Mead Paper - Executive Summary |
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Mead Paper Division - Escanaba Mill 1. EXECUTIVE SUMMARY The Mead Paper Division-Escanaba Mill (Mead-Escanaba) is committed to operating in a manner that is safe for employees, the public, and the environment. As part of this commitment, Mead-Escanaba has established a system to help ensure safe operation of the processes at this facility. Two components of this system are a Process Safety Management (PSM) program that helps manage the risk and that complies with the requirements of the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals; and a risk management program (RMP) that complies with the requirements of the Environmental Protection Agency (EPA) 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 (RMPlan) describing the risk management program at Mead-Esc anaba. This document is intended to satisfy the RMP requirements of the rule and to provide the public with a description of our risk management program. The process safety and risk management program at Mead-Escanaba consists of three elements: A hazard assessment to help understand (a) the potential off-site 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) - see topics 1.3 and 1.5 A prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered processes) - see topic 1.4 An emergency response program to help respond to accidental releases of regulated substances from covered processes - see topic 1.6 Information further describing these elements is provided in this RMPlan. Although the risk management program at Mead-Escanaba helps provide assu rance that the facility is maintained and operated in a safe manner, it is only one component of the safety program at Mead-Escanaba. In fact, Mead-Escanaba has a comprehensive safety program in place establishing many levels of safeguard against release of a hazardous substance and resultant injuries or damage from such a release. Mead-Escanaba limits the use of hazardous substances. Prior to using a hazardous substance, less hazardous alternatives are considered. When a hazardous substance is used at Mead-Escanaba, consideration is given to the potential for this substance to adversely affect employees, the public, as well as the environment and steps are taken to prevent any such effects. Mead-Escanaba prevents releases of the hazardous substances used at the facility. When a hazardous substance is used at Mead-Escanaba, the equipment is carefully designed, built, and operated to reduce the likelihood of an accidental release. Industry and government standards are closely adh ered to in the design, construction, and operation of the equipment. Mead-Escanaba limits damage from a release, if such a release occurs. Mead-Escanaba trains employees to respond to an accidental release, reducing the consequences of a release should one occur. In addition, Mead-Escanaba works with the local emergency planning committee (LEPC) to help ensure that injuries and/or environmental damage will be minimized if a release does occur. The safety program at Mead-Escanaba consists of a number of elements, only, some of which are required by the RMP rule. This RMPlan is primarily intended to describe those parts of the safety program at Mead-Escanaba that are required by the RMP rule. 1.1 Accidental Release Prevention and Emergency Response Policies Mead-Escanaba is committed to the safety and health o f our employees, contractors, the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. Mead-Escanaba 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 Mead-Escanaba; and programs to evaluate the hazards at Mead-Escanaba. In the event of an accidental release, Mead-Escanaba will make every effort to control and contain the release in a manner that will be safe for employees and will prevent injury to the public or the environment. Mead-Escanaba provides response training to Mead-Escanaba personnel, designates an emergency response coordinator to oversee response activities, and coordinates response efforts with the local public safety department. Response activities have also been discussed with the LEPC. 1.2 The Mead Corporation - FACILITY and Regulated Substances Mead-Escanaba is an integrated pulp and paper mill involved in the manufacture of bleached pulp and related finished paper products. As a part of this manufacturing process, Mead-Escanaba handles several regulated substances in sufficient quantities to be covered by the RMP rule, as shown in the following list of RMP-covered processes at Mead-Escanaba. Process Program Level Regulated Substance Process Quantity (lb) Water Treatment 3 Chlorine 2,000 Chlorine Dioxide Generation & Storage 3 Chlorine Dioxide 19,935 Waste Water Treatment 3 Anhydrous Ammonia 54,591 Bleach Plant 3 Chlorine 180,000 1.3 Off-site Consequence Analysis Mead-Escanaba performed off-site consequence analyses to estimate the potential for an accidental release of a regulated substance that might affect the public or the environment. The off-site consequence analysis consists of evaluating both worst-case release scenarios and alternative release scenarios. Mead-Escanaba does not expect a worst case release scenario to ever occur. The alternative release scenarios were selected to help the local emergency planning committee improve the community emergency response plan. An alternative release scenario represents a release that (1) although unlikely, is more probable than a worst-case release scenario and (2) could result in a potential off-site consequence. The main objective of performing the off-site consequence analysis is to determine the distance at which certain effects might occur to the public because of an accidental release (called the endpoint di stance). 