Donohue Industries Inc. Lufkin Texas Mill - Executive Summary |
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I. EXECUTIVE SUMMARY - Donohue Industries Inc.Lufkin Facility Donohue is committed to operating in a manner that is safe for Donohue employees, for the public, and for the environment. As part of this commitment, Donohue has established a system to help ensure safe operation of the processes at this facility. One component of this is a risk management program (RMP) that helps minimize the risks at Donohue and that complies with the requirements of the Environmental Protection Agency?s (EPA?s) regulation 40 CFR part 68, Accidental Release Prevention requirements: Risk Management Program ( the RMP rule). One of the requirements of the rule is to submit a risk management plan (RMPlan) describing the risk management program at the Donohue, Lufkin Mill. This document is intended to summarize and communicate the RMP elements for the interested public and satisfy the RMPlan requirement of the RMP rule. 1.1 Accidental Release Prevention and Emergency Response Policies Donohue is comm itted to the safety of employees and the public and the preservation of the environment through the prevention of accidental releases of hazardous chemicals. These controls include: training programs for personnel; programs to help ensure safety in the design, installation, operation, and maintenance of processes at Donohue; and programs to evaluate the hazards at Donohue. In the event of an accidental release, Donohue will control and contain the release in a manner that will be safe for workers and will help prevent injury to the public or the environment. Donohue is actively involved with other local industries and the Local Emergency Planning Commission (LEPC). This group has invested in the First Alert emergency notification system that can be activated day or night during emergencies to automatically call residents and businesses. A voice message can inform individuals of the emergency and instruct them on the proper safety precautions to follow. 1.2 Donohue's Regulated Su bstances Donohue is an integrated pulp and paper mill primarily involved in the manufacture of bleached pulp and related finished paper products. Chlorine dioxide and chlorine are used in sufficient quantities to be covered by the RMP rule, although chlorine dioxide will be used at a concentration below the regulated level. A risk management plan was prepared for chlorine dioxide as an additional safe guard for that system. The recently installed chlorine dioxide generation system eliminated the use of chlorine in railcars. Chlorine dioxide is an integral part of the paper making process and is used to bleach pulp. Chlorine in cylinders is used to treat and disinfect water and waste water. 1.3 Offsite Consequence Analysis Worst Case Scenario The Environmental Protection Agency (EPA) requires a worst-case release scenario analysis and an alternative release scenario analysis for chlorine dioxide and chlorine. The worst-case scenario is intended to provide an estimate of the max imum possible area that might be affected under catastrophic conditions. In other words, the worst-case release is based on EPA?s estimate of the worst possible accident that could occur at any given facility. The worst-case scenario at Donohue Lufkin Mill involves the storage tank that stores chlorine dioxide prior to its use in the bleaching process. The RMP rule requires Donohue to assume that all the contents of the tank will be released in 10 minutes. The worst-case scenario also assumes that no safety equipment operates properly and no plant personnel respond to contain the leak. The EPA-defined endpoint for this analysis is estimated to be beyond the boundaries of the facility. Donohue does not expect the worst-case scenario to occur. Alternative (more-likely ) Release Scenario (one for CLO2 and CL2) Although the probability of a release remains small, the alternative release scenario is intended to represent what is more likely to happen in the event there is a release. Fo r the Donohue Lufkin Mill, the alternative release scenario for chlorine dioxide involves a rupture of a 4" supply line. The alternative release scenario for chlorine involves a break in the 3/4" tubing connected to a chlorine cylinder. These analyses were completed using appropriate information concerning physical location, detection methods, equipment layout and expected response time along with the guidelines provided by the EPA. The endpoint concentrations for both alternative release scenariors would extend slightly beyond the plant boundaries. 