Mead Oxford Corporation - Executive Summary |
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Mead Corporation - Maine Paper Operations 1. PURPOSE This document describes Mead Paper Division - Rumford, Maine mill's philosophy and procedures for managing the risk to employee health, contractor health, public health, and to the environment. Besides providing a basis for organizing Process Safety Management and Risk Management Plan activities, this document also helps to meet the OSHA requirement of 29 CFR 1910.119 and EPA requirement of 40CFR Part 68 for a system that oversees the integration and implementation of the elements of a Process Safety Management and Risk Management Plan programs. Other specific purposes of this document are (1) to clearly define how our Process Safety Management (PSM) and Risk Management Plan (RMP) system meets all regulatory requirements and (2) to explain where to find the programs or results related to each regulatory element. The Process Safety Management and Risk Management Plan system is designed to ensure that ongoing implementation is effectively maintained. EXECUTIVE SUMMARY Mead Paper Division - Rumford, Maine is committed to operating in a manner that is safe for Mead employees, contractors, the public, and the environment. As part of this commitment, Mead's Rumford Mill 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. This docu ment is intended to satisfy the RMP requirements of the rule and to provide the public with a description of the risk management program at Mead. These federal regulations apply to this facility because we use various chemicals that are on the PSM/RMP list at or above threshold concentration and quantity. The process safety and risk management program at Rumford consists of three elements: 1. 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 2. 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 3. An emergency response program to help respond to accidental releases of r egulated substances from covered processes - see topic 1.6 Information further describing these elements is provided in this RMPlan. COVERED PROCESSES AND NOT-COVERED PROCESSES Mead Paper Division - Rumford, Maine ("Rumford") has Chlorine Dioxide as a covered chemical. Methanol, a flammable liquid stored in an "atmospheric tank", is treated as a covered system for PSM, but is not a covered process for RMP. Propane, which is stored in excess of 10,000 pounds is not a PSM covered process because it is used for filling propane bottles for industrial trucks, or as a fuel to light off the Lime Kiln burner. Propane is not a covered process for RMP because it is less than the 67,000 pounds limit for the executive stay. The Chlorine Dioxide system includes the manufacture and storage of Chlorine Dioxide and ends at the addition of Chlorine Dioxide to the Bleach Plant mixers. The starting boundaries of the Chlorine Dioxide manufacturing (R-8 Process) begins at the chemical fe ed pumps; the acid feed pump; the methanol feed pumps (P-59 A & B); and the chlorate feed pump. Chlorine Dioxide is also used as a biocide in the Mill. The boundary for the biocide system starts at the tie in to the 1.2% (12 g/l) solution from the Chlorine Dioxide Storage and ends at the mixer in the R-8 Chlorine Dioxide Plant where the solution is diluted to 0.2 % (2g/l) solution. The dilute piping system (2 g/l) is not a covered process for PSM or RMP. Even though the methanol system is not a covered process based upon the Meer decision (OSHRC Docket No. 95-0341), we will continue to treat the system as if it were a covered process for PSM. The ruling was that OSHA's Process Safety Management Standard (1910.119) does not extend to stored flammables in "atmospheric tanks", even if they were connected to a "process" within the definition of the standard. 1.1 Accidental Release Prevention and Emergency Response Policies Rumford is committed to the safety and health of Rumford work ers and the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. Rumford 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 Rumford; and programs to evaluate the hazards at Rumford. In the event of an accidental release, Rumford attempts to control and contain the release in a manner that will be safe for workers and will prevent injury to the public or the environment. Rumford provides response training to Rumford personnel, designates an emergency response coordinator to oversee response activities, and coordinates response efforts with the local fire department. Response activities have been discussed and coordinated with the LEPC. In order to effectively implement these policies, Rumford established a management sy stem headed by the Safety Manager to oversee safety-related activities. 1.2 The Mead Corporation - Maine Paper Operations and Regulated Substances Rumford 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, Rumford 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 Rumford. Process Program Level Regulated Substance Process Quantity (lb.) Chlorine Dioxide 3 Chlorine Dioxide 11,144 Generation and Storage 1.3 Off-site Consequence Analysis Rumford performed an off-site consequence analysis to estimate the potential for an accidental release of a regulated substance affect the public or the environment. The off-site consequence analysis cons ists of evaluating both worst case release scenarios and alternative release scenarios. Rumford does not expect a worst case release scenario to ever occur. The alternative release scenario was selected to help the local emergency planning committee improve the community emergency response plan. An alternative release scenario represents a release that (1) might occur at a facility like Rumford and (2) would result in the greatest potential off-site consequence if the release occurred. 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 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 en dpoint 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 possible. 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 Rumford. These requirements are: One worst case scenario for the class of toxic substances in Program 3 processes (i.e., chlorine dioxide) One alternative release scenario for each of the toxic substance in Program 3 process (i.e., chlorine dioxide) The following information summarizes this off-site consequence analysis performed by Rumford. 1.3.1 Program 3 Processes - Toxic Substances The worst case release scenario for toxic substances is rupture of the 110,000 gallon chlorine dioxide solution (1.2 wt%) storage tank in the Chlorine Dioxi de Generation and Storage process. A dike area contains the released chlorine dioxide solution, which evaporates and forms a vapor cloud. The maximum distance to the toxic endpoint concentration is 0.93 miles. The U.S. Census indicates that 91 people live within this distance from the storage tank; several public receptors are also located within this distance (e.g. commercial businesses). No environmental receptors are within this distance. The alternative release scenario for chlorine dioxide is an outside flange or valve leak of an 8-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 flange or valve for 10 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 0.44 miles. The U.S. Census indicates tha t 91 people live within this distance from the chlorine dioxide release location; several public receptors are also located within this distance (e.g., commercial businesses). No environmental receptors are within this distance. 1.4 Accidental Release Prevention Program and Chemical-specific Prevention Steps Rumford maintains a prevention program to help prevent accidental releases of hazardous substances and ensure safe operation. Rumford follows the EPA RMP rule of the two levels of prevention program requirements. Program 3 - essentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environment. The following sections briefly describe the elements of Rumford's prevention program that address the EPA RMP rule prevention program requirements. 1.4.1 Program 3 Prevention Program The Rumford Program 3 prevention program, which applies to the Chlorine Dioxide Generation and Storage Processes, con sists of the following 13 elements: 1. Employee Participation. Mead Paper Division - Rumford, Maine developed a written employee participation plan for covered processes to help ensure that the safety concerns of Mead employees are addressed. The Employee Participation final plan was written after consultation and review by RMIT (Rumford Mill Improvement Team which focuses on employee involvement), the Management Team, and the Central Safety Committee. The Central Safety Committee has official union representation by both of our unions and is jointly chaired by an hourly and a salaried person. The Central Safety Committee hourly co-chair signed the policy. Rumford employees have access to information developed under the Process Safety Management Standard. The information is in the Process Safety Management Coordinator's office, or information in the office will state where the information or records are stored. 2. Process Safety Information. Mead maintains a variety of technical documents that are used to help ensure safe operations. These documents address (1) chemical hazard information, (2) process technology information, and (3) equipment information. Mead ensures that the process safety information is available to all affective employees. Material safety data sheets (MSDSs) document the physical and health properties of hazardous substances handled at the Rumford Mill, 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 MSDSs for hazardous substances handled in each process are available in the process control rooms so that the operators have ready reference to this information. In addition, MSDSs are provided to the Rumford Fire Department for use in helping formulate emergency 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 relevant control room. Information pertaining to the equipment of the process such as piping and instrument diagrams (P&ID's), relief system design and design basis, and ventilation system design can be found in Document Control. The remaining equipment information can be found in the operating manuals located in the Control Room. 3 Process Hazard Analysis. Mead Paper Division - Rumford, Maine performs and periodically updates (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 safety of the process. A team composed of personnel with engineering, maintenance, and operating experience and a leader with p rocess hazard analysis experience is assembled to analyze the hazards of the process. Mead primarily uses the hazard and operability (HAZOP) technique, supplemented by what-if or what-if/checklist, to perform these analyses. The PHA team leader prepares a written report describing the results of the analysis, 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 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 both during normal operations and process upsets. Operating procedures include: steps for safely conducting activities applicable pro cess 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 personnel develop and maintain operating procedures that cover various phases of operations, including initial startup, normal operations, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations. Mead Safety Professionals, Central Safety Committee, Operations, and Maintenance Personnel develop and maintain Safe Work Practices, such as Zero Energy (Lock Out Tag Out), Confined Space, Line Breaking (opening process equipment or lines), and control over entrance into a covered process by contractors and visitors. 5. Training. Mead Paper Division - Rumford, Maine trains employees to safely and effectively perform their assigned tasks. The M ead 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. Contractors. Mead Paper Division - Rumford, Maine established a program to help ensure that contractor activities at the Rumford Mill 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 explains to the contract supervisors the hazards of the process on which th ey and their employees will work, Mead safe work practices, and Mead emergency 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 periodically reviews contractor, training documents and work performance to help ensure that safe practices are followed. 7. Pre-Startup Safety Review. Mead Paper Division - Rumford, Maine performs a safety review of a new process or modified covered process, if the review is needed based on the hazard analysis in the Management of Change. The review is complete prior to introduction of a highly hazardous material to 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 Ch ange requirements have been completed if an existing process has been modified Management of Change requirements and PHA have 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 safety review checklist is included with the Management of Change form. On large projects the standard engineering pre-start up review documentation may be used. 8. Mechanical Integrity. Mead Paper Division - Rumford, Maine maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger employees, contractors, the public, or the environment. Mead's mechanical integrity program includes (1) an inspection and testing program to help identify equipment deterioration and damage before the equipment fails and (2) a quality assurance program to help insure that new and replacement equipment meet the design standards required for service i n Mead processes. The Mead mechanical integrity program 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 zero energy, hot work, confined space entry, and line breaking training of maintenance personnel documentation of maintenance activities 9. Hot Work Permit. Mead Paper Division - Rumford, Maine established a hot work permit program to control spark or flame producing activities that could result in fires or explosions. The Rumford Mill reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a) and created a Hot Work Permit form and policy to comply with these requirements. Personnel who are to perform hot work are required to fill out the Hot Work Permit Form. The supervisor reviews the completed form and signs it before work can begin. The Hot Work Permits are stored by Plant Protection until the job is completed Training in the use of the Hot Work Permit Form is included in the Mead Paper Division - Rumford, Maine safe work practices periodic training. 10. Management of Change. The Mead Paper Division - Rumford, Maine management of change program evaluates and approves all proposed changes to chemicals, equipment, and procedures for a covered process to help ensure that the change does not negatively affect safe operations. Process changes that are determined to be a replacement in kind (e.g., replacing a valve with an identical valve) are allowed without completing a management of change. All other changes must be confirmed through the management of change program to help ensure that inadvertent consequences of process changes are prevented, safety consequences of changes are addressed, affected process safety information and procedures are updated, and affected employees are notified of the changes. The management of change completed forms are maintained in the mill's Document Control system for a minimum of five years. 11. Incident Investigation. Mead Paper Division - Rumford, Maine investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, and the environment so that similar accidents can be prevented. Mead trains employees to identify and report any incident requiring investigation. An investigation team is assembled, and the investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendations are identified, resolved, and appropriate process or equipment enhancements are implemented. Incident reports remain on file in the Medical Department for at least five years. 