17, 1998, 7-lb. of chlorine was released as the HOCl generators were starting up after being down for maintenance. 1999 None Emergency Response Programs P&T has established a written emergency response program to help safely respond to a ccidental releases of hazardous substances. The emergency response plan includes procedures for: 7 Informing the local fire department and the public about accidental releases that could reasonably result in offsite consequences 7 Providing proper first aid and emergency medical treatment to treat accidental human exposure to hazardous substances at P&T 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 P&T maintains an emergency response team trained in these emergency response procedures. All P&T personnel are trained in evacuation procedures. P&T periodically conducts emergency response drills on site with the Pope & Talbot emergency response teams and also coordinates drills with the local fire department. The written emergency response plan complies with other federal contingency plan regulatio ns (e.g., the OSHA regulations 29CFR 1910.38(a)) and has been communicated to local emergency response officials through the local fire department. P&T maintains a regular dialogue with the local fire chief, and P&T provides appropriate information to the fire chief. PLANNED CHANGES TO IMPROVE SAFETY P&T constantly strives to improve the safety of the processes at P&T through both the incident investigation program and a program soliciting safety suggestions from the workers. The following changes to improve safety are planned or have recently been completed. Because of the accidental release in September 1998, P&T reviewed the chlorine handling system and eliminated excessive condensation in the equipment with nitrogen. These changes reduce the likelihood of a chlorine release caused by degraded equipment or external impact. |