1.4 Accidental Release Prevention Programs and Chemical-specific Prevention Steps Donohue complies with the OSHA Process Safety Management Rule (29 CFR 1910.119) and with the EPA RMP rule. The accident prevention programs in place at Abitibi include: distribution of safety information, hazard analysis and review, defined operating procedures, training of personnel, proper maintenance of systems, thorough evaluation of process changes and safety checks of new processes. Safety Information - Donohue maintains a variety of technical documents that are used to help ensure safe operation of the Mill?s processes. Material safety data sheets (MSDSs) document the physical properties of hazardous substances handled at Donohue, including substances regulated under the RMP rule. Hazard Analysis / Hazard Review - Donohue performs and periodically updates hazard reviews of the covered processes to help identify and control possible accidental releases. Operating Procedures - Donohue develops and maintains operating procedures to define how tasks should be safely performed. The operating procedures are used to train employees and to serve as reference guides for appropriate actions to take during both normal operations and process upsets. Training -Donohue trains personnel to safely and effectively perform their assigned tasks. This includes initial and refresher training for Operations and Maintenance personnel. Mainten ance - The Donohue maintenance program includes (1) procedures to safely guide workers in their maintenance tasks, (2) worker training in maintenance procedures, (3) an inspection and testing program, and (4) a quality assurance program. Managing Change - Donohue evaluates and approves all proposed changes to chemicals, equipment, and procedures for covered processes. Safety consequences of changes are addressed, safety information and procedures are updated, and affected employees are notified of the changes. Pre-startup Safety Review - Donohue performs safety reviews of new or modified covered processes before they are placed into service to help ensure safe operation. Compliance Audit - Donohue performs periodic compliance audits of covered processes to verify that they are operating in compliance with the requirements of the RMP rules. A compliance audit report is prepared after each audit and any deficiencies noted by the audit are corrected in a timely manner. Incident In vestigation - Donohue investigates all incidents that could have resulted in serious injury to personnel, the public, or the environment so that future accidents can be prevented. The results of the investigation are documented, recommendations are resolved, and appropriate process improvements are implemented. Employee Participation - Donohue involves Mill personnel in the prevention program activities of all processes at the facility. Hot Work Permits - Donohue has a hot work permit program to control spark or flame producing activities that could result in fires or explosion as outlined in OSHA?s fire prevention and protection requirements (29 CFR 1910.252). Contractors - Donohue has a program to help ensure that contractor activities at the Donohue facility are performed in a safe manner. Chemical-Specific Prevention Steps for Chlorine Dioxide and Chlorine - Industry standards are followed at Donohue to help ensure safe handling of chlorine dioxide and chlorine. The vendors s upply chlorine in Department of Transportation (DOT) approved containers. Workers who perform operations involving chlorine dioxide or chlorine receive training for the safe handling procedures for these chemicals. 1.5 Five-Year Accident History The RMP rule requires Donohue to maintain a five-year accident history of all accidental releases from covered processes that resulted in death, injury, significant on-site property damage, off-site property damage, evacuations, shelter-in-place, or off-site environmental damage. The Lufkin Mill has done an excellent job in preventing accidents and in five years there have been only two minor incidents involving chlorine. Both incidents involved a release of less that one pound of chlorine and did not result in any significant injuries. Further, neither of the two releases resulted in any off-site consequences. 1.6 Emergency Response Programs An Emergency Response Plan has been developed for the Lufkin Mill. The response portion of thi s plan includes: permanent fire protection systems, mobile fire fighting and hazardous material handling equipment, training for employees and emergency responders, a computer modeling program to predict the movement of air-borne materials , a mutual aid agreement with City of Lufkin Fire Department and active membership in the Angelina County Local Emergency Planning Commission (LEPC). Notification capabilities include: alpha-numeric pagers for the emergency response team (personnel assigned to each shift), 24 hour on-site fire/ safety inspectors (EMT certified), and a rotating emergency call list. Donohue can also activate a 24-hour community notification system. This system can automatically call affected residents and businesses with emergency information and instructions within minutes. 1.7 Planned Changes to Improve Safety Donohue is committed to the process of continuous improvement. Improvements in the safety and environmental aspects of the operation are critical components of the commitment. The following changes to improve safety are planned or have recently been completed. ? The facility will no longer use chlorine in railcars for bleaching. ? There has been a reduction of chlorine cylinder inventories stored on-site. By reducing the chlorine inventory, the potential consequences of an accidental release were also reduced. ? Several chlorine monitors and alarms have been added for the cylinder systems to help alert operators of upset conditions. ? Rollers were added under the chlorine cylinders to help prevent the possibility of a liquid release. ? The North and South water chlorination systems will be relocated in 2001, to an area away from the Mill and Public population. This area is closer to the group that maintains the systems and will improve response time for any emergencies. |