Georgia-Pacific Corporation, Palatka Operations - Executive Summary |
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Georgia-Pacific Palatka Operations Risk Management Plan 1. Executive Summary Georgia-Pacific Palatka Operations (GP/Palatka) is committed to operating in a manner that is safe for GP/Palatka workers, the public, and the environment. As part of this commitment, the company has established a system to help ensure safe operation of the hazardous chemical processes at this facility. One component of this system is a Risk Management Program (RMP) that helps manage the risks at the facility and addresses compliance with the requirements of the Environmental Protection Agency's (EPA's) 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 Georgia-Pacific in Palatka. This document is intended to satisfy the RMPlan requirements of the RMP Rule and to provide the public with a description of the Risk Management Program at the facility. The Risk Management Program at the facility consist of three elements: 1. a hazard assessment to help understand (a) the potential off-site consequences of hypothetical accidental releases and (b) accidents that may have occurred during the last five years associated with the use of the substances regulated by the RMP Rule (chlorine dioxide and chlorine) - see topic 1.2 2. a prevention program to help maintain and safely operate the processes containing more than the threshold quantity of the regulated substances (covered processes) - see topic 1.4 3. an emergency response program to help respond to accidental releases of the regulated substances from the covered processes - see topic 1.6 Information further describing these elements is provided in this RMPlan. Although the Risk Management Program at the facility helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety program at GP/Pal atka. In fact, the facility has a comprehensive safety program in place establishing many levels of safeguards that are designed to minimize the potential for the release of any hazardous substances and injuries and damage resulting from the release of hazardous substances. GP/Palatka minimizes the potential releases of the hazardous substances used at the facility. When the hazardous substances are used at the facility, the equipment is carefully designed, built, and operated to reduce the likelihood of an accidental release. Industry and government standards are closely adhered to in design, construction, and operation of the equipment. GP/Palatka limits damage from a release, if such a release occurs. The facility trains workers to respond to upset conditions, reducing the consequences of a release if it occurs. In addition, the facility will be working with the Local Emergency Planning Commission (LEPC) to help ensure that injuries and/or environmental damage will not occur in th e event a release does occur. The safety program at GP/Palatka 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 the facility that are required by the RMP Rule. 1.1 Accidental Release Prevention and Emergency Response Policies GP/Palatka is committed to the safety of workers and the public, as well as the preservation of the environment through the prevention of accidental releases of the hazardous substances. The facility implements reasonable controls to prevent foreseeable releases of the hazardous substances. These controls include training programs for personnel; programs to help ensure safety in the design, installation, operation, and maintenance of the processes; and programs to evaluate the hazards at the facility. In the event of an accidental release, the facility will control and contain the release in a manner that will be safe for workers and will help prevent injury to the public and/or the environment. GP/Palatka provides response training for upset conditions to facility personnel, designates an emergency response coordinator to oversee response activities, and coordinates response efforts with the local emergency response organizations. In order to effectively implement these policies, the facility has established a management system directed by the Vice President Pulp and Paper /Palatka Operations. 1.2 Georgia-Pacific Palatka Operations and Regulated Substances Georgia-Pacific Palatka Operations is a pulp and paper mill primarily involved in the manufacture of brown/bleached pulp and paper products. As part of this manufacturing process, the facility produces and stores Chlorine Dioxide (C102) for the use of bleaching pulp. The facility stores and transfers chlorine for use in bleaching pulp, as well as water treatment, in sufficient quantities to be covered by the RMP Rule. The Chlorine Dioxide Solution System, which includ es the generation, storage and distribution of the chlorine dioxide, is considered an RMP-covered processes in Program Level 3. The Chlorine Systems, which include the 90-ton railcar and distribution system for the Bleach Plant and the 90-ton railcar and distribution system for the Water Treatment Plant, are considered RMP-covered processes in Program Level 3. The threshold quantity for Chlorine is approximately 90 tons during peak operations in each system. The threshold quantity for Chlorine Dioxide is approximately 5,694 pounds (67,619 gallons at a 10 gram per liter (1% in solution) strength) during peak operations. 1.3 Off-Site Consequence Analysis GP/Palatka performed an off-site consequence analysis to estimate the potential for an accidental release of the regulated substances to affect the public or the environment. The off-site consequence analysis consists of evaluating both the worst-case release scenarios and alternative release case scenarios. The facility does not ex pect a worst-case release scenario to ever occur. An alternative release scenario represents a release that (1) might occur at a facility like GP/Palatka and (2) would result in an off-site consequence if the release occurred. The alternative release scenarios will help the Local Emergency Planning Committee improve the community emergency response plan. 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 distance). The following effects could occur at the endpoint distances. 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 dioxide or chlorine, most people at the endpoint distance would be able to walk away from the exposure without any long-term health consequences, a lthough some short-term consequences (e.g., strong eye or throat irritation) are likely. The RMP Rule includes specific requirements for the worst-case and alternative release scenarios that must be reported by Georgia-Pacific Palatka Operations. These requirements include: * one worst-case release scenario for a toxic substance in Program Level 3 (one scenario representing chlorine) * one alternative release scenario for each toxic substance in Program Level 3 processes (one scenario representing chlorine and one scenario representing chlorine dioxide) The following information summarizes the off-site consequence analysis performed by Georgia-Pacific Palatka Operations. 