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 likely. Some people who are particularly susceptible to the substance released could be incapacitated. The RMP rule requires specific requirements for the worst case and alternative release scenarios that must be reported by Mead-Escanaba. These requirements are: One worst case scenario for the class of toxic substances in Program 2 or Prog ram 3 processes (i.e., one scenario representing both chlorine and chlorine dioxide) One alternative release scenario for each of the toxic substance in a Program 2 or Program 3 process (i.e., chlorine, chlorine dioxide and ammonia) The following information summarizes the off-site consequence analyses performed by Mead-Escanaba. 1.3.1 Program 3 Processes - Toxic Substances The worst case release scenario for toxic substances is rupture of the 90-ton chlorine railcar. The maximum distance to the toxic endpoint concentration is greater than 25 miles. Approximately 20,396 people live within this distance from the storage area; several public receptors are also located within this distance (e.g., residential areas, schools, hospital, recreation areas, industrial and commercial areas). Some environmental rece ptors are located within this distance (e.g., national forest and state park). The alternative release scenario for chlorine (1-ton cylinder) is a failure of a <" tube on a vacuum regulator valve. This scenario assumes that workers require 30 minutes to detect and plug the leak. The maximum distance to the toxic endpoint is .38 miles. Approximately 400 people live within this distance from the chlorine cylinder location; several public receptors are also located within this distance (e.g., residential and industrial area). No environmental receptors are within this distance. The alternative release scenario for chlorine dioxide is rupture of a 4-inch chlorine dioxide solution (1.2 wt%) line from the storage tank to a mixer. This scenario assumes that the solution is released through the hole for 30 minutes before the workers detect the release and isolate the line. The released chlorine dioxide solution forms a pool and the chlorine dioxide evaporates from the pool, forming a vapor cloud. The maximum distance to the toxic endpoint is 1.1 miles. Approximately 1500 people live within this distance from the chlorine dioxide storage tank location; several public receptors are also located within this distance (e.g., residential, school, recreation and industrial area). No environmental receptors are within this distance. The alternative release scenario for anhydrous ammonia is a vessel leak from a =" opening. This scenario assumes that employees require 30 minutes to detect and plug the leak. The maximum distance to the toxic endpoint is .16 miles. Approximately 150 people live within this distance from the storage tank. A small residential area is located within this distance. No environmental receptors are located within this distance. The alternative release scenario for chlorine (90-ton railcar) is a failure on a 1" flex-hose on the 90-ton railcar. This scenario assumes that workers require 30 minutes to detect the release and isolate the line . The maximum distance to the toxic endpoint is .76 miles. Approximately 500 people live within this distance from the railcar location. Several public receptors are also located within this distance (e.g., residences, schools, and industrial areas). No environmental receptors are located within this distance. 1.4 Accidental Release Prevention Program and Chemical-specific Prevention Steps Mead-Escanaba maintains a prevention program to help prevent accidental releases of hazardous substances and ensure safe operation. Mead-Escanaba follows the EPA RMP rule of the Program three level of prevention program requirements: Program 3 - Program level 3 requirements are essentially the same as OSHA PSM, except that the program also focuses on protecting the public as well as the environment. The following sections briefly describe the elements of Mead-Escanaba's prevention program that address the EPA RMP rule prevention program requirements. 1.4.1 Program 3 Prevention Program The Mead-Escanaba Program 3 prevention program, which applies to the Chlorine, Chlorine Dioxide Generation and Storage, and Anhydrous Ammonia processes, consists of the following 13 elements: 1. Employee Participation. A written employee participation program has been developed for covered processes to help ensure that the safety concerns of employees are addressed. Active participation of personnel is encouraged in the prevention program activities of all processes at the facility. Employees are consulted on and informed about all aspect of the PSM and RMP prevention programs, including PHAs and operating procedures. Mead-Escanaba employees have access to information developed under the Process Safety Management Standard. The documentation is located in the Process Safety Engineer's office and will st ate where relevant information or records are stored. 2. Process Safety Information. Mead-Escanaba maintains a variety of technical documents that are used to help ensure safe operations our processes. These documents address (1) chemical hazard information, (2) process technology information, and (3) equipment information. Mead-Escanaba ensures that the process safety information is available to all affected employees. Material safety data sheets (MSDSs) document the physical properties of hazardous substances handled at Mead-Escanaba, including regulated substances in covered processes. The information includes: * toxicity information * permissible exposure limits * physical data * reactivity data * corrosivity data * thermal and chemical stability data * hazards of mixing substances in the process MSDS s for hazardous substances handled in each process are available in the process control room so that the operators have ready reference to this information. In addition, MSDSs are provided to the Escanaba Public Safety Department for use in helping formulate emergency response plans. Information pertaining to the technology of the process such as block flow diagram, process chemistry, maximum intended inventory, safe upper and lower limits, and an evaluation of the consequences of deviation can be found in the operating manuals located in the control room. Information pertaining