Westvaco Texas, L.P. - Executive Summary
Risk Management Plan
1. EXECUTIVE SUMMARY
Westvaco is committed to operating in a manner that is safe for Westvaco employees, the public, and the environment. As part of this commitment, Westvaco has established a system to help ensure safe operation of the processes at this facility. One component of this system is a Risk Management Program (RMP) that helps manage risks at Westvaco, and also complies 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 Westvaco. This document is intended to satisfy the RMPlan requirement of the RMP rule and to provide the public with a description of the risk management program at Westvaco.
The risk management program at Westvaco consists of three elements:
1. A hazard assessment
to help understand:
(a) the potential offsite consequences of hypothetical accidental releases
(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 regulated substances from covered processes - see topic 1.6
Information further describing these elements is provided in this RMPlan.
Although the risk management program at Westvaco helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety program at Westvaco. In fact, Westvaco has a comprehensive safety program in place establishing many levels of safeguards against release of a hazardous subst
ance and injuries or damage from a release of a hazardous substance.
Westvaco limits the use of hazardous substances. Before using a hazardous substance at Westvaco, less hazardous alternatives are considered. When a hazardous substance is used at Westvaco, Westvaco considers the potential for this substance to adversely affect Westvaco employees, the public, and the environment and takes steps to prevent any such effects.
Westvaco prevents releases of the hazardous substances used at the facility. When a hazardous substance is used at Westvaco, 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 the design, construction, and operation of the equipment.
Westvaco limits damage from a release, if such a release occurs. Westvaco trains employees to respond to an accidental release, reducing the consequences of a release if it occurs. In addition, Westvaco works with
the local fire department and with the local emergency planning committee (LEPC) to help ensure that injuries and/or environmental damage will not occur if a release does occur.
The safety program at Westvaco 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 Westvaco that are required by the RMP rule.
1.1 Accidental Release Prevention and Emergency Response Policies
Westvaco is committed to the safety of employees and the public, and the preservation of the environment through the prevention of accidental releases of hazardous substances. Westvaco 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, operations, and maintenance of processes at Westvaco, and programs to evaluate the hazards at Westvaco.
In the event of
an accidental release, Westvaco controls and contains the release in a manner that will be safe for employees and will help prevent injury to the public or the environment. Westvaco also provides response training to employees, designates an emergency response coordinator to oversee response activities, and coordinates efforts with local emergency planning and response organizations. Response activities have also been discussed with the LEPC.
1.2 Westvaco and Regulated Substances
Westvaco is an integrated pulp and paperboard mill primarily involved in the manufacture of bleached paperboard products. As part of this manufacturing process, Westvaco handles several regulated substances in sufficient quantities to be covered by the RMP rule, as shown in the following list of RMP-covered processes.
Process Program Level Regulated Substance Process Quantity
Monox-L Generation 3
Chlorine 180,000 lb.
Water Treatment/Chlorine 3 Chlorine 180,000 lb.
Chlorine Dioxide Generation 3 Chlorine Dioxide 7,844 lb.
Chlorine DIoxide Generation 3 Chlorine Dioxide 77,691 lb.
1.3 Offsite Consequence Analysis
Westvaco performed an offsite consequence analysis to estimate the potential for an accidental release of a regulated substance to affect the public of the environment. The offsite consequence analysis consists of evaluating both worst-case release scenarios and alternative release scenarios. Westvaco does not expect a worst-case release scenario to ever occur. The alternative release scenarios were 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 Westvaco
(2) would result in a conservative estimate of potential offsite consequences if the release occurred
The main objective of performing the offsite 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 endpoint 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 likely. Some people who are particularly susceptible to the substance released could be in
The RMP rule includes specific requirements for the worst-case and alternative release scenarios that must be reported by Westvaco. These requirements are:
? one worst-case release scenario for the class of toxic substances in Program 3
processes (i.e., one scenario representing both chlorine and chlorine dioxide)
? one alternative release scenario for each of the toxic substances in a Program 3 process
(i.e., chlorine and chlorine dioxide)
The following information summarizes the offsite consequence analysis performed by Westvaco.
