Procter & Gamble Paper Products Co. - Mehoopany - Executive Summary |
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COMMITMENT TO SAFETY AND ENVIRONMENTAL STEWARDSHIP Procter & Gamble (P&G) Mehoopany has a long-standing commitment to maintaining a safe work environment for our employees and minimizing the impact of our operations on the environment. We take a leading role in developing innovative, practical solutions to environmental issues related to our products, packaging and processes. We use environmentally sound practices even in the absence of governmental standards. Our safety and environmental programs are managed by well trained and qualified employees, and are actively supported by the participation of all employees, site leadership, and a strong central staff. Loss prevention is the goal and first priority of P&Gs safety and environmental programs. Safety teams focus on training and special projects and exist in every department across the site. P&G's safety record is among the best in the United States and in the industry, and we are constantly striving for improvement. Some of o ur most recent improvements are enhancements to our key element safety assessment procedures and team safety leader/new manager safety training . Awards presented to the Mehoopany site for its excellent safety record include the 1996 & 1997 American Forestry and Paper Association Awards for our Tissue/Towel Plant. P&G is very committed to the safety and protection of the local community and our neighbors. P&G employees have strong, healthy relationships with of the Emergency Management Agency (EMA) and are charter and long standing members the Local Emergency Planning Commission (LEPC). P&G has supported the these groups in several areas such as flood forecasting, tornado response, participation & observation in our chemical emergency response drills, and leading a community task force on local community communications in case of a chemical spill in the area. The Mehoopany site has 40 employees trained to serve on the P&G Hazardous Materials (HAZMAT) Response Team and has an activ e site fire brigade with 116 employee participants. Many P&G employees live in the vicinity of the site, and support local community emergency providers. P&G employees represent 30 local fire companies in the area and 52 employees are certified in either Emergency Medical Technician or CPR/First Aid training. The site has 87 employees on our confined space rescue teams. P&G is also active in the Northeast Pennsylvania Chapter of the Society of Safety Engineers and the Northern Tier Safety Association. P&G is also very committed to the safety, health, and protection of the environment. The Mehoopany site has had a strong history of reducing waste, discharge and emissions, and has actively pursued pollution prevention as a business strategy. This site has reduced it wastes to landfill by over 85% since 1983, voluntarily reduced wastewater discharges by over 38% since 1985, and reduced air emissions by 9% since 1985. In 1994, the site eliminated the use of chlorine in pulp bleachin g, and eliminated rail car storage of chlorine. P&G has received numerous environmental awards, US EPA 33/50 Success Story for chlorine bleaching elimination in 94, the Governors Waste Minimization Award in 94, the including the Pennsylvania Governors Award for Environmental Excellence in 1996 for ammonia nitrogen reduction, and continued recognition in Renew Americas "Environmental Success Index" for our recycling & pollution prevention results from 90 to 97. The Mehoopany site has also had a strong record of compliance with environmental laws and regulations. P&G Mehoopany site employees have participated in Earth Day celebrations, provide environmental training in local schools, sponsor and actively participate in the 5th Grade Environmental Day, and co-sponsor the Environmental Partnership Awards for Northeastern Pennsylvania. SOURCE AND SUBSTANCE: PREVENTION, CONTROL , AND MITIGATION The P&G Mehoopany plant manufactures tissue/towel products, such as Bounty and Char min, as well as diapers, such as Luvs and Pampers. Although not a raw material used directly in our products, Chlorine is used to disinfect the water processes to prevent bacteria growth, not unlike many other municipal water and wastewater treatment plants. Chlorine is delivered to our site by dedicated trucks which carry multiple one ton cylinders of chorine. These cylinders are made of heavy gauge metals appropriate for chlorine storage and are designed for sturdy handling and exposure to the elements. Empty cylinders of chlorine are delivered and replaced by the supplier on-site. There are four locations where the one ton (2,000 pounds) chlorine cylinders are stored and used. The storage cylinders are above ground, and are protected by barricades. The chlorine cylinders are monitored every shift and routine maintenance of the cylinders is performed by the chlorine supplier. Chlorine is completely consumed in the reactions in our processes. A number of safety systems are in place at the P&G Mehoopany site to reduce the potential for accidental releases and to quickly respond to those which might occur. The process design and operating systems are continually assessed and improved through a procedure detailed by the OSHA regulations for Process Safety Management (PSM) which is also used to identify potential points from which chlorine may spill or leak from the process. These points have received special consideration during the process design, the training of operators and maintenance personnel, and in the development of our accident prevention and response systems. The studies are updated routinely by a team of specially trained and qualified employees and engineers. Training, maintenance, controls, operating practices, and purchasing requirements are updated based on the results of these hazard studies. The results of the assessments are communicated to all effected employees in a timely fashion. Improvements resulting from these assessments ov er the last five years included improvement in the tubing in the chlorine process to a more robust material, improved labeling, improved access for chlorine cylinder deliveries, installation of barricades around the cylinders, and more rigorous and routine process checks and inspections. A formal change management system is employed on site for any and all changes to process systems. The system includes a review of proposed changes by a group of individuals who are highly skilled in their fields of expertise. Changes are proposed, reviewed, and adjustments made as necessary to ensure personnel, process, and environmental safety is maintained. A planned change to the chlorine system currently underway is the relocation of pipe bridges to allow easier access for loading and unloading of cylinders. RELEASE SCENARIOS - ASSESSMENT PUBLIC IMPACTS In order to meet the requirements of the Environmental Protection Agency (EPA) Risk Management Program (RMP), the site has assessed a "worst case" and an "alternative" release scenario and considered the potential community effect which is summarized here. A "worst case scenario" is defined by the EPA as an instantaneous release of the single largest vessel (one storage cylinder), outdoors, during a time of light winds and stable weather conditions. An instantaneous release of this kind is assumed to release the entire contents of one of the chlorine cylinders. The worst case release assumes that no emergency response would occur, even though both the on-site emergency response team and the HAZMAT team contracted by the community are trained to respond to this type of scenario. The spill of an entire storage cylinder would disperse into the air. The EPA defines an "alternative release scenario" as a ten minute release from a more likely scenario that would migrate off-site, and assumes more normal weather conditions. A supply valve failure on a one ton chlorine cylinder was assumed to release the entire contents of t he tank for this scenario. The repair/capping systems and/or valves to shut down the chlorine system would be activated well within ten minutes. EPA Risk Management Program Guidance for Wastewater Treatment Plants (published October 1998) was utilized to estimate the distance a chlorine vapor cloud (at a certain concentration predetermined by EPA) could travel in the unlikely event of the worst case scenario or alternative release scenario as defined above. Since the winds would blow the cloud in only one direction (or would disperse the cloud more quickly if it was to blow in multiple directions), and given that chorine gas is heavier than air, chlorine would follow low land/stream areas. Therefore, the impacts presented above would overestimate the impact of a worst case release. The sites worst case and alternative release scenarios have offsite consequences. EMERGENCY RESPONSE The goal of the safety & environmental programs at P&G is prevention - it is our first line of defens e. Our chlorine systems have numerous process controls, alarm systems, and emergency shut-down procedures. Highly skilled and qualified technicians monitor the process round the clock from three control rooms equipped with computers that monitor the processes chlorine is fed to, and also contain detailed inventory tracking logs. Chlorine cylinders are only switched when a cylinder goes empty and deliveries to replenish the supply at the various locations are done in one delivery to minimize the unlikely event of accidental leaks or spills. In the event of an accident, the site has systems to respond to the spill or leak quickly to minimize impacts. Spills or leaks of chlorine can be quickly communicated to emergency responders by personnel on the scene from phones located in the control rooms, or by hand-held two-way radios carried by many personnel and a plant wide alarm system. The police and fire departments have procedures to manage direct communications with the general pu blic in any affected neighborhoods. Response drills are conducted once every three years and the local EMA and the LEPC have been invited. The drills allow the opportunity to train new responders, to refresh the skills of the experienced responders, and to improve the communications and response systems. Equipment that may be used to respond during a real emergency, such as a water spray system and emergency response protective equipment, is employed during these drills. The local fire department, LEPC, and EMA have been toured through the site to make them aware of hazards and risks on site, and where critical materials are stored. All of the chlorine system operator & maintenance technicians have been qualified in all of our standard operating procedures. The operating procedures include both routine and non-routine operations. A total of forty employees are trained as part of a Hazardous Materials Team (HAZMAT), and eight to ten HAZMAT Team members are available on each shif t. All employees participate in the emergency response drills held once every three years and complete refresher training on the systems annually. The assessments and results of the emergency response drills are communicated to site employees. An emergency response plan has been developed and coordinated with the EMA and the LEPC, including the fire department, hospitals, and police. A very successful full scale drill and test of the emergency response system was conducted most recently in September of 98, as has been done every three years prior to that. In addition, plant emergency response teams drill on a more regular basis. Further improvements were made to various systems as a result of the drill. HISTORY OF SAFE OPERATIONS The P&G Mehoopany site has an excellent history of chlorine system safety. There have been no RMP reportable accidents at this site involving the chlorine systems during the last five years. |