1.3.1 Program Level 3 Process - Chlorine (C12) Systems and the Chlorine Dioxide (C102) Solution System The worst-case release scenario for the chlorine system is the rupture of the 90-ton railcar. The railcar is connected to the chlorine feed system. The RMP Rule mandates that, for the worst-case scenario, the analysis assume loss of the largest storage vessel in ten minutes. The released chlorine would evaporate to form a vapor cloud. The maximum distance to the toxic endpoint concentration, based on the EPA Lookup Table approach, is greater than 25 miles. The United States Census indicates that approximately 127,596 people live within this distance from the vessel; several public receptors are also located within this distance (e.g., Putnam Community Hospital, St. Johns River Junior College, Putnam County Jail, Kay Larkin Airport, several industrial facilities, several public and private elementary schools and high schools, several nursing homes, several churches, several recreation parks, Palatka Shopping Mall, St. Johns River Water Management District, and numerous subdivisions). There are also several environmental receptors. The alternative release scenario for chlorine is the rupture of the chlorine unloading hose, releasing 208 pounds per minute for 10 minutes before it could be isolated. The released chlorine will evaporate to form a vapor cloud. The maximum distance to the toxic endpoint concentration, based on the EPA Lookup Table approach, is 2.0 miles. The United States Census indicates that approximately 3,725 people live within this distance from the ruptured line.. Several public receptors are also located within this distance (e.g., Putnam County Jail, St. Johns River Water Management District, Palatka Shopping Mall, Kay Larkin Airport, one public elementary school, several industrial facilities, several recreation parks, and several subdivisions). There are also several environmental receptors. The alternative release scenario for chlorine dioxide is the rupture of a chlorine dioxide solution line located at the discharge side of the C102 transfer pumps' header. During normal operations, the pump could pump approximately 675 gallons per minute for fifteen minutes before the release might be recognized and isolated. The released chlorine dioxide so lution will form a pool of minimum depth (1 (cm)) and evaporate to form a vapor cloud. The maximum distance to the toxic endpoint concentration, based on the EPA Lookup Table approach, is 1.9 miles. The United States Census indicates that approximately 3,725 people live within this distance from the discharge line at the chlorine dioxide solution transfer pumps. Several public receptors are also located within this distance (e.g., Putnam County Jail, St. Johns River Water Management District, Palatka Shopping Mall, Kay Larkin Airport, several industrial facilities, several recreation parks, and several subdivisions). There are also several environmental receptors. . 1.4 Accidental Release Prevention Program Georgia-Pacific Palatka Operations has always used a prevention program to help prevent accidental releases of hazardous substances. Beginning in 1992, the facility formalized this prevention program for the Chlorine Dioxide Solution System and the Chlorine System to comply wit h the 14 elements of the Occupational Safety and Health Administration's Process Safety Management (PSM) prevention program. In 1996, the EPA RMP Rule established that a Program Level 3 prevention program would become a requirement for these processes as well. The facility's Program Level 3 Prevention Program under the RMP Rule is essentially the same as the OSHA PSM Program, except that the RMP also focuses on protecting the public and the environment. 1.4.1 The following sections briefly describe the twelve elements of the Georgia-Pacific Palatka Operations Program Level 3 prevention program that addresses the EPA RMP rule prevention program requirements for the Chlorine Systems and Chlorine Dioxide Solution Systems. 1. Employee Participation The facility has developed a written employee participation program for the covered processes to help ensure that the safety concerns of GP/Palatka employees are addressed. The facility encourages active participation from personnel in the de velopment and maintenance of the prevention program activities of all processes at the facility. Employees are consulted on, and informed about, all aspects of the RMP Rule prevention program, including the development of Process Hazard Analysis and Operating Procedures. 2. Process Safety Information The facility maintains a variety of technical documents that are used to help ensure the safe operation of the processes. The documents address (1) the hazards of the chemicals used in the process, (2) the technology data of the process, and (3) the design basis and configurations of the equipment used in the processes. The facility ensures that this process safety information is maintained, accurate, and available to all GP/Palatka employees, and the Local Emergency Planning Committee (LEPC). All of the information and documentation for the RMP Prevention Program is maintained in the PSM/RMP Center at the facility. Material safety data sheets (MSDS) document the physical and chemical pr operties of the hazardous substances handled at the facility, including non-regulated substances in the covered process. MSDS's for hazardous substances handled in each process are available in the control rooms so the operators have ready reference to this information. In addition, MSDS's are provided to the LEPC and/or Plant Emergency Response teams for use in helping formulate emergency response plans Many of the operating parameters are included in the technology information ????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????rate recommendations that might improve the safe operation of the process. A team composed of personnel with engineering and pro????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????process. The facility primarily uses the "Hazard and Operability" (HAZOP) and/or "What If'" techniques, supplemented with checkl??? ?????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????ndations. Responsibility for resolving the recommendations is assigned to personnel and, when appropriate, changes to enhance th????