to the equipment of the process such as piping and instrument diagrams (P&ID's), design basis for relief and ventilation systems, electrical classification, applicable design codes and standards can be found in the Safety Department. The remaining equipment information can be found in the operating manuals located in the control room. 3. Process Hazard Analysis. Mead-Escanaba performs and periodically up dates (at least every five years) process hazard analyses (PHAs) 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 personnel with engineering, maintenance, and operating experience and a leader with process hazard analyses experience is assembled to analyze the hazards of the process. Mead-Escanaba primarily uses the hazard and operability (HAZOP) technique, supplemented with what-if/ checklists, to perform these analyses. The PHA team leader prepares a written report describing the results of the analyses, including a list of recommendations. Responsibility to resolve the recommendations is assigned to unit personnel and, when appropriate, changes to enhance the safety of the process are implemented. 4. Operating Procedures. Mead-Escanaba process engineers, operators, and supervisors work together to develop and maintain operating procedures to define how tasks related to process operations should be safely performed. 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: steps for safely conducting activities applicable process safety information, such as safe operating limits and consequences of process deviations safety and health considerations, such as chemical hazards, personal protective equipment requirements, and actions to take if exposure to a hazardous substance occurs Mead-Escanaba personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operations, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations. The operating procedures are used both to help in operating the Mead-Escanaba processes and as a training guide. 5. Training. Mead-Escanaba trains employee s to perform their assigned tasks in a safe and effective manner. The Mead-Escanaba 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. Oral reviews and written tests are used to verify that an employee understands the training material. The operators are consulted after training sessions to evaluate the effectiveness and frequency of the training. Recommendations from the operators are reviewed, and changes to the program are implemented as appropriate. 6. Mechanical Integrity. Mead-Escanaba maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger employees, contractors, the public, or the environment. Mead-Escanaba's mechanical integrity program includes (1) an inspection and testing program to help identify equip ment deterioration and damage prior to equipment failure and (2) a quality assurance program to help ensure that new and replacement equipment meet the design standards required for service in Mead-Escanaba processes. The Mead-Escanaba mechanical integrity program also includes: * specifications for inspection and testing of process equipment * specifications for replacement parts and equipment * procedures for inspecting, testing, and maintaining process equipment * procedures for safe work practices such as lockout, hot work, confined space entry, and line breaking * training of maintenance personnel * documentation of maintenance activities 7. Management of Change. The Mead-Escanaba management of change program evaluates and approves all proposed changes to chemicals, equipment, and procedures for covered processes 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 valv e with an identical valve) are allowed without completing a full management of change. All other changes must be confirmed through the full management of change process 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. The management of change completed forms are maintained in the Safety Department. 8. Pre-Startup Review. Mead-Escanaba 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: construction and equipment are in accordance with design specifications adequate safety, operating, maintenance, and emergency procedures are in place employee training has been completed management of change requirements have been completed if an existing covered proce ss has been modified management of change requirements and Process Hazard Analyses has been performed for a new process A pre-startup review checklist is completed to document the review and to ensure that appropriate issues have been addressed. A pre-startup review checklist is included with the management of change form. 9. Compliance Audit. Mead-Escanaba audits covered processes to be certain that the Process Safety Management program is effectively addressing the safety issues of our operations. Mead assembles an audit team that includes personnel knowledgeable in the Process Safety Management regulations as well as the process. This team evaluates whether the Process Safety Management program satisfies the requirements of 29 CFR 1910.119 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 process enhancements are implemented. The same audi t procedures will be used to audit the Risk Management Program. 10. Incident investigations. Mead-Escanaba will investigate all incidents that could have reasonably resulted in a serious injury to personnel, the public, or the environment so that similar accidents can be prevented. Employees are trained to identify and report any incident requiring investigation. An investigation team will be 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 or equipment enhancements are implemented. Incident reports remain on file in the Safety Department. 11. Hot Work Permits. Mead-Escanaba established a hot work permit program to control spark or flame producing activities that could result in fires or explosions. Mead-Escanaba reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a) and created a Hot Work Permit form and policy to com ply with these requirements. Personnel 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. The Hot Work Permits are assigned a number by the Loss Prevention Officer and are monitored until the job is complete. The Loss Prevention Department retains copies of the completed permits. Training in the use of the Hot Work Permit is included in the Mead-Escanaba safe work practices training programs that are conducted on a regular basis. 