Willamette Industries - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Willamette Industries-Kingpsort Mill, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: * A description of our facility and use of substances regulated by EPA's RMP regulation * A summary of results from our assessment of the potential offsite consequences from accidental chemical releases * An overview of our accidental release prevention programs * A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule * An overview of our emergency re sponse program * An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment * The certifications that EPA's RMP rule requires us to provide * The detailed information (called data elements) about our risk management program STATIONARY SOURCE AND REGULATED SUBSTANCES Our facility produces bleached soda pulp and fine paper using a variety of chemicals and processing operations. We manufacture and use chlorine dioxide for bleaching operation. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Toxics Chlorine Dioxide, 10.5 tons/day, bleaching of soda pulp Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, an d the environment by our use of these chemicals. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenario and alternative release scenario for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario - Regulated Toxic Chemicals The worst case scenario is a liquid spill and vaporization caused by a loss of the contents of two connected 29,800 gallon tanks containing 1% ClO2 solution. This is a gas release of chlorine dioxide for 10 minutes. The assumed weather conditions include a conservative temperature and relative humidity. The estimated exposure distance is 4.19 miles. Areas which could be affected by the release include Holston Valley and Indian Path Hospitals, the Kingsport Health Clinic, Andrew Jackson, George Washington, Gr avely, Andrew Johnson, Jefferson, Cedar Grove, Brookside, Roosevelt, Carters Valley, John F. Kennedy, and Abraham Lincoln Elementary Schools, Lynn View, John Sevier, and Robinson Middle Schools, Dobyns Bennett and North High Schools, Gravely Apolistic Christian, St. Dominic's, and Cedar View Christian Schools, Christian Life Academy, and the Kingsport University Center. Controls are in place to limit the offsite consequences of any release through pre-startup review, training, and onsite response personnel. Alternative Release Scenario - Regulated Toxic Chemicals The alternative release of chlorine dioxide includes liquid spill of chlorine dioxide solution from a pipe leak and vaporization. The pipe is 700 feet of 4" pipe filled with 1% chlorine dioxide solution. An estimated 38 pounds of ClO2 would be released under this scenerio. The release could impact an area 1.21 miles from the event. Areas which could be affected by this scenerio include Holston Valley Hospital, Andrew Jackson Elementary Schools, and businesses and homes located in the downtown area. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: * Process safety information * Process hazard analysis * Operating procedures * Training * Mechanical integrity * Management of change * Pre-startup review * Compliance audits * Incident investigation * Employee participation * Hot work permit * Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: EMPLOYEE PARTICIPATION Active employee participation and involvement a re essential to the success of the RMP program. The participation minimizes the consequences of releases of toxic, reactive, flammable, or explosive chemicals. Communication is encouraged between supervision and employees. To promote safety, at a minimum, monthly departmental safety meetings are held. In addition, to the meetings, a central safety committee with employee representation from all areas is held. Five minute huddles are also used to communicate additional safety concerns. Other forms of safety communication include near miss reporting, abnormal incident reports (AIR), and special training (emergency response, first aid, CPR, etc.) Employees are always encouraged to speak to supervision about questions, suggestions, or comments concerning safety. PROCESS SAFETY INFORMATION A variety of process safety information is available concerning process chemicals and their uses. MSDSs are available through most networked computers and the main guard house computer. A hard c opy is also available in the medical office. The MSDSs are updated and any new chemical received into the mill must first undergo a new material check approval signed by the environmental, safety, process, and purchasing departments. PSI notebooks containing pertainant operations, safety, and maintenance information is kept in various places throughout the mill. SOPs supply additional information on safety when performing a task. PROCESS HAZARD ANALYSIS (PHA) Process hazard analysis (PHA) are performed on the PSM/RMP chemicals used in the mill. Chlorine dioxide is the only on-site chemical that the PHA is performed on. The PHA is performed for the chlorine dioxide system and is instrumental in determining potential safety items which can be corrected and known. A what if and fault tree analysis is performed to identify failure modes. Once a failure condition is known, the consequences of the failure is identified. The PHAs are conducted by a team consisting of engineering, saf ety, environmental, maintenance, operations, and supervision. The team identifies failures and their consequences. The results are reviewed for the seriousness of the hazards and the most severe are performed first. The reviews are updated at a minimum of every 5 years. The updates are documented and reviewed for the recommendations and appropriate measures are taken. OPERATING PROCEDURES The Kingsport Mill has standard operating procedures (SOPs) which address the general purpose, operating equipment, objectives, safety