12. Compliance Audits. Mead Paper Division - Rumford, Maine audits covered processes to be certain that the Process Safety Management program is effectively addressing the safety issues of Rumford operations. Mead assembles an audit team that includes personnel knowledgeable in the Process Safety Management regulation and in the process. This team evaluates whether the Process Safety Management program satisfies the requirements of 29 CFR 1910.119 and whether the program is sufficient to help ensure safe operations and the process. The results of the audit are documented, recommendations are resolved, and appropriate process enhancements are implemented. The same audit procedures will be used to audit the Risk Management Program. The PSM/RMP Coordinator maintains a copy of the last two audits. 13. Trade Secrets. Mead Paper Division - Rumford, Maine has no trade secrets in the covered processes other than Chlorine Dioxide. The Chlorine Dioxide manufacturing process is licensed from Sterling Chemical. The Rumford Mill under Boise Cascade management signed a confidentiality agreement not to disclose the operating conditions of the R-8 Chlorine Dioxide Plant t o vendors or competitors. The agreement allows us to disclose all information on the R-8 Plant to our employees, and to regulatory officials. At the startup of the Plant in 1992, each operator was given their own personal copy of the R-8 Plant operating manual. Mead Paper Division - Rumford, Maine shall make all information necessary to comply with 29 CFR 1910.119 available without regard to possible trade secret status of such information. Mead Paper Division - Rumford, Maine reserves the right to require confidentiality agreements. 1.4.2 Chemical-specific Prevention Steps In addition to the required prevention program elements, Rumford has implemented safety features specific to the hazardous substances used at Rumford. The following paragraphs describe some of these safety features. Chlorine Dioxide. Chlorine dioxide is produced at the Rumford facility and stored as a dilute aqueous solution to avoid the necessity of transporting large quantities of the solution. Chlo rine dioxide is produced in the chlorine dioxide generator and piped to an absorber column, where a 1.2 wt% chlorine dioxide solution 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 consequences of a release. The chlorine dioxide manufacturing process and chlorine dioxide storage tanks are fully enclosed further reducing the risk of off site consequences. 1.5 Five-Year Accident History Rumford has completed a five-year accident history that indicates continued safe operations at Rumford. The number of accidental releases has been low over the last 5 years. Year Number of Reported Accidents Substance Released Consequences 1994 0 1995 0 1996 0 1997 1 Chlorine Dioxide No off site consequences; 3 injured employees 1998 1 Chlorine Dioxide No off site consequences; 1 injured employee 1999 0 1.6 Emergency Planning and Response Program Mead Paper Division - Rumford, Maine has established a written response program to help safely respond to accidental releases of hazardous substances. The emergency response plan includes procedures for: Providing proper first aid and medical treatment to treat accidental human exposure to hazardous substances (Mead Paper Division - Rumford, Maine has a full time Medical staff on site.) Controlling and containing accidental re leases of hazardous substances, including the use of response equipment Inspecting and maintaining emergency response equipment Reviewing and updating the emergency response plan Training response teams (HAZMAT, Rescue, Fire Brigade, and Security) Mead Paper Division - Rumford, Maine maintains emergency response teams trained in emergency response procedures. (The emergency teams are a Pulp Mill HAZMAT Team, an Emergency Response Team (HAZMAT, Confined Space Rescue, Fire Brigade, and Security Team) and a Medical Staff.) All Mead Paper Division - Rumford, Maine employees are trained in evacuation procedures. Mead periodically conducts emergency response drills, including drills coordinated with the Rumford Fire Department. The written emergency response plans complies with OSHA regulations 29 CFR 1910.38(a), 29 CFR 1910.120(a), 29 CFR 1910.119(n) and has been communicated to local emergency response officials through the Rumford Fire Department. 1 .7 Planned Changes to Improve Safety Rumford constantly strives to improve the safety of the processes at Rumford through both the incident investigation program and a program soliciting safety suggestions from the workers. In fact, Rumford has a comprehensive safety program in place establishing many levels of safeguard against release of a hazardous substance and injuries and damage from release of a hazardous substance. Rumford limits the use of hazardous substances. A Chemical Management system is in place to review all chemicals in the Mill and to screen all new chemicals. Before using a hazardous substance at Rumford, less hazardous alternatives are considered. When a hazardous substance is used at Rumford, Rumford considers the potential for this substance to adversely affect the workers, the public, and the environment and takes steps to prevent any such effects. Rumford has a current propane inventory of 11,233 gal (47,179 lbs.) as of October 4, 1999. There are administra tive procedures in place as of June 8, 1999 to reduce the propane inventory to a maximum of volume of 15,000 gal (63,000 lbs.). This will place the Rumford facility below the threshold quantity as a covered process based on the Environmental Protection Agency's propane stay of 67,000 lbs. The worst case and alternate release for flammables and the Prevention Program 2 are still listed in the RMP Submit document for information in case the executive stay changes. |