Georgia-Pacific West, Inc. - Executive Summary |
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Georgia-Pacific West, Inc. Risk Management Plan Executive Summary Georgia-Pacific West, Inc. (GP/Bellingham) is committed to operating in a manner that is safe for GP/Bellingham workers, the public, and the environment. As part of this commitment, the Company has established a system to help ensure safe operation of the hazardous chemical processes at this facility. One component of this system is a Risk Management Program (RMP) that helps manage the risks at the facility and addresses compliance with the requirements of the Environmental Protection Agency's (EPA's) Regulation 40 CFR 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 Georgia-Pacific in Bellingham. This document is intended to satisfy the RMPlan requirements of the RMP Rule and to provide the basis for public communication of the Risk Management Program for the facility. The Risk Management Program at the facility consists of four elements: 1. a hazard assessment to help understand (a) the potential off-site consequences of hypothetical accidental releases, and (b) the accidents that may have occurred during the last five years associated with the use of the substances regulated by the RMP Rule (chlorine, chlorine dioxide, and ethyl ether) - see topic 1.3; 2. a prevention program to help maintain and safely operate the processes containing more than the threshold quantity of the regulated substances (covered processes) - see topic 1.4; 3. an emergency response program to help respond to accidental releases of the regulated substances from the covered processes - see topic 1.6; and 4. a management system that delineates responsibility for implementing and maintaining the Risk Management Program. Information further describing these elements is provided in this RMPlan. Although the Risk Management Program at the facility helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety program at GP/Bellingham. In fact, the facility has a comprehensive safety program in place, establishing many levels of safeguards that are designed to minimize the potential for the release of any hazardous substance and injuries and damage resulting from the release of a hazardous substance. GP/Bellingham minimizes the potential releases of the hazardous substances used at the facility. When hazardous substances are used at the facility, 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 design, construction, and operation of the equipment. GP/Bellingham limits damage from a release, if such a release occurs. The facility trains workers to respond to upset conditions, reducing the consequences of a release if it occurs. In addition, the facility w ill be working with the Local Emergency Planning Commission (LEPC) to help ensure that injuries and/or environmental damage will not occur in the event that a release does occur. The safety program at GP/Bellingham 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 the facility that are required by the RMP Rule. 1.1 Accidental Release Prevention and Emergency Response Policies GP/Bellingham is committed to the safety of workers and the public, as well as the preservation of the environment through the prevention of accidental releases of hazardous substances. The facility implements reasonable controls to prevent foreseeable releases of the hazardous substances. These controls include training programs for personnel; programs to help ensure safety in the design, installation, operation, and maintenance of the processes; and programs to evaluate the hazards at the faci lity. In the event of an accidental release, the facility will control and contain the release in a manner that will be safe for workers and will help prevent injury to the public and/or the environment. GP/Bellingham provides response training for upset conditions to facility personnel, designates an emergency response coordinator to oversee response activities, and coordinates response efforts with the local emergency response organizations. The facility has established a management system directed by the General Manager Georgia-Pacific West, Inc. to effectively implement these policies. 1.2 Georgia-Pacific West, Inc. and Our Regulated Substances Georgia-Pacific West, Inc. is a pulp and paper facility primarily involved in the manufacture of paper products. Chlorine is currently the preferred bleaching agent at the facility. Chlorine is purchased from other sources and shipped on-site in rail cars as needed to support the pulp bleaching process. Chlorine is present in three p rocesses at the Bleach Plant. The Unloading/Vaporization process at the Bleach Plant is the only covered chlorine process under the RMP Rule. Ethyl Ether is also present in both a drum storage area and in the anhydrous column in the Alcohol Plant. The anhydrous column will be covered by the rule. Chlorine dioxide is present in the Bleach Plant. None of the chlorine dioxide processes require RMP coverage because they are below the threshold quantity or below the 1% by weight exclusion limit. However chlorine dioxide storage will be voluntarily covered by this RMP. EPA will classify the Chlorine Systems, the Chlorine Dioxide Storage and the Ethyl Ether process as Program Level 3 processes. 