Boise Cascade Corporation - Executive Summary

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Policy Statement 
The Jackson Mill is committed to the safety of workers and the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances.  Boise Cascade 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, operation, and maintenance of processes at Boise Cascade; and programs to evaluate the hazards at Boise Cascade. 
In the event of an accidental release, Boise Cascade controls and contains the release in a manner that will be safe for workers and will help prevent injury to the public or the environment.  Boise Cascade provides response training to Boise Cascade personnel, designates an emergency response coordinator to oversee response activities, and coordinates response efforts with the local fire department, police department, and hospital.  Response activities have a 
lso been discussed with the Clarke County Emergency Management Agency. 
In order to effectively implement these policies, Boise Cascade has established a management system headed by the RMP Manager to oversee risk management-related activities. 
Facility Information and Regulated Substances 
The Jackson Mill is an integrated bleached kraft pulp and paper mill located in Jackson, Alabama.  The mill produces approximately 800 tons per day of bleached kraft pulp.  The mill currently operates one paper machine with capacity of 475 tons per day and a second paper machine with a capacity of 1,400 tons per day.  The facility stores chlorine dioxide solution (containing approximately 1 percent by weight chlorine dioxide) in two tanks of capacity 112,000 gallons each.  Assuming a specific gravity of 1.0, chlorine dioxide contained in each full tank is 9,341 pounds.  Chlorine dioxide solution is used as a bleaching agent in the pulping process. 
A Hazard Assessment was conducted as an initial scree 
ning procedure to determine the Program Level (1, 2, or 3) that applies to the chlorine dioxide process.  The mill currently stores chlorine dioxide in a quantity that exceeds the threshold amount listed in the RMP rule.   
Because the chlorine dioxide process is covered by OSHA's Process Safety Management (PSM) rule and because nearby residents (public receptors) lie within the toxic endpoint concentration of the mill's worst-case release, the chlorine dioxide process is subject to Program 3 requirements of the RMP.  
Worst-case and Alternative Release Scenarios 
The worst case scenario is the rupture of a chlorine dioxide solution storage tank and subsequent release of 9,341 pounds (112,000 gallons) of chlorine dioxide over a 33 minute duration, or 4.71 lb/sec. The released liquid solution is assumed to quickly volatilize and begin to disperse as a vapor cloud.  The release rate of 4.71 lb/sec is modeled with DEGADIS 2.1 using the worst case weather conditions prescribed by the RMP Ru 
le.  The estimated maximum distance to the toxic endpoint concentration (1 ppm) is 9.5 miles, beyond which there will be enough dispersion that the hazard to the public will no longer exist.  The total population within the toxic endpoint circle is estimated to be 5,700 persons based on 1990 Census Data.  The worst-case release scenario would affect two environmental receptors, the Upper Stimpson Wildlife Sanctuary and the Stimpson State Game Sanctuary. 
The chlorine dioxide alternative release scenario is the rupture of a 4-inch diameter transfer line leading from the storage tank to the bleach plant.  The 1 percent chlorine dioxide solution is pumped through the line via a 500 gpm pump. Because of the high vapor pressure of chlorine dioxide in the solution and the turbulent action of the spill, the entire chlorine dioxide in the solution is assumed to volatilize as soon as the spill occurs.  With a 500 gpm solution spill rate the chlorine dioxide emission rate is 41.7 lb/min.  The re 
lease duration is assumed to be 30 minutes during which time the pump is shut off.  Under realistic weather conditions of 3.0 m/s wind speed and a wind stability class of "D," the DEGADIS 2.1 estimated distance to the toxic endpoint concentration (1 ppm) is 1.4 miles.  The total population within the alternative release toxic endpoint circle is estimated to be 2,400 persons based on 1990 Census Data.  The alternative release scenario affects no environmental receptors. 
Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
The Boise Cascade accident prevention program for the chlorine dioxide process consists of the following 13 elements. 
1.  RMP Management System 
A management system consisting of a Risk Management Program Team was established to assign responsibility for the development, implementation, and maintenance of the Risk Management Program.  The team is comprised of Hazard Assessment Coordinator, Prevention Program Coordinator, Emergency Response Coor 
dinator and Communications Coordinator.  The Jackson Mill Environmental Manager serves as the RMP Manager and has the overall responsibility to oversee and implement the Risk Management Program. 
2.  Process / Chemical Safety Information 
Comprehensive chemical data has been assembled to include regulatory reporting and action thresholds, health hazard and chemical exposure limitations, as well as detailed physical properties of chlorine dioxide. This information was compiled from numerous sources, and is intended to be a one-stop source for the reader seeking data on chlorine dioxide.  
Process safety information was meticulously compiled on the chlorine  dioxide process. Hard-to-find specifications are located in one place for easy reference. Details such as Maximum Intended Inventory, Safe Upper and Lower Temperatures, Safe Upper and Lower Pressures, and codes and standards used to design, build and operate the processes are on file at the mill.  
3.  Process Hazard Analysis 
A hazard  
review was conducted for the chlorine dioxide process. The review team included plant management, process operating and maintenance experts, process design engineers, and Boise Cascade employees knowledgeable in the Hazard Review process itself. The Hazard Review technique used was a Hazard and Operability Study (HAZOP), supplemented by completion of design checklists. 
4.  Operating Procedures 
Standard operating procedures have been developed, and stringently reviewed by Jackson Mill employees. They provide system descriptions, specifications, and operating procedures for the chlorine dioxide system. Procedures include Startup, Shutdown, Normal, Abnormal, and Emergency Operations. Also included are Maintenance and Troubleshooting Procedures. 