1.3.1 Program 3 Processes - Toxic Substances
The worst-case release for toxic substances is rupture of a tank car of 90-tons of chlorine, which evaporates and forms a vapor cloud. The maximum distance to the toxic endpoint concentration is greater than 25 miles. The U.S. Census indicates that 242,313 people live within the 25-mile radius from the storage vessel. This 25-mile radius contains public receptors of all types defined by
the EPA in the RMP regulation. The receptors include schools, hospitals, industrial developments, and residential developments. The primary environmental receptors within the 25 mile radius per USGS maps are Big Thicket National Preserve, E.O. Siecke State Forest, and Sabine Island State Wildlife Management Area.
The alternative release scenario for chlorine is the rupture of a 1" liquid unloading line from a 90-ton tank car. This scenario assumes active mitigation from tank car's built-in excess flow valve, which restricts the release to one that is instantaneous in nature. It is also assumed that this release requires approximately 30 minutes for workers to discover and isolate the ruptured hose. The maximum distance to the toxic endpoint is 2.1 miles. As many as 2,221 people offsite (U.S. Census data indicates approximately 1,406 local residents) could be impacted within this 2.1-mile radius. Several public receptors are also located within this distance (e.g., the local sc
hool, the Pinefield subdivision, the Westvaco park baseball field, and several small businesses). No environmental receptors are within this distance.
The alternative release scenario for chlorine dioxide is shearing off a two-inch sample line on the discharge of a chlorine dioxide solution (1.2 wt%) booster pump in the system that transfers solution from storage to the process injection point. This scenario assumes that the solution is released from the ruptured pipe for 10 minutes before the release is detected and workers can isolate and secure the ruptured 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 2.2 miles. As many as 2,221 people offsite (U.S. Census data indicates approximately 1,406 local residents) could be impacted within this 2.2-mile radius. Several public receptors are also located within this distance (e.g., the local school, part
of the Pinefield subdivision, a local baseball field, and several small businesses). No environmental receptors are within this distance.
1.4 Accidental Release Prevention Program and Chemical - Specific Prevention Steps
Since its inception in 1953, Westvaco has used a prevention program to help prevent accidental releases of hazardous substances. Beginning in 1992, Westvaco formalized this prevention program for the Water Treatment/Chlorine and Chlorine Dioxide Generation and Storage processes to comply with the 13 elements of the OSHA process safety management (PSM) prevention program. In 1996, the EPA RMP rule established 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 Westvaco's prevention program that address the EPA RMP rule prevention program requirements.
1.4.1 Program 3 Prevention Program
o Program 3 prevention program, which applies to the Monox-L Generation, Water Treatment/Chlorine and the Chlorine Dioxide Generation and Storage processes, consists of the following 12 elements:
a. Process Safety Information. Westvaco maintains a variety of technical documents that are used to help ensure safe operations of the Westvaco processes. These documents address:
(1) physical properties of hazardous substances handled at Westvaco
(2) operating parameters of the equipment at Westvaco
(3) design basis and configuration of the equipment at Westvaco.
Westvaco ensures that this process safety information is available to all employees, the local emergency planning committee (LEPC), and the fire department.
Material safety data sheets (MSDSs) document the physical properties of hazardous substances handled at Westvaco, including regulated substances in covered processes. The information available for each hazardous substance typically includes:
? toxicity information and perm
issible exposure limits
? physical data (e.g., boiling point, melting point, flash point)
? reactivity and 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 room so that the operators have ready reference to this information. In addition, MSDSs are provided to the LEPC and the fire department for the use in helping formulate emergency response plans.
The engineering design documents include the operating parameters and the design basis and configuration of the equipment in each covered process. The available information includes:
? operating parameters
? block flow or simplified process flow diagrams
? process chemistry
? maximum intended inventories
? safe upper and lower limits for parameters such as temperature, pressure, or flow
? consequences of deviations from established operating limits
? design basis and configuration of
? piping and instrument diagrams, including materials of construction
? electrical classification
? safety systems
? applicable design codes and standards
? design basis for relief and ventilation systems
When important information was not available for the design documents, it was developed through special projects or, in the case of operating parameters, during process hazard analysis of the process. Many of the operating parameters are included in the operating procedures to help with the safe operation of the process. These documents are used:
(1) to train employees
(2) to perform process hazards analyses
(3) to help maintain the equipment.