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????her to develop and maintain accurate operating procedures to define how tasks related to process operations should be safely per????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????ke during both normal operations and upset operating conditions. The operating procedures include: - steps for safely conduct????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????s annually. 5. Training. GP/Palatka trains employees to safely and effectively perform their assigned tasks. The facility tra????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????ining materials before the employee can operate the process. The operators are consulted annually about the frequency of the ????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????ing are implemented as appropriate. 6. Contractors. GP/Palatka has established a program to help ensure that contractor acti????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????y response procedures for the facility. The facility requires that the contractor supervisors train each of their employees who ????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????rs' training documents and work performance to ensure that safe practices are followed. 7. Pre-startup Safety Reviews. GP/Pa????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????- employee training has been completed - for a covered process, a PHA has been performed if the process is new or management ???????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????? completed to document the review and to ensure that the appropriate issues have been addressed. 8. Mechanical Integrity. GP???????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????? ensure that new and replacement equipment meets the design standards required for service in GP/Palatka covered processes. The ????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????ecifications for replacement parts and equipment - standard maintenance procedures for inspecting, testing, and maintaining p????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????s at the facility. The facility reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a) and created a ????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????ork Permit form. The supervisor reviews the completed form before work can begin. 10. Management of Change. The GP/Palatka "???????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????? full "management of change" program to help ensure that inadvertent consequences of the process changes are prevented, safety c???????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????? employees are notified of the changes. 11. Incident Investigations. GP/Palatka investigates all incidents that could reason????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????commendations are resolved and appropriate process enhancements are implemented. 12. Compliance Audits. GP/Palatka audits th????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????ations. The facility assembles an audit team that includes personnel knowledgeable in the RMP Rule and in the process, and this ???????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????? is sufficient to help ensure safe operation of the process. The results of the audit are documented, recommendations are resolv????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????addition to the required preventi on program elements, GP/Palatka has implemented safety features specific to the Chlorine Dioxid????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????of transporting large quantities of the solution. Chlorine dioxide is produced in the chlorine dioxide generator and piped to an????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????reduce and/or replace chlorine in the bleaching process. Plans are being completed to construct a new Chlorine Dioxide generator??????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????? ???? ????? ???? ?modFO.OpenBlankFormA?3/4aA(?????????? ??????? ???? ???? ???? ?modFO.FormPlusHelpA?3/4aA(??????? ??????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????? ????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????? ? ? ? ? ? ? ? ? ? ? ? ? ??{lf`f`ZZTNHB?????r??????r????????r? ????H????H????H????H????H????H????H????H?j ?C???????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????1.5 Five-Year Accident History There have been no accidental releases that have met the reportable criteria. 1.6???????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????? ?????????????????????????????????????????????????????????????????????????????????????????????????????????????????????? ?????????? ? y ? } ? } ? } ? } ? u ? s ? } ? AAAAAAA ?????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????atka) is committed to operating in a manner that is safe for GP/Palatka workers, the public, and the environment. As part of thi????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????ility. One component of this system is a Risk Management Program (RMP) that helps manage the risks at the facility and addresses???????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????? Prevention Requirements: Risk Management Programs (the RMP Rule). One of the requirements of the RMP Rule is to submit a Risk M?????????????????????????????????????????????????????????????????????????????????????????????? ??????????????????????????????????fy the RMPlan requirements of the RMP Rule and to provide the public with a description of the Risk Management Program at the fa????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????a) the potential off-site consequences of hypothetical accidental releases and (b) accidents that may have occurred during the l????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????.2 2. a prevention program to help maintain and safely operate the processes containing more than the threshold quantity of t???????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????? damage from a release, if such a release occurs. The facility trains workers to respond to upset conditions, reducing the conse???????????????????????????????????????????????????????????????????????? ???????????????????????????????????????????????????????? to help ensure that injuries and/or environmental damage will not occur in the event a release does occur. The safety progra????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????preservation of the environment through the prevention of accidental releases of the hazardous substances. The facility implemen???????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????? personnel; programs to help ensure safety in the design, installation, operation, and maintenance of the processes; and program?????????????????????????????????????????????????????????????* |