5.  Operator Training Program  
Boise Cascade trains employees to safely and effectively perform their assigned tasks.  The Jackson Mill training program for the chlorine dioxide process includes both initial and refresher training that covers:  

A general overview of the process,  
2 The properties and hazards of the substances in the process, and  
3 A detailed review of the process operating procedures and safe work practices.   
Oral reviews and written tests are used to verify that an employee understands the training material before the employee can work in the process. 
6.  Mechanical Integrity Program 
The Jackson Mill maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public, or the environment.  The mechanical integrity program includes an inspection and testing program to help identify equipment deterioration and damage before the equipment fails.  The Boise Cascade mechanical integrity program includes: 
? Specifications for 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/tagou 
t, hot work, confined space entry, and line or equipment opening 
? Training of maintenance personnel 
? Documentation of maintenance activities 
7.  Management of Change 
The Boise Cascade management of change program evaluates and approves all proposed changes to chemicals, equipment, and procedures for the chlorine dioxide process to help ensure that changes do not negatively affect safe operations.  Process 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 procedure.  All other changes must be confirmed through the full management of change procedure to help ensure that inadvertent consequences of process changes are prevented, safety consequences of changes are addressed, and affected employees are notified of the changes. 
8.  Pre-startup Review 
Boise Cascade performs a safety review of a new or modified process before the process is placed into service to help ensure t 
hat the process has been prepared to operate safely.  A pre-startup review checklist is completed to document the review and to ensure that appropriate issues have been addressed. 
9.  Internal Compliance Audits 
Internal compliance audits are conducted every three years to verify compliance with the programs and procedures contained in the Accident Prevention Program. Boise Cascade assembles an audit team that includes personnel knowledgeable of the RMP rule and of the chlorine dioxide process, and this team evaluates whether the prevention program satisfies the requirements of 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. 
10.  Incident Investigation 
The Jackson Mill investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the e 
nvironment so that similar accidents can be prevented.  Boise Cascade 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. 
11.  Employee Participation 
Boise Cascade has developed a written employee participation program for the chlorine dioxide process to help ensure that the safety concerns of Boise Cascade workers are addressed.  The Jackson Mill encourages active participation of personnel in the prevention program activities at the facility.  Employees are consulted on and informed about all aspects of the chlorine dioxide accident prevention program, including Process Hazard Analyses and operating procedures. 
12.  Hot Work Permits 
Boise Cascade has established a hot work permit program to control spark or flame producin 
g activities that could result in fires or explosions at the facility.  Personnel who are to perform hot work are required to fill out the Hot Work Permit Form.  The Shift Supervisor reviews the completed form before work can begin.  Training in the use of the Hot Work Permit Form is included in the Jackson Mill safe work practices orientation. 
13.  Contractors 
Boise Cascade has established a program to help ensure that contractor activities at the mill are performed in a safe manner.  The Jackson Mill provides training to contractor supervisors on the hazards of the process on which they and their employees will work, and also informs the contractor supervisors of safe work practices and emergency response procedures.  The Jackson Mill requires that the contractor supervisors train each of their employees who will work in the mill before that worker begins work on site.  The Jackson Mill periodically reviews contractors' training documents and work performance to help ensure that saf 
e work practices are followed. 
Five-Year Accident History 
The Jackson Mill's five-year accident history includes one release of chlorine dioxide solution that occurred on August 14, 1997.   The release occurred while an employee was installing a patch on a leaking valve weephole.  A small amount of solution dripped down his arm inside his protective clothing.  The employee did not follow the proper procedures for reporting the incident to the mill medical department.  Six days after the exposure, the employee received medical treatment for chemical burns from the local hospital.  Had the employee followed mill procedures and reported the exposure at the time of the release, the exposure would not have resulted in chemical burns and the incident could have been resolved by simple first aid treatment at the mill.  As a result of the accident, the Jackson Mill reviewed the proper procedures for reporting an incident with the affected employee. 
This release did not result in any property  
damage onsite, and there were no offsite impacts from the release.  Boise Cascade is proud of the safety record of its employees at the Jackson Mill and provides many incentives for employees to maintain the high safety standards set at the mill.   The Jackson Mill has set a goal to have no reportable incidents within its five-year accident history in the future. 
Emergency Response Program 
Boise Cascade 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 accidental releases that could reasonably result in offsite consequences 
? Providing proper first aid and emergency medical treatment to treat accidental human exposure to hazardous substances at the Jackson Mill 
? Controlling and containing accidental releases of hazardous substances, including the use of emergency response equipment 
? Inspecting and m 
aintaining emergency response equipment 
? Reviewing and updating the emergency response plan 
Boise Cascade maintains an emergency response team trained in these emergency response procedures.  All Boise Cascade personnel are trained in evacuation procedures.  The Jackson Mill 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 and has been communicated to local emergency response officials and to the local fire department.  The City of Jackson fire chief, Neal Bradley, is also the fire chief for the Jackson Mill. 
Planned Changes to Improve Safety 
Boise Cascade strives to improve the safety of the processes at the Jackson Mill through both the incident investigation program and a program soliciting safety suggestions from the employees.  The following change to improve process safety is planned: 
? Provide a spare tail gas exhaust fan with an  
independent power supply for the chlorine dioxide plant scrubber to ensure that chlorine dioxide fumes do not get trapped in the plant as a result of a mill power failure.
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