12. Contractors. Mead-Escanaba established a program to help ensure that contractor activities at our facility are performed in a safe manner. The program reviews the safety record of all contractors to help ensure that Mead only hires contractors who can safely perform the desired job tasks. Mead-Escanaba explains to the contract supervisors the hazards of the process on which they and their employees will work, Mead-Escanaba safe work practices, and e mergency response procedures. Mead requires that the contractor supervisors train each of their employees who will work at Mead before that worker begins work at the Mead site. Mead-Escanaba periodically reviews contractor-training documents, and work performance to help ensure that safe practices are followed. 13. Trade Secrets. Mead-Escanaba will provide all information necessary to comply with 29 CFR 1910.119 without regard to possible trade secret status of such information. Mead-Escanaba reserves the right to require confidentiality agreements. 1.4.3 Chemical-specific Prevention Steps In addition to the required prevention program elements, Mead-Escanaba has implemented safety features specific to the hazardous substances used at Mead-Escanaba. The following paragraphs describe some of these safety f eatures. Anhydrous Ammonia. Industry standards are followed at Mead-Escanaba to help ensure safe handling of anhydrous ammonia. The ammonia vendor supplies ammonia via Department of Transportation (DOT)-approved tank truck and follows DOT standards when loading the anhydrous ammonia storage tank. The storage tank design and construction are consistent with American National Standards Institute (ANSI) standards for the storage and handling of anhydrous ammonia. Employees who perform operations involving ammonia receive training emphasizing safe handling procedures for ammonia developed by Mead-Escanaba. Chlorine. Chlorine is supplied in DOT-approved 1-ton cylinders. Chlorine is fed through a short length of 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. If release occurs downstream of the regulator at the cylinder, the regulat or will close and only the quantity in the piping will be released. Chlorine detectors and alarms are provided in most areas containing chlorine. Chlorine is also supplied by DOT approved 90-ton railcars. A remote camera monitors the chlorine railcars twenty-four hours a day. A blue flag and derailer protection program is utilized as well. Employees who perform operations involving chlorine receive training emphasizing safe handling procedures for chlorine developed by Mead-Escanaba. Chlorine Dioxide. Chlorine dioxide is produced at the Mead-Escanaba facility and stored as a dilute aqueous solution to avoid the necessity of transporting large quantities of the solution. Chlorine dioxide is produced in the chlorine dioxide generator and piped to an absorber column, where a chlorine dioxide solution (1.2 wt%) is generated. Storing this substance as a solution helps to reduce the consequences of a release. A diked area around the storage tank further reduces the consequen ces of a release. 1.5 Five-Year Accident History There has only been one accidental release of a regulated chemical during the last five years. On May 9-10, 1995, 19 pounds of chlorine dioxide was accidentally released from a bleach plant scrubber system. This was due to a non-routine startup of the equipment after shutdown. There were neither off-site nor on-site impacts to personnel, property or the environment. 1.6 Emergency Response Program Mead-Escanaba has established a written emergency response program to help safely respond to accidental releases of hazardous substances. The emergency response plan includes procedures for: informing the local public safety department and the public about accidental releases that could reasonably result in off-site consequences providing proper first aid and emer gency medical treatment to treat accidental human exposure to hazardous substances at Mead-Escanaba controlling and containing accidental releases of hazardous substances, including the use of emergency response equipment inspecting and maintaining emergency response equipment reviewing and updating the emergency response plan Mead-Escanaba maintains an emergency response team trained in these emergency response procedures. All Mead-Escanaba personnel are trained in evacuation procedures. Mead-Escanaba periodically conducts emergency response drills, including annual drills coordinated with the local emergency planning coordinator. 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 been communicated to local emergency response officials through the LEPC. Mead-Escanaba maintains a regular dialogue with the local emergency planning coordinator and Mead-Escanaba provides appropriate information to the LEPC. 1.7 Planned Changes to Improve Safety Mead-Escanaba constantly strives to improve the safety of the processes at Mead-Escanaba through both the incident investigation program and a program soliciting safety suggestions from employees. The following changes to improve process safety are planned. Currently changes are being made to the bleaching process at our facility. Chlorine is being phased out of our bleaching operations and by April 15, 2001 our facility will be elemental chlorine free (ECF). CERTIFICATION STATEMENT FOR PROGRAM LEVEL 2 & 3 PROCESSES To the best of undersigned's knowledge, information, and belief formed after reasonable inquiry, the information submitted in this RMPlan is true, accurate, and complete. _________________________________ ___________________________________ Signature Print Name _________________________________ ____________ Title Date |