considerations, normal operating parameters, troubleshooting and reference drawings for the process. The purpose of the SOPs are to understand the correct procedures for a job or task. SOPs are reviewed by operations and supervision for accuracy and understanding. Special safety considerations are also presented in the SOPs. TRAINING All new employees are required to have a general mill safety training before their specific area safety training. All safe ty training is documented and audited for completeness. Procedural training, on-the-job training, and testing on safety and process ability is also a mandatory part of the training program. Employees are also encouraged to participate in computerized training programs available at the mill. PRE-STARTUP SAFETY REVIEW Whenever process safety information is modified or added, a pre-startup safety review is conducted to ensure the safety of the modification or addition. The PSSR involves field verification of amended area and verification of the accident prevention program. MECHANICAL INTEGRITY The maintenance department has well established procedures for maintaining process equipment. Training, inspections and a tracking system to detect deficiencies is in place. Whenever maintenance personnel are required to work on PSM equipment, an overview of the process and the safety and health hazards are discussed with the personnel along with applicable safe work practices. Another par t of the integrity program is the quality assurance of the material used in the repairs. Unique PSM equipment is set up in a separate area of the storeroom and is used exclusively for the chlorine dioxide system. SAFE WORK PRACTICES Safe work practices are encouraged and required at the Kingsport Mill. Several safe work practice plans are enforced including lockout/tagout, control of entry and exit, hot work permits, fall protection, and confined space programs. These procedures and training programs help ensure good safe work practices. MANAGEMENT OF CHANGE The Kingsport Mill has a comprehensive system to manage changes to all PSM/RMP processes. The management of change requires that changes to items such process equipment, procedures and other changes be reviewed and documented (by participants signature) before initiation of the change. The modifications are reviewed and documented to verify the new changes do not present a new hazard and that the controls not updated are stil l safe. Also, any additional training needed for operations or maintenance is given and documented. INCIDENT INVESTIGATION The Kingsport Mill investigates any incident or near miss incident that could have resulted in a fire or explosion, toxic release, property damage, environmental damage, or personal injury. The intent of the investigations are to correct the situation or install additional safety factors so that the incident will not reoccur. The outcome of the investigations are forwarded to specific individuals or departments for corrective actions to begin as soon as possible. COMPLIANCE AUDITS Compliance audits are performed at least every 3 years. The findings are documented and resolutions for the findings are done. The findings are tracked for completeness until each items has been addressed. An additional internal chlorine dioxide plant audit is performed by mill personnel from the Kingsport mill and other Willamette mills. This additional audit was performed in 19 98 in addition to the 1996 PSM audit. Bi-annual safety audits are done by safety professionals from other Willamette facilities. These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. FIVE-YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occur at our facility. The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule during the past five years: The Kingsport mill has had only one accident in the last 5 years. The accident was the result of lost water flow to the scrubber condensor, which caused increased emissions of chlorine dioxide. The release did not go off site; however, one person was treated for chlorine dioxide exposure and released. We have conducted a formal incident investigation to identify and correct the root causes of the events. EMERGENCY RESPONSE PROGRAM We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. The overall emergency porcedure program is coordingated with the Local Emergency Planning Committee (LEPC). This program includes periodic meetings with local emergency personnel, government officials, and industry representatives. Emergency personnel (fire department, etc.) are available on a continuous basis, either by phone or radio. The ability to notify off site responders may therefore by performed very quickly. In addition, the Kingsport mill is located very close to the downtown fire hall. In addition to committe meetings, off site personnel participate in emergency drills at the mill. Local personnel are also involved in periodic refresher training (i.e., hazmat training, confined space rescue training. etc.) performed at the mill. The Kingsport mill has several accident prevention programs in place to help reduce the threat of a release. Safety features are designed to contain or control a release, detect a release quickly, and reduce the impacts of a release. Examples of the features in place include: chlorine dioxide detectors with alarms, isolation valves, interlocks to shut down the process, redundant equipment and instrumentation, emergency procedure training (HAZWOPER, Confined space rescue), and personal protective equipment (SCBA, protective clothing). PLANNED CHANGES TO IMPROVE SAFETY Our facility is committed to preventing releases from the chlorine dioxide system. The facility is considering the installation of more chlorine dioxide monitors in the building to indicate accidental releases. Also, we are improving housekeeping and building upkeep. |