b. Process Hazard Analysis. Westvaco performs and periodically updates process hazard analyses (PHAs) of the covered processes to help identify process hazards and generate recommendations that might improve the safe operation of the process. A team composed of personnel with engineering and process operating experience a
nd a leader with process hazard analyses experience is assembled to analyze the hazards of the process. Westvaco primarily uses the hazard and operability (HAZOP) technique, supplemented with checklists, to perform this analysis. The PHA team 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.
c. Operating Procedures. Westvaco 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
(2) serve as reference guides for appropriate actions to take during both normal operations and process
Operating procedures include:
? steps for safely conducting activities
? applicable proc
ess safety information, such as safe operating limits and consequences of process
? safety and health considerations, such as chemical hazards, personal protective equipment
requirements, and actions to take if exposure to a hazardous substance occurs
Westvaco personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operations, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations. The operating procedures are used both to help in operating the Westvaco processes and as a training guide.
d. Training. Westvaco trains workers to safely and effectively perform their assigned tasks. Westvaco 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
(3) a detailed review of the process operating procedures and safe work prac
Oral reviews and written tests are used to verify that an employee understands the training material before the employee can resume work in the process.
The operators are consulted annually at safety meetings to evaluate the effectiveness and frequency of the training. Recommendations from the operators are reviewed, and changes to the training program are implemented as appropriate.
e. Mechanical Integrity. Westvaco maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public, or the environment. The Westvaco mechanical integrity program includes:
(1) an inspection and testing program to help identify equipment deterioration and damage before the
(2) a quality assurance program to help ensure that new and replacement equipment meet the design
standards required for service in Westvaco process
The Westvaco mechanical integrity program includes:
? specifications f
or 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 lockout/tagout, hot work, confined space entry, and line or
? training of maintenance personnel
? documentation of maintenance activities
f. Management of Change. The Westvaco 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. Changes that are determined to be a replacement in kind (e.g., replacing a valve with an identical valve) are allowed without completing a full management of change program. All other changes must be confirmed through the full management of change program to help ensure that inadvertent consequences of process changes are prevented, safety consequences of changes a
re addressed, affected process safety information and procedures are updated, and affected employees are notified of the changes.
g. Pre-startup Review. Westvaco performs a safety review of a new or modified process before the process is placed into service to help 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
? for a covered process, a PHA has been performed if the process is new or management of change
requirements have been completed if an existing process has been modified
A pre-startup review checklist is completed to document the review and to ensure that appropriate issues have been addressed.
h. Compliance Audit. Westvaco audits covered processes to be certain that the prevention program is effectively addressing the safety issues of
operations. Westvaco assembles an audit team that includes personnel knowledgeable in the RMP rule and whether the prevention program is sufficient to help ensure safe operation of the process. The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented.
i. Incident Investigation. Westvaco investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment so that similar accidents can be prevented. Westvaco 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 resolved, and appropriate process enhancements are implemented.
j. Employee Participation. Westvaco developed a written employee participation program for covered processes to help ensu
re that the safety concerns of Westvaco workers are addressed. Westvaco encourages active participation of personnel in 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 PHAs and operating procedures.
k. Hot Work Permits. Westvaco established a hot work permit program to control spark- or flame- producing activities that could result in fires or explosions in covered processes at the Westvaco facility. Westvaco reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a) and created a Hot Work Permit Form to comply with these requirements. Personnel who are to perform hot work are required to fill out the Hot Work Permit Form. The Operating Supervisor/Construction Coordinator/Team Leader reviews the completed form and work area then signs form before work can begin. Training in the use of the Hot Work Permit Form is included in the Westv
aco safe work practices orientation.
l. Contractors. Westvaco established a program to help ensure that the contractor activities at the Westvaco facility are performed in a safe manner. The program reviews the safety record of all contractors to help ensure that Westvaco only hires contractors who can safely perform the desired job tasks. Westvaco explains to the contract supervisors the hazards of the process on which they and their employees will work, Westvaco safe work practices, and Westvaco emergency response procedures. Westvaco requires that the contractor supervisors train each of their employees who will work at Westvaco before that worker begins work at the Westvaco site. Westvaco periodically reviews contractors' training documents and work performance to help ensure that safe practices are followed.
1.4.2 Chemical-specific Prevention Steps
In addition to the required prevention programs elements, Westvaco has implemented safety features specific to the hazardous
substances used at Westvaco. The following paragraphs describe some of these safety features.
