S.D. Warren Co. (Somerset Mill) - Executive Summary
Risk Management Plan |
S.D. Warren Company
I. Executive Summary
A. Accidental Release Prevention and Emergency Response Policies
S.D. Warren Company is committed to operating its integrated pulp and paper mill in Skowhegan, Maine in an environmentally responsible manner and to providing a safe work place for its employees and the surrounding community. As part of this commitment to environmental stewardship and employee safety, S.D Warren has developed and implemented numerous environmental and safety programs that are designed to eliminate and/or drastically reduce the potential for accidental releases. S. D. Warren has also developed and implements a number of programs that are designed to ensure that if an accidental release occurs, it will be handled in a manner that minimizes adverse impact to people, the environment and the mill. Many of these programs have been in place since the late 1980s.
S.D. Warren believes that saf
ety, health, and environmental protection are essential to the responsible operation of its facilities. S.D. Warren views accident prevention, and personnel and environmental protection as a continuous process. Consequently, S.D. Warren continuously strives to improve its accident prevention, environmental protection and emergency response programs. A recent addition to S.D. Warrens overall accident prevention and response program is the development of the Somerset mills Risk Management Program. Somersets risk management program complies with the U.S. Environmental Protection Agencys ("EPAs") Chemical Accident Prevention rule found at 40 C.F.R. Part 68. One of the requirements of this rule is to submit a Risk Management Plan (RMP) to the EPA. This document satisfies the requirement by providing the public with information about processes, accident prevention programs and emergency response planning efforts at the Somerset mill. Somersets compliance with EPAs RMP rule inc
1. Completion of a hazard assessment in compliance with 40 C.F.R. Part 68, Subpart B, including the five-year accidental release history.
2. Implementation of an accident prevention program. The mills RMP program to prevent accidental releases of regulated chemicals complements the existing Process Safety Management (PSM) program which was developed in 1994 under similar rules administered by the Occupational Safety and Health Administration "OSHA";
3. Implementation of an emergency response program. As recommended in the RMP rule and by numerous federal response entities, the mill is developing a single integrated contingency plan (ICP) that is designed to meet the emergency response planning requirements under a number of applicable state and federal emergency response and accident prevention planning laws.
Additional information regarding how Somerset addresses each of these requirements is summarized below and in the attached RMP.
While the RMP program at Somerset help
s ensure that the facility is maintained and operated in a safe and environmentally responsible manner, it is just one component of Somersets comprehensive safety and environmental programs. Additional components include, but are not limited to:
1. Maintenance of a fully equipped and trained Hazardous Materials Response Team (Hazmat Team) and Fire Brigade;
2. Regular employee/contractor safety training;
3. Participation with and representation on the local emergency planning committee (LEPC);
4. Coordinated training and drills with the local fire departments;
5. Periodic table-top and full scale safety and emergency response drills;
6. Acquisition and maintenance of emergency response and personnel protective equipment;
7. Development of safe work practices ( e.g. confined space, lockout/tagout; etc.)
8. New project safety review procedures;
9. Preventive maintenance procedures;
10. Material chemical intake and purchasing procedures;
11. Medical emergency response training;
Contractor certification; and
13. Forklift training.
In addition, the mill and all equipment are designed and operated to minimize the possibility of an accidental release.
S. D. Warrens commitment to environmental stewardship and providing a safe workplace is demonstrated in its phase-out of elemental chlorine in 1997 and aqueous ammonia at the waste treatment plant in 1998. In 1999, the mill decreased its propane storage levels by 1/3 in two different locations. Somerset is also integrating all of its emergency response and accident prevention plans into a single, easy to use Integrated Contingency Plan (ICP). The ICP is designed to provide more-effective emergency response guidance and to comply with a number of state and federal laws.
B. RMP Covered Process and Regulated Substances
The Somerset mill is an integrated pulp and paper mill primarily involved in the manufacture of bleached pulp and fine coated papers. In 1997 it replaced chlorine in its bleaching process w
ith chlorine dioxide making the process an Elemental Chlorine Free System (ECF). The only chemical present at the mill in sufficient quantities to be regulated by the RMP rule is chlorine dioxide used in the bleaching process (covered process). Chlorine dioxide comprises approximately 1% of a liquid mixture that is stored in four 110,000 gallon tanks. These tanks are protected by a dike that is designed and capable of holding 110% of the single largest storage tank. In addition to containing a liquid release, the dike is designed to mitigate the adverse impact of any vapor release that could potentially result from a liquid spill of the mixture by reducing the surface area of the exposed liquid.
At a concentration of 1%, the total amount of chlorine dioxide stored on-site could be 36,684 pounds. The amount of chlorine dioxide stored in any single vessel is normally 9,170 pounds.
C. Off-site Consequence Analysis
An off-site consequence analysis is required by the RMP rul
e to estimate potential impacts to the community. Somersets off-site consequence analysis included evaluation of a worst-case accidental release and an alternative release.
A worst-case release is defined by EPA as "a release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to an endpoint defined in ' 68.22." 40 C.F.R. ' 68.3. EPA requires the worst-case accidental release to be modeled using highly conservative meteorological data designed to result in the maximum possible adverse impact. For example, EPA requires worst-case models to be based on the hottest day of the year, occurring at night with a very slow, steady wind which would not disperse a release very effectively. Further, the model assumes that the entire contents of the largest tank is released instantaneously. While it is virtually impossible for an entire 110,000 gallon tank to instantaneously release its contents, the chances of this occ
urring in Central Maine on a 960F night with the most stable atmospheric conditions and the wind blowing at 3.4 miles per hour are extremely remote.
Under the EPA mandated scenario described above, the worst-case release at the mill for purposes of RMP would result in a vapor cloud that could extend beyond the mills fence line. To further mitigate adverse impacts associated with this worst-case release, Somerset is building a new dike around the chlorine dioxide storage tanks that is designed to contain a liquid chlorine dioxide spill and reduce the surface area of the pool of ClO2 in the event of a spill. The reduced dike surface area will minimize vapor released from such a spill. The newly constructed dike would reduce the potentially impacted off-site areas by the worst case release by approximately 50%.
An alternative release focuses on more realistic release scenarios occurring during more common meteorological conditions. After considering all criteria in the RMP rule,
Somerset chose an alternative release scenario. The alternative release scenario modeled a spill of 2,400 gallons of chlorine dioxide solution at 1% concentration.
D. Accident Release Prevention Program
Somerset has developed an accidental release prevention program that is designed and implemented to reduce the possibility of an accidental catastrophic release from the covered process. The program complies with the requirements of OSHAs Process Safety Management rule found at 29 C.F.R. Part 1910.119 and analogous RMP requirements found at 40 C.F.R. Part 68, Subpart D. To comply with the RMP rule, the mill has taken its existing PSM program and incorporated an additional focus -- protection of the public.
The basic elements of Somersets accident prevention program are described below:
1. Employee Participation. Somerset has developed and implements a written plan of action regarding employee participation in the safety and accident prevention process. The plan describe
s how employees are: (A) consulted and what input they will have in the development of Process Hazard Analysis (PHA) and other PSM and RMP safety elements; and (B) given access to PSM and RMP information at the mill.
2. Process Safety Information. In accordance with applicable requirements, Somerset has compiled and maintains written process safety information about the design, installation, maintenance, and operation of the covered process. This ensures that information remains current.
3. Process Hazard Analyses. Somerset performed a process hazard analysis (PHA) on the covered process. The PHA is a key component of the process safety management system and Somersets RMP accident prevention program. It is a thorough, orderly, systematic approach for identifying, evaluating, and addressing potential hazards posed by the covered process.
Specifically, the PHA addressed: (1) hazards of the covered process; (2) engineering and administrative controls applicable to the ha
zards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases (e.g., process monitoring and control instrumentation with alarms); (3) consequences of failure of engineering and administrative controls; (4) facility siting; (5) human factors (human error); and (6) a qualitative evaluation of a range of the possible safety and health effects of failure of controls on the employees in the work place.
4. Operating Procedures. Somerset has developed and implemented written operating procedures that provide instructions for safely operating the covered process. These procedures are consistent with the process safety information described earlier and include:
A. Initial startup;
B. Normal operations;
C. Temporary operations;
D. Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is e
xecuted in a safe and timely manner;
E. Emergency operations;
F. Normal shutdown;
G.Startup following a turnaround, or after an emergency shutdown;
H.Consequences of deviation from operating limits;
I. Steps required to correct or avoid deviation;
J. Precautions necessary to prevent exposure, including maintenance activities, engineering controls, administrative controls, and personal protective equipment;
K. Control measures to be taken if physical contact or airborne exposure occurs;
L. Quality control for raw materials and control of hazardous chemical inventory levels; and
M. Safety systems and their functions.
Somerset has also developed and implements safe work practices that provide for the control of hazards during operations of the covered process. For example, Somerset has programs that govern the following activities: lockout/tagout; confined space entry; opening process equipment or piping; and controls entrance into PSM and RMP covered process areas by maintenance, c
ontractor or other support personnel.
5. Training. Somerset provides employees, contractors and visitors with training that focuses on the special safety and health hazards posed by the mills operations, the RMP and PSM covered process, emergency operations including shutdown, and safe work practices applicable to the employees job tasks. Somerset confirms that employees and contractors involved in operating a covered process have successfully completed the required periodic training. Somerset documents that covered employees and contractors have received and understood the required training. Documentation, at a minimum, includes the identity of the employee or contract employee, and the date of training.
6. Contractors. As part of Somersets contractor selection process, it obtains and evaluates information regarding contract employers safety performance and programs. 29 C.F.R. ' 1910.119(h). Somerset also:
A. Informs contract employers of the known potential fire, expl
osion, or toxic release hazards related to the contractors work and the covered process;
B. Explains to contract employers the applicable provisions of the facilitys emergency response plans (discussed below); and
C. Controls the entrance, presence and exit of contract employers and contract employees in covered process areas.
7. Pre-startup Safety Review. As required, following a modification or change to the covered process, a pre-startup review is conducted to ensure that the process was constructed and the equipment is in accordance with design specifications; and safety, operating, maintenance, and emergency procedures are in place to adequately protect the health and safety of employees and the nearby public.
8. Mechanical Integrity. Somerset has developed and implements written procedures to ensure the ongoing integrity of the chlorine dioxide process equipment listed below. Somerset also trains employees to maintain the following process equipment:
A. Pressure vessels a
nd storage tanks;
B. Piping systems (including piping components such as valves);
C. Relief and vent systems and devices;
D. Emergency shutdown systems;
E. Controls (including monitoring devices and sensors, alarms, and interlocks); and
9. Hot Work Permit. As part of its overall fire protection program, Somerset maintains a hot work permit program for all hot work operations (e.g., welding, soldering) conducted on or near the covered process.
10. Management of Change. Somerset has established and implemented a procedure to authorize and document changes to the covered process. This procedures ensures that the all required considerations are addressed prior to any change:
11. Incident Investigation. Somerset investigates each incident which resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical in the workplace. An incident investigation team is established and consists of at least one person knowledgeable in the process
involved, including a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident.
12. Emergency Planning and Response. Somerset is developing an integrated contingency plan that satisfies all applicable state and federal emergency response and prevention planning requirements (described under emergency response policies below).
13. Compliance Audits. Somerset has evaluated compliance with OSHAs PSM Standard at least every three years to verify that the procedures and practices it has developed are adequate and being followed. A similar schedule for RMP will be established.
14. Trade Secrets. Somerset makes all necessary information available to those persons responsible for compiling the process safety information and those assisting in the development of the process hazard analysis.
E. Five Year Accident History
The Somerset plant experienced one RMP re
portable incident during the last five years. In 1998 an incident occurred which involved an incidental release of chlorine dioxide gas from a sewer system. One employee was treated for a sore throat and coughing as a result of this exposure.
F. Emergency Response Procedures and Policies
Somerset maintains a fully trained Hazardous Materials Response Team and Fire Brigade that is on-site 365 days a year, 24 hours a day. These teams are capable of minimizing the adverse impact from reasonably forseeable accidental releases that may occur.
In the unlikely event that an accidental release occurs that is beyond the capabilities of Somersets Hazardous Material Response Team and Fire Brigade, the mill has entered into mutual aid agreements with the Skowhegan and Fairfield Fire and Police Departments, Maine General Medical Center and Redington-Fairview General Hospital, and several private emergency response contractors. The mutual aid agreements allow these entities to respond to
emergencies at the mill upon request by Somerset. The Skowhegan fire Department operates under mutual aid agreements with the towns of Fairfield, Canaan, Cornville, Anson, Clinton, Norridgewock, and Waterville which ensure that additional emergency response personnel and equipment are available to respond to a significant release at the mill.
Somerset is developing an Integrated Contingency Plan designed to meet the regulatory requirements of the following federal and state response planning and prevention laws:
7 OSHA emergency response plan (29 C.F.R. 1910.120(q))
7 OSHA Process Safety Management emergency response requirements (29 C.F.R. ' 1910.119(n))
7 OSHA Hazard Communication Plan (29 C.F.R. ' 1910.1200(h))
7 EPA Risk Management Plan Emergency Response Program (40 C.F.R. ' 68.95)
7 EPA Hazardous Waste Contingency Plan (851 DEP Regs. ' 8(B)(5) incorporating by reference 40 C.F.R. ' 264.51-.56)
7 EPA Oil Spill Prevention Control and Countermeasure Plan (40 C.F.R. ' 112.7)
7 EPA Best Management Practices Plan (40 C.F.R. ' 112.104(b))
7 Maine Emergency Response Plan (37-B M.R.S.A. ' 795)
7 Maine Hazardous Matter Spill Prevention Control and Cleanup Plan (38 M.R.S.A. ' 1318-C).
The ICP will include, among other things:
7 Procedures for notifying the public and the local emergency responders
7 Arrangements for first-aid procedures and emergency medical treatment procedures for exposure to chlorine dioxide
7 Emergency response and incident termination procedures
7 Procedures for using, inspecting and testing emergency response equipment
7 Employee training procedures
7 Procedures to amend the ICP plan
G. Planned Changes
A new dike wall will be installed inside the existing dike to minimize the surface area of a potential chlorine dioxide release from the covered process. The mill is in the process of integrating its emergency response and spill contingency plans. The mill is scheduled to seal the drain lines in the railroad car unloading area that ar
e tied into the sewer that services the chlorine dioxide process.