1.3 Off-site Consequence Analysis GP/Bellingham performed an off-site consequence analysis to estimate the potential for an accidental release of regulated substances to affect the public or the environment. The off-site consequence analysis consists of evaluating both the worst-case release scenarios and alternative release case scenarios. The facility does not expect a worst-case release scenario to ever occur. An alternative release scenario represents a release that (1) might occur at a facility like GP/Bellingham, and (2) would result in an off-site consequence if the release occurred. The alternative release scenarios will help the Local Emergency Planning Committee improve the community emergency response plan. 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 distances. 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, such as chlorine or chlorine dioxide, most people at the endpoint distance would be ab le 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. When considering the explosion of a flammable substance, such as ethyl ether, people within the endpoint distance are likely to be knocked down by the blast. Windows at the endpoint distance could shatter, and the potential for structural damage to buildings exists, although a building collapse is unlikely. Serious injury is possible from people being knocked down by the force of the blast, flying glass or falling objects. When considering the fire hazard of a flammable substance, people at the endpoint distance are likely to receive second-degree burns over the exposed parts of their bodies if they cannot find cover or otherwise escape the heat of the flame. The burns are likely to require hospitalization. The RMP Rule includes specific requirements for the worst-case and alternative release scenarios that must be re ported by Georgia-Pacific West, Inc. These requirements include: - one worst-case release scenario for all toxic substances in Program Level 3 processes (one scenario representing chlorine) - one alternative release scenario for each toxic substance in Program Level 3 processes (one scenario representing chlorine, one scenario representing chlorine dioxide) - one worst-case release scenario for the flammable substance in the Program Level 3 process (one scenario representing ethyl ether) - one alternative release scenario for the flammable substance in the Program Level 3 process (one scenario representing ethyl ether) The following information summarizes the off-site consequence analysis performed by Georgia-Pacific West, Inc. 1.3.1 Program Level 3 Processes - Chlorine (Cl2) System and Ethyl Ether Process The worst-case release scenario for a toxic, chlorine, is the rupture of a 90-ton capacity rail car cylinder. The RMP Rule mandates for the worst-case scenario involving a covere d substance normally a gas at ambient temperature and pressure, that the analysis assume loss of the entire contents of the largest storage vessel in ten minutes. The maximum distance to the toxic endpoint concentration, based on the EPA RMP*Comp Model approach, is 25 miles (the limit of the model). The United States Census indicates that approximately 201,915 people live within this distance. Several public receptors are also located within this distance (e.g., several industrial facilities, several public and private elementary schools and high schools, several nursing homes, several churches, several recreational parks, and numerous subdivisions). There are also several environmental receptors. The alternative release scenario for chlorine is the failure of an unloading transfer line where the cylinder is unloaded. Such a failure would allow chlorine gas to discharge from the valve at a restricted rate of 500 pounds per minute for 30 minutes before workers would detect and cap the valve. The maximum distance to the toxic endpoint concentration, based on the EPA RMP*Comp Model approach, is 1.0 mile. The United States Census indicates that approximately 4,668 people live within this distance. Several public receptors are also located within this distance (e.g., public elementary school, several industrial facilities, several recreational parks, and several subdivisions). There are also several environmental receptors. The alternative release scenario for chlorine dioxide is the failure of the discharge piping from the storage vessel. The transfer pump will feed the leak. Such a failure would allow chlorine dioxide solution to discharge from the pipe at a rate of 500 gallons per minute for 21.6 minutes, allowing the tank to drain. The solution will spill inside a building equipped with curbing and sewering that will contain the release and mitigate evaporation. The maximum distance to the toxic endpoint concentration, based on the EPA RMP*Comp Model approach, is 0.2 miles. There are no residences within this distance. Several public receptors are located within this distance (e.g., office buildings, restaurants, small businesses). There are also several environmental receptors. The worst-case release scenario for the ethyl ether process is the rupture of the column containing the solution. The RMP Rule mandates that for the worst-case scenario, the analysis assumes loss of the largest storage vessel in ten minutes. A 11,810-pound release of a solution would occur. The worst-case scenario is the vapor cloud explosion of 10 percent of the vapor released. The maximum distance to the toxic endpoint concentration, based on the EPA Look-up Table approach, is 0.17 mile (0.2 mile using RMP*Comp). There are no residences within this distance, but there are several businesses. There are also several environmental receptors. The alternative release scenario for ethyl ether process is the failure of the column with a resulting vapor cloud explosion , similar to the worst case scenario described in the section above, but employing a lower yield (3 percent). The maximum distance to the toxic endpoint concentration, based on the EPA RMP*Comp Model approach, is <0.1 mile. There are no off-site consequences from any alternative release scenarios. 1.4 Accidental Release Prevention Program Georgia-Pacific West, Inc. has always used a prevention program to help prevent accidental releases of hazardous substances. Beginning in 1992, the facility formalized this prevention program for the Chlorine Solution System to comply with the 14 elements of the Occupational Safety and Health Administration's (OSHA's) Process Safety Management (PSM) Prevention Program. In 1996, the EPA RMP Rule established that a Program Level 3 Prevention Program would become a requirement for these processes as well. The facility's Program Level 3 Prevention Program under the RMP Rule is essentially the same as the OSHA PSM Program, except that the program also focuses on protecting the public and the environment. 1.4.1 The following sections briefly describe the elements of the Georgia-Pacific West, Inc. Program Level 3 Prevention Program that addresses the EPA RMP Rule prevention program requirements for the Chlorine, Chlorine Dioxide and Ethyl Ether Systems. 1. Employee Participation. The facility has developed a written employee participation program for the covered processes to help ensure that the safety concerns of GP/Bellingham employees are addressed. The facility encourages active participation from personnel in the development and maintenance of 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 the development of Process Hazard Analysis and Operating Procedures. 2. Process Safety Information. The facility maintains a variety of technical documents that are used to help ensure the safe operation of the pr ocesses. The documents address (1) the hazards of the chemicals used in the process, (2) the technical data of the process, and (3) the design basis and configurations of the equipment used in the processes. The facility ensures that this process safety information is maintained, accurate, and available to all GP/Bellingham employees, and the LEPC. All of the information and documentation for the RMP Prevention Program is maintained at the facility. Material safety data sheets (MSDSs) document the physical and chemical properties of the hazardous substances handled at the facility, including non-regulated substances in a covered process. MSDS's for hazardous substances handled in each process are available in the control rooms so the operators have ready reference to this information. In addition, MSDS's are provided to the LEPC and/or Plant Emergency Response teams for use in helping formulate emergency response plans Many of the operating parameters are included in the technical in formation to help with the safe operation of the process. These documents are also used (1) to train employees, (2) to perform process hazard analysis, and (3) to help maintain the equipment to the design specification. 3. Process Hazard Analysis. GP/Bellingham 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 and a team leader with experience in performing process hazard analyses is assembled to analyze the process. The facility has primarily used the "What If'" technique, supplemented with checklists, to perform this analysis. The PHA team prepares a written report describing the results of the analysis, including recommendations. Responsibility for resolving the recommendations is assigned to personnel and, when appropriate, changes to enhance the sa fety of the process are implemented. PHAs are being re-validated using the "Hazard and Operability" (HAZOP) technique. 4. Operating Procedures. GP/Bellingham operators, supervisors, and engineers work together to develop and maintain accurate 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 during both normal operations and upset operating conditions. The operating procedures include: - Steps for safely conducting activities - Applicable process 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 The facility personnel develop and maintain operating procedures that cover all phases of the operations, inclu ding initial start-up, normal operation, normal shutdown, emergency shutdown, start-up following a standby condition, emergency shutdown, and temporary operations. The facility reviews and certifies the operating procedures annually. 5. Training. GP/Bellingham trains employees to safely and effectively perform their assigned tasks. The facility training program for process operators includes both the initial training and refresher training that covers (1) a general overview of the process, (2) the properties and hazards of the substance in the process, and (3) a detailed review of the process operating procedures and safe work practices. Written tests and oral reviews are used to verify that the employee understands the training materials before the employee can operate the process. The operators are consulted annually about the frequency of the training and the materials to be used for the training. Recommendations from the operators are reviewed and changes to the training are imp lemented as appropriate. 6. Contractors. GP/Bellingham has established a program to help ensure that contractor activities at the facility are performed in a safe manner. The program reviews the safety record of all contractors to help ensure that the facility only hires contractors who can safely perform the desired job tasks. GP/Bellingham explains to the contract supervisors the hazards of the process on which they and their employees will work, the facility safe work practices, and the emergency response procedures for the facility. The facility requires that the contractor supervisors train each of their employees who will work on or near a covered process before that employee begins work at the site. The facility periodically reviews contractors' training documents and work performance to ensure that safe practices are followed. 7. Pre-startup Safety Reviews. GP/Bellingham performs a safety review of new or modified equipment in the covered process before the process is place d 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 if management of change requirements have been completed if an existing process has been modified. A pre-startup safety review checklist is completed to document the review and to ensure that the appropriate issues have been addressed. 8. Mechanical Integrity. GP/Bellingham maintains the mechanical integrity of the covered process equipment to help prevent equipment failures that could endanger workers, the public, or the environment. The facility 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 ensure that new and replacement equipment meets the design standards required for service in GP/Bellingham covered processes. The facility mechanical integrity program also includes: - Specifications for inspection and testing of process equipment - Specifications for replacement parts and equipment - Standard maintenance procedures for inspecting, testing, and maintaining process equipment - Procedures for safe work practices, such as lockout/tag out, hot work, and confined space entry - Training of maintenance personnel - Documentation of maintenance activity 9. Hot Work Permit. GP/Bellingham has 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 facility. The facility 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 t o perform hot work are required to fill out the Hot Work Permit form. The supervisor reviews the completed form before work can be initiated. 10. Management of Change. The GP/Bellingham "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 replacements in kind are allowed without completing a "management of change" form. All other changes must be confirmed through the full "management of change" program to help ensure that inadvertent consequences of the process changes are prevented, safety consequences of the changes are addressed, affected process safety information and operating procedures are updated, and affected employees are notified of the changes. 11. Incident Investigations. GP/Bellingham investigates all incidents that could reasonably have resulted in a serious injury to p ersonnel, the public, or the environment so that similar accidents can be prevented. The facility trains employees to identify and report any incident requiring investigation. An incident investigation team is assembled, and the investigation is initiated within 48 hours of the incident. The results of the investigations are documented, recommendations are resolved, and appropriate process enhancements are implemented. 12. Compliance Audits. GP/Bellingham audits the covered processes to be certain that the facility's prevention program is effectively addressing the safety issues of the operations. The facility assembles an audit team that includes personnel knowledgeable in the RMP Rule and in the process, and this team evaluates whether the prevention program satisfies the requirements of the RMP Rule, and also whether the prevention program is sufficient to help ensure safe operations of the process. The results of the audit are documented, recommendations are resolved, and appropr iate enhancements to the prevention program are implemented. 1.5 Five - Year Accident History 1.5.1 Chlorine There have been no accidents in the past five years from the chlorine unloading/vaporization process that resulted in deaths, injuries, or significant property damage on-site, or known off-site deaths, injuries, evacuations, sheltering in place, property damages, or environmental damage. 1.5.2 Chlorine Dioxide There have been no accidents in the past five years from the chlorine dioxide process that resulted in deaths, injuries, or significant property damage on-site, or known off-site deaths, injuries, evacuations, sheltering in place, property damages, or environmental damage. 1.5.3 Ethyl Ether There have been no accidents in the past five years from the ethyl ether process that resulted in deaths, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. 1.6 Emer gency Response Programs Georgia-Pacific West, Inc. 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 response organizations and the public about accidental releases that could reasonably result in off-site consequences - Providing proper first aid and emergency medical treatment to treat accidental human exposure to hazardous substances at the facility - Controlling and containing accidental releases of hazardous substances, including the use of emergency response equipment - Inspecting and maintaining emergency response equipment - Reviewing and updating the Emergency Response Plan The facility maintains an Emergency Response Team trained in the emergency response procedures. All the facility personnel are trained in evacuation procedures. The facility periodically conducts emergency response drills, and will include an annual dril l coordinated with the local fire department. The written Emergency Response Plan complies with other federal contingency plan regulations and will be communicated to local emergency response officials through the Local Emergency Planning Committee. The facility will maintain a regular dialogue with the local emergency response organizations and will provide appropriate information to them. |