Willamette Industries, Inc., Port Wentworth Mill - Executive Summary
Executive Summary |
RMP Program for Willamette Industries, Inc.
Port Wentworth Pulp Mill, Port Wentworth, Ga
1.0 Facility Background
Willamette Industries, Inc. now owns and will operate a fully integrated bleached pulp mill with operations commencing in September, 2000. Willamette obtained ownership of the facility in May, 2000. Previously, Stone Container Corporation owned and operated the mill. In 1991, Stone installed a new bleached pulp line which included a Eka AVP chlorine dioxide plant. Chlorine dioxide is a key bleaching element. Prior to the effective date of RMP program developemnt (6-21-99), Stone Container Corportation shut down the Port Wentworth facility due to market conditions. This shutdown occurred in October of 1998, consequently, the chlorine dioxide facility's RMP program was never developed or registered. Chlorine dioxide is the only item which will be applicable to the RMP program.
The facility is located near Port Wentworth, Ga (Chatham County) or abou
t 5 miles upstream from Savannah, Ga on the Savannah River. The topography surrounding the mill is comprised of coastal plains and wetlands. The City of Port Wentworth surrounds the facility and has a population of about 5,000. However, within a 30 mile radius of the facility lies a metropolitin area including the City of Savannah and Hunter Army Airfield. Additionally, the surrounding area contains many and varied industries.
The only product manufactured at the Port Wentworth facility is bleached wood pulp.
2.0 Accidental Release Prevention and Emergency Response Policies
Willamette is committed to the safety of Willamette employees and the general public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. Willamette implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of an accidental release, Willamette controls and contains, to the extent possible, the release
in a manner that will be safe for employees and will help prevent injury to the public or damage to the environment. In addition, Willamette will investigate incidents soon after they occur to determine the root cause(s) for the incident and develop plans to ensure that the incident does not occur again.
3.0 RMP Applicability
Willamette Industries' Port Wentworth facility employs one process that contains chemicals to such a degree that the process is required to be "covered" under the RMP program, 40 cfr 68. The one covered process is a Eka SVP chlorine dioxide plant. The chlorine dioxide plant contains three storage tanks that contain 18,930 lb. of chlorine dioxide. The threshold quantity for chlorine dioxide is 1,000 lb. In this case, the boundary of the covered process has been developed conservatively so that the chlorine dioxide generation process is covered as well as just the storage tanks.
4.0 Overview of the Eka Chlorine Process and Off-site Consequence Analysis
1 Eka SVP Process
The Eka process produces chlorine dioxide in a closed recirculating reactor. In this case, sodium chlorate and sulfuric acid are added together in a closed dynamic reactor to produce chlorine dioxide gas. Methanol is also added to the reactor to serve as a catalyst. Chlorine dioxide gas is drawn off the top of the reactor and routed to a chilled water absorption column where the chilled water strips the chlorine dioxide out of the gas stream to form liquid chlorine dioxide, which is 0.012% ClO2 concentration. Chlorine dioxide is stored in three storage tanks with a combined capacity of 18,930 lb. The process was installed in 1991, shutdown in October, 1998 by a previous owner, and is slated for a August, 2000 start up. The Eka process is undergoing extensive pre-startup safety reviews prior to start up. Additionally, a Process Hazard Analysis (PHA) has been completed.
4.2.1 Worst Case Scenario Review
The worst case scenario would be the complete failure of
all three chlorine dioxide storage tanks releasing the full capacity of 18,930 lb. In this scenario, the liquid chlorine dioxide would vaporize and form a toxic gas cloud. This gas cloud would impact an area of up to 5.53 miles from the plant site. Within this boundary and depending upon wind direction, a gas cloud could impact the City of Port Wentworth, the Savannah International Airport, the City of Garden City, and the north end of the City of Savannah.
4.2.2 Alternate Release Scenario Review
The most probable alternate release scenario is the rupture of a 6" pipe, 280 feet long containing chlorine dioxide. In this case, the total contents of the pipe would be released. As with the worst case scenario, the liquid chlorine dioxide would pool on the ground then vaporize forming a gas cloud. A total of 41 lb. of chlorine dioxide would be released. This gas clould would impact an area up to 1.43 miles from the mill site. Only the City of Port Wentworth would be affected by
this type of release.
5.0 General Accidental Release Prevention Program
Willamette's Port Wentworth Mill takes a proactive view of preventing incidents related to releases of hazardous chemicals. We value OSHA's PSM program and EPA's RMP program on the same level and in many cases combine into one effort those overlapping prevention activities. The key elements of our prevention program include:
* Process Safety Information
* Process Hazard Analysis
* Standard Operating Procedures
* Training Programs
* Mechanical Integrity Programs
* Management of Change Procedures
* Pre-startup Safety Reviews
* Compliance Audits
* Incident Investigations
* Employee Participation
* Hot Work Permitting
* Management of Contractors within RMP systems
5.1 Process Safety Information
Process Safety Information consists of many different types of information related to hazardous chemicals and the processes that contain them. Types of information that are available to all employees and contractors in
clude MSDSs, chemical control information, PSM/RMP files, engineering files, process specific safety information, and Willamette's Engineering Standards.
5.2 Process Hazard Analysis (PHA)
Upon the purchase of the Port Wentworth facility by Willamette, a PHA was performed on the ClO2 covered process prior to any check out or start up activities. The PHA served to provide a list of recommended changes and fixes to the plant during the pre-startup safety review prior to start up. The Hazard and Operability (HazOp) technique was used to complete the PHA. Per the requirements of the RMP program, the PHA will be repeated or reviewed every five years.
5.3 Standard Operating Procedures
The mill is developing and implementing SOPs in every operating area, including the ClO2 covered process. SOPs include normal operating as well as start up and shutdown procedures. SOPs are developed using vendor supplied and recommended practices modified and applied to specific processes. Further, wh
ere procedures are deemed necessary, qualified personnel from that operating area develop applicable operating procedures. The SOP program is a dynamic program in that SOPