Fort James LLC Camas Mill - Executive Summary |
|
ES.1 FORT JAMES LLC POLICIES ON ACCIDENTAL RELEASE PREVENTION Corporate Commitment The management and employees of the Fort James LLC Camas Mill are committed to responsible stewardship of the environment, protection of the community, protection of employee health, and assurance of product safety. Management systems in compliance with the applicable regulations have been developed to prevent the release of regulated substances, especially in locations which may cause detrimental effects to employees, the community, or the environment. This is accomplished through a systematic evaluation of process design, process technology, operational procedures, maintenance activities, non-routine procedures, emergency preparedness, training, and several other factors. The Fort James LLC Camas Mill has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement process controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release. The Fort James LLC Camas mill plans to meet or surpass all regulatory requirements. In the attempt to accomplish this goal, the management systems at Camas have been developed in such a way that the hazards are identified, understood, and controlled to prevent accidents. The RMP regulated chemicals include chlorine and chlorine dioxide. ES.2 DESCRIPTION OF CAMAS MILL, REGULATED SUBSTANCES AND REGULATED PROCESSES Mill Description The Fort James LLC Camas Mill is located on 185 acres adjacent to the Columbia River in Clark County, Washington. It has occupied this site since 1883 when it was constructed to supply newsprint for the Portland area. The Mill currently produces over 600,000 tons per year of cut s ize, tissue, toweling and communication papers. Raw materials in the form of wood chips, sawdust, waste paper and pulp arrive from all over the Northwest by truck, barge and rail car. The Camas Mill uses both the kraft and magnesium bisulfite (MGO) processes to convert wood chips and sawdust into pulp. Kraft pulp is produced from chips and sawdust. Brown pulp is then bleached in one of three bleach plants. Most of the paper grades produced contain a blend of these pulps and as well as purchased pulp and secondary fiber recycled from waste paper. Paper is made on twelve different machines, half of them producing towel and tissue grades and the other half communication paper grades. The oldest machine dates from 1910 and the newest from 1984. Daily production ranges from 30 tons per day on the smallest to over 600 tons per day on the newest and largest. Rolls of paper from the machines are sold directly to printers and converters or further processed into finished goods. The mi ll also operates a pulp dryer to produce baled pulp for internal use or sale to outside customers. Waste water is treated and discharged to the main channel of the Columbia River. The clarifier, aeration ponds and waste fiber landfill are located on Lady Island, a 476 acre site separated from the mill by the Camas Slough. The Camas Mill employs about 1470 people from the local area. Most processes operate 24 hours a day, 7 days a week and 52 weeks a year. Production equipment can be shut down for cleaning maintenance or to control output. The entire facility is shut down periodically for maintenance and cleaning. Several other Fort James operations are located north of the mill site. These include Specialty Chemicals, the Camas Business Center and Corporate Environmental Services. Of these, only Specialty Chemicals stores and uses chemicals regulated under the 40 CFR Part 68. Regulated Substances and Processes The Camas mill stores two chemicals above the threshold limits o f 40 CFR 68.130. Chlorine is stored at the bleach plant in 90-ton rail cars and a 450 gallon level tank, and at the filter plant and Specialty Chemicals Plant in 1-ton cylinders. Chlorine dioxide, manufactured in the Lurgi and R-8 systems, is stored in tanks located in the bleach plant. ES.3 ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS AT THE CAMAS MILL EPA's Accidental Release Prevention Program (40 CFR Part 68) requires industries to demonstrate that they have implemented an Accident Prevention Program. This section briefly describes the elements of the Fort James LLC Camas Mill program. A program has been developed to comply with OSHA's 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals, and EPA's 40 CFR part 68 subpart D, Accidental Release Prevention Provisions in the Risk Management Program. The Prevention Program consists of 12 elements which help Fort James LLC at Camas to minimize releases of regulated substances. Employee Participation Camas mi ll employees are involved in the development and implementation of the elements of Process Safety Management and the Prevention Program, with the understanding that their participation is a key factor to the success of any program. Fort James LLC is committed to maintaining a safe workplace, and as a result employees are responsible for adhering to the PSM/RMP regulations. Fort James LLC has committed to the following: o Including employees in Process Hazard Analyses o Consulting employees on the development of PSM/RMP regulation elements o Providing employees with access to the information developed through the PSM and RMP rules. A description of the Employee Participation Program is provided in the Process Safety Management central files. The PSM Coordinator is responsible for ensuring the Employee Participation program is implemented. Process Safety Information Camas mill employees are provided with the necessary information about the process equipment to conduct their jobs in a safe manner. A complete compilation of Process Safety Information (PSI) is made available to those involved in operating and maintaining the PSM/RMP regulated processes. The PSI includes the following: o Hazards from chemicals used or produced by the process o Information pertaining to the technology of the process o Information pertaining to the equipment in the process A manual containing the PSI for each regulated process is available in the PSM Central files. The Supervisor of each area, in conjunction with the PSM Coordinator, are responsible for ensuring the PSI remains up to date. Process Hazard Analysis The Accident Prevention Program is designed to provide appropriate resources to make the working environment around regulated substances safe. To assist in assuring safety, hazards are identified through the Process Hazard Analyses performed on each of the areas regulated by PSM/RMP. Process Hazard Analyses (PHA) have been performed on the regulated processes, an d will be updated at least every five years to assure that the PHA remains applicable to any process improvements and changes. The level of detail in the PHA is intended to be appropriate to the complexity of the process. A copy of each PHA is available in the PSM Central files. The PSM Coordinator is responsible for scheduling the PHAs and notifying the supervisor of maintenance, engineering, and operations of the area. The supervisors are responsible for ensuring appropriate representatives participate in the PHA. The ongoing recordkeeping requirements for process hazard analysis are: o Documentation that shows what actions are to be taken as a result of the PHA; a written schedule of when these actions are to be completed; communication of these actions to operating; maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions. o Documentation that shows the recommendations from the PHA are resolved in a timely manner. o Document that all PHA's are updated at least every five years. Standard Operating Procedures Written operating procedures have been developed and implemented. These procedures provide clear instructions for safely conducting activities involved in each of the PSM/RMP-regulated processes. The procedures are utilized by employees who work in or maintain the process. Copies of the Standard Operating Procedures are available in the corresponding control rooms. The PSM Coordinator is responsible for notifying the supervisor of the process area the date by which the SOP needs to be re-certified. The supervisor of the process is responsible for ensuring the manual is reviewed and certified annually. The ongoing recordkeeping requirements for the standard operating procedures are: o Proof of certification annually that the standard operating procedures are current and accurate. o Documentation of training for Fort James LLC staff and contractors in applying the SOPs Training Appropriate resources are provided to ensure adequate training of personnel involved in operating the regulated processes and to ensure that the jobs can be performed safely. The training program includes initial training, refresher training, and training documentation. Employees currently involved in operating a regulated process, and employees being transferred into a regulated process, are trained in an overview of the process and in the standard operating procedures. This initial training also includes emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks. Refresher training is provided at least every three years to employees involved in operating a regulated process to assure that the employee understands and adheres to the current standard operating procedures of the process. Each employee involved in operating a regulated process must verify that (s)he has recei ved and understood the required training. A record is prepared that contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training. The training programs and documentation are available in the PSM Central files. The area supervisors are responsible for ensuring employees in their area are appropriately trained. The ongoing recordkeeping requirements for training are: o A written record that contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training. Contractors Contractors periodically perform work in and around processes that involve regulated substances. To ensure safety, the Camas mill has developed a Contractor Program to inform and manage contract employees working in the PSM/RMP regulated systems. The program has been developed to establish a screening process so that only those contractors who have a commitment to safe work practi ces are hired. The contractor program includes all activities that have the potential for affecting process safety, including the performance of maintenance or repair, turnaround, equipment installation, renovation, demolition, or specialty work on or adjacent to the PSM/RMP regulated processes. A mill wide Contractor Program Manual is available in the PSM Central files and through the Camas Mill Purchasing Department, to document the safety practices and to document the training of mill staff and contractors. Pre-Startup Safety Review The Camas mill has procedures to ensure a new, or significantly modified, facility in a regulated process is as safe as possible before starting the system. To assist in assuring safety, a Pre-Startup Safety Review (PSSR) is performed before regulated substances are introduced to the system. The PSSR verifies the following information: o A PHA has been complete, if it is a new process o Construction/equipment is in accordance with the design specif ications o SOPs are complete o Training is complete Records of the PSSRs and procedures are available in the PSM Central Files. The supervisor of the area/ construction project leader is responsible for ensuring a PSSR is performed. Mechanical Integrity The Camas mill provides appropriate resources to ensure that the equipment used to process, store, or handle highly regulated substances is designed, constructed, installed, and maintained to minimize the risk of releases of the regulated substances into the workplace or community. To accomplish this goal, a Mechanical Integrity Program has been implemented to ensure the continued integrity of the processes. The Mechanical Integrity Program has been implemented for the systems which could potentially result in the release of a hazardous chemical. The program utilizes increased maintenance training, and preventive maintenance in conjunction with regular inspections and tests, to ensure equipment is in satisfactory condition. A s ummary of the Mechanical Integrity Program is found in the PSM Central Files with more details located in the maintenance shop. The ongoing recordkeeping requirements for the mechanical integrity testing program are: o Documentation showing each inspection and test that has been performed on process equipment. The documentation shall identify 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. Hot Work/ Safe Work The objective of the Hot Work Permit is to consistently control non-routine work conducted in the process areas. The Hot Work Permit System is specifically concerned with the permitting of hot work operations associated with welding and cutting on or near PSM/RMP regulated process areas. The permits document compliance with the fire prevention and protection requirements. Additional safe work practices such as lockout/tagout, confined space entry, and control over entrance have also been implemented to increase facility safety. The ongoing recordkeeping requirements for the hot work/safe work programs are: o Copies of the hot work permit showing: that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented prior to beginning the hot work operations; the date(s) authorized for hot work; and the object on which hot work is to be performed. The permit shall be kept on file until completion of the hot work operations. Management of Change All changes to processes regulated by PSM or RMP are monitored and managed to ensure the processes are operated and maintained as safely as possible. To assist in accomplishing this goal, a Management of Change Program has been implemented. Management of Change examines any type of change which is planned for the process, and the basis of th e change. The Management of Change Program is designed to evaluate, approve and administer changes to PSM/RMP regulated processes to assure any changes implemented enhance the operation and safety of the system. A description and procedures for the Management of Change Program can be found in the PSM Central Files. The PSM Coordinator is responsible for ensuring all MOC forms are complete. The ongoing recordkeeping requirements for management of change are: o Copy of the written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to stationary sources that affect a covered process. Incident Investigation Any incident which occurs in a process regulated by PSM or RMP, which could have or did result in a catastrophic release of a hazardous chemical in the workplace, is investigated. The Incident Investigation policy, procedures, and records of the Incident Investigations are available in the PS M Central Files. Compliance Audits Compliance audits are utilized to evaluate the effectiveness of the PSM/RMP programs which have been implemented. The compliance audit is intended to identify any deficiencies or weaknesses in mill policies, programs, or procedures, and take action to correct the deficiencies. A compliance audit is performed at least every three years to verify that the systems required by the PSM and RMP Regulations are in place and have been implemented. The regulations require that the previous two compliance audits be kept on file. This documentation and the Compliance Audit procedures are available in the PSM Central Files. The ongoing recordkeeping requirements for compliance audits are: o Proof of certification that compliance with the provisions of the prevention program have been evaluated at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed. ES.4 5-YEAR ACCIDENT HISTO RY AT THE CAMAS MILL The Camas mill has demonstrated a good record of accident prevention over the past five years. There has been a decreasing trend in the frequency of accidental releases. Mill policy is to investigate every incident to determine ways to prevent similar incidents from recurring. The checklists given in Section 3 of the main text of the Risk Management Plan contain all of the information required under the RMP rule for each identified release. ES.5 SUMMARY OF SAFETY FEATURES AT REGULATED PROCESSES Section 4 of the Risk Management Plan includes checklists that itemize the monitoring methods and mitigations at each RMP-regulated process. ES.6 MODELING OF OFF-SITE CONSEQUENCES OF ACCIDENTAL RELEASES This section describes the off-site consequence modeling to predict the downwind distance to the toxic endpoint concentrations as defined by the RMP regulations. ES6.1 Administrative Worst-Case Release for Toxic Compound (Chlorine) The administrative worst-cas e release (WCS) at the Camas mill is a hypothetical release of the entire contents of a rail car containing 90 tons of chlorine. In accordance with the RMP regulations, the entire 90 tons of chlorine was assumed to be released as a gas cloud in 10 minutes The RMP*Comp model was used to estimate the downwind concentrations under the EPA-mandated weather conditions of 1.5 meters per second wind speed and F stability. No passive mitigation measures were considered for this hypothetical release. The RMP*Comp model predicted a maximum distance of greater than 25 miles to the toxic endpoint of 3 ppmv. The event radius predicted by RMP*Comp assumes that the wind blows at the worst-case conditions of 1.5 meters per second and F stability. In reality, the average wind speed at Camas is about 3.0 meters per second. To estimate the off-site consequences under average conditions, the worst-case chlorine release was modeled at 3.0 meters per second wind speed and D stability. As expected, t he predicted distance to the chlorine toxic endpoint decreased significantly, down to a distance of 8.7 miles. Even if an entire chlorine railcar were somehow to be released during the worst-case atmospheric conditions, the steep terrain in the region would probably prevent the released gas from traveling anywhere other than along the river valley. Under F stability conditions, light winds would not be able to transport the dense chlorine cloud to a height of more than about 400 feet above the release. As a result, receptors situated at elevations greater than 400 feet above the Camas mill would probably not be impacted under EPA's stipulated worst case weather conditions. ES6.2 Alternate Release Scenario: Chlorine The alternate release scenario assumes that chlorine is accidentally released from a faulty bung at the bottom of the 450-gallon "level tank" at the bleach plant. The room in which the level tank is located is part of a larger, partially enclosed building. The floor area of the room is approximately 6,125 ft2. If a release were to occur, the emissions would exhibit properties somewhere between an "outdoor" release and an "indoor" release. The level tank holds 4,000 pounds of liquefied chlorine gas, stored at ambient temperature (60 degrees F) with a vapor pressure of 5.8 atmospheres. The hypothetical release scenario assumes that a corrosion hole develops in a 1.25-inch bung at the bottom of the tank, and in 10 minutes the entire contents of the tank are released. The average chlorine release rate of liquefied chlorine during the 10-minute duration was calculated to be 400 pounds per minute, using the TANKLEAK program that is part of the AIRTOX modeling package. All of the liquefied chlorine was conservatively assumed to immediately expand to a dense gas and disperse into the atmosphere without forming a residual pool of liquid near the leak (in reality, much of the discharged liquid would be expected to form a pool, and the vapors would b e released more slowly than estimated for the modeling used in this RMP). The SLAB computer dispersion model was used to model the distance to the downwind toxic endpoint. The SLAB spill source type of "evaporating pool" was selected, with a source area equal to the floor area. This modeling approach effectively disperses the release over the area of the room, rather than simulating a jet release directly from the level tank For this alternate release scenario, EPA's suggested atmospheric dispersion conditions of 3.0 meters per second and D stability were used for the modeling. A surface roughness of 0.5 meters was used, which is consistent with the mixed land use of the surrounding area (urban and rural). EPA guidance states that, for a gaseous indoor release, the release rate can be reduced by 55 percent to account for the mitigating effect of the building. Although the chlorine level tank is situated inside a partially-enclosed building, for this Risk Management Plan Fort Ja mes LLC elected not to reduce the release rate for modeling, for the reasons described below. EPA derived the 55 percent reduction factor by assuming that outside air displaces building (indoor) air at a rate of 0.5 air exchanges per hour. The air exchange rate in a building with some open areas would be higher than 0.5, a rate which is representative of well-sealed buildings. A release inside the building that houses the chlorine level tank would be mitigated by the building structure. However, information on the actual air exchange rate for this building was not available and, given that parts of the building are not enclosed, there is no reason to believe an air exchange rate as low as 0.5 is appropriate in this case. The SLAB model predicted a downwind distance of 2.4 miles to EPA's endpoint concentration of 3.0 ppmv for chlorine gas. The affected area extends into the commercial and residential neighborhoods in Camas and Washougal, and across the Columbia River to the outski rts of Troutdale, Oregon. In reality the emission rate from the spill would be reduced by the partially-enclosed nature of the process area. Using the rate at which chlorine releases from the tank as the actual release rate to the atmosphere is conservative (that is, using this higher release rate gives a greater downwind distance). To demonstrate how conservative it is to assume the full release rate, the downwind distance using a reduced rate (to simulate an indoor release) was also calculated. The input parameters from the alternative case presented here were used, but the release rate was reduced to 1.7 from 3.0 kilograms per second to account for a partial-indoor event, using the 55% reduction that is stipulated by the EPA Offsite Consequence Modeling Document. The SLAB model calculated that the toxic endpoint for this partial-indoor release would reach 1.7 miles, rather than 2.4 miles for the outdoor release. It is likely that the actual distance would be between 1.7 and 2. 4 miles. ES6.3 Alternate Release Scenario: Chlorine Dioxide The hypothetical alternate release scenario for chlorine dioxide assumes that an 8-inch pipe that connects two large chlorine dioxide storage tanks is accidentally broken, resulting in the release of a dilute aqueous solution of chlorine dioxide. Two chlorine dioxide storage tanks, each containing 80,700 gallons of nominal 1% aqueous chlorine dioxide solution, are located indoors at the Lurgi Building. These tanks receive chlorine dioxide from both chlorine dioxide generators, the Lurgi and R-8 systems. An 8-inch pipe interconnects the two tanks near the bottom of the tanks. The aqueous solution in the tanks is at ambient temperature (assumed to be 60 degrees F) and has a vapor pressure of 75 kPa. The hypothetical release scenario assumes that the 8-inch pipe is accidentally broken, resulting in the release of the solution onto the floor of the Lurgi Building. It is assumed that the leak continues for 30 minutes un til is detected and manually repaired by mill staff. Equations from Section D.7 of EPA's "RMP Offsite Consequence Modeling Guidance", May 24, 1996, were used to estimate the discharge of the liquid solution from the broken 8-inch pipe, and the POOL module of the AIRTOX modeling package was used to calculate the ClO2 evaporation rate from the liquid pool at the leak. In this case the ClO2 evaporation rate was greater than the average liquid release rate over the 30-minute duration, which indicates that the rate of ClO2 evaporation to the atmosphere is not affected by the depth of the liquid pool that might form in and around the Lurgi Building. Based on these calculations, the estimated average ClO2 evaporative release rate over the 30-minute leak duration is 281 pounds per minute. The RMP*Comp model was used to model the distance to the downwind toxic endpoint. The model predicted a downwind distance of 3.4 miles to EPA's endpoint concentration of 1.0 ppmv for chlorine dioxide. T he affected area extends into the commercial and residential neighborhoods in Camas and Washougal, and extends across the Columbia River and across Interstate-84 to Troutdale, Oregon. ES.7 EMERGENCY RESPONSE PROGRAM AT THE CAMAS MILL ES.7 Emergency Response Program at the Camas Mill. The Camas mill maintains a comprehensive written emergency response program, which is intended to protect worker and public safety and the environment. The program includes plans and procedures for responding to a wide range of events, caused either naturally or accidentally, that could result in a release of a regulated substance. The possibility of fire or explosion in the event that a flammable substance is released is also included in this full range program. The protocols and procedures address all aspects of emergency response: o Emergency notification protocol - Mill Emergency Response Team - Emergency Coordination Center - Public Safety Agencies - Public Regulatory Agencies o Cl assification of hazards o Responsibilities for management of response o Evacuation plans (routes and assembly areas) o Internal and external communication o First aid and prompt medical care procedures The emergency response plan also includes procedures for classifying both the nature of the emergency and the level of potential hazard so that responses will be appropriate and proportional the to the hazard level. The Camas mill employs the Incident Command System (ICS) which parallels the National Interagency ICS. This is an "all risk" system utilized for on-scene management of any emergency event. The ICS is functionally oriented around five major areas: (1) command, (2) operations, (3) planning, (4) logistics, and (5) finance (administration). In a major incident the response command could consist of a unified command grooup containing mill personnel and local, state, and federal agency representatives. The ICS includes eight crucial components: common terminology, modular o rganization, integrated communications unified command structure, consolidated action plans, manageable span of control (3-7 people), predesignated incident facilities, and comprehensive resource management. These components work together to provide the direction and control for effective response proportional to the severity of the incident. Measures for incident termination, post-incident cleanup and documentation requirements are also included. The Camas mill emergency preparedness program addresses maintenance, inspection and testing of response equipment, and training and instructions that address use of this equipment. The emergency response program is updated when necessary based on modifications made to the mill processes or facilities. The functional design of the ICS minimizes the impact upon the emergency plan of changes in personnel assignments. All changes in the emergency response program are administered through the management of change (MOC) process that is also u tilized in the accident prevention program. This process addresses informing and/or training affected personnel whenever changes with potential safety implications occur. The most recent training of the Mill Emergency Response Team, included rescue training, ICS training, and a combination of HAZWOPER, Oil Spill, and Gas Pipeline annual training. The overall emergency response program for the mill is coordinated with the City of Camas Fire Department. This coordination includes periodic meetings with local emergency response officials, local government officials, independent response contractors and industry representatives. Fort James LLC has around-the-clock communications capabilities with appropriate local officials emergency response organizations (e.g., Camas Fire Department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response. The mill conducts periodic emergency drills that involve the LEPC and emergency re sponse organizations, and provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the mill. The most recent cross training/practice drill coordinated with local emergency responders was in November of 1998. |