Chlorine. Chlorine is supplied in DOT-approved 90-ton rail tank cars, 1-ton cylinders, and 150-lb cylinders. Chlorine is used for water treatment and for preparation of a bleaching chemical, Monox-L.
For water treatment, chlorine gas is fed through a short length of piping to an eductor, where it is absorbed into process water for use in the water treatment unit. The length of piping containing chlorine is kept to a minimum to reduce the likelihood of a release. If a release occurs downstream of the regulator at the cylinder, the regulator will close and only the quantity in the piping will be released. This quantity is small because of the short pipe in length and the vacuum conditions inside the piping. Chlorine detectors and alarms are provided in most areas containing chlorine.
For Monox-L preparations, liquid chlorine is vaporized to chlorine gas prior to reacting with other c
hemicals. Operators via remote TV cameras constantly monitor rail tank car unloading. Chlorine detectors and alarms provide an immediate warning of any release.
Chlorine Dioxide. Chlorine dioxide is produced at the Westvaco facility and stored as a dilute aqueous solution to avoid the necessity of transporting large quantities of the solution. Chlorine dioxide is produced in the chlorine dioxide generator and piped to an absorber column, where it is mixed with chilled water and a 1.2 wt% chlorine dioxide solution is generated. Storing this substance as a solution helps to reduce the consequences of a release.
1.5 Five-Year Accident History
Westvaco has completed a five-year accident history that has shown an improvement over the past year. The number of accidental releases declined from a peak of 18 in 1997 to 10 in 1998 and show continuous decline in 1999.
The most significant incident in the past five years was on May 22, 1997. Release was due to a broken electrical wir
e to a caustic makeup valve, which caused a loss of caustic to a scrubber resulting in a release of 7-9 pounds of chlorine. Incident resulted in 7 OSHA's and 1 first aid. An accident investigation team was assembled in accordance with the investigation protocol. The team recommended and implemented several improvements to eliminate the potential of this in the future.
Since 1994, there have been 7 OSHA's and 23 first aid cases involving both contractors and inland employees due to inhalation or skin contact with either chlorine or chlorine dioxide. The records for releases for the 5-year period prior to June 1999 show a total of 46. There is no record of offsite consequences in the past 5-years.
1.6 Emergency Response Programs
Westvaco has established a written emergency response program to help safely respond to accidental releases of hazardous substances. The emergency response plan includes procedures for:
? informing the local fire department and the public about accide
ntal releases that could reasonably result in
? providing proper first aid and emergency medical treatment to treat accidental human exposure to
hazardous substances at Westvaco
? controlling and containing accidental releases of hazardous substances, including the use of emergency
? inspecting and maintaining emergency response equipment
? reviewing and updating the emergency response plan
Westvaco maintains an emergency response team trained in these emergency response procedures. All Westvaco personnel are trained in evacuation procedures. Westvaco periodically conducts emergency response drills, including annual drills coordinated with the local fire department.
The written emergency response plan complies with other federal contingency plan regulations (e.g., the OSHA regulations 29 CFR 1910.38(a), 29CFR 1910.120(a)) and has been communicated to local emergency response officials through the local fire department. Westvaco
maintains a regular dialogue with the local emergency planning and response organizations.
1.7 Planned Changes to Improve Safety
Westvaco constantly strives to improve safety in all areas including covered processes. Improvements in incident investigations and employee involvement with processes such as our behavior process (Hero: Hazards Eliminated through Routine Observations) and continued aggression in our Standing Safety Committee. The PSM Program will continue to improve due to full time coordinator and continual evaluation by a team of diversified talent.
? Westvaco reviewed the chlorine handling system, increased the inspection frequency for chlorine equipment, added TV cameras and chlorine detectors for remote observations, and took steps to decrease the traffic near chlorine equipment - these changes reduce the likelihood of a chlorine release caused by degraded equipment or external impact
? The new chlorine dioxide generating facility that is pending startup is t
he driving force behind this update. This new chlorine dioxide generating facility has been designed and constructed with industry's best practices from safety, environmental, and operational perspectives. This new facility will enable the mill to minimize (and potentially eliminate) its dependence on elemental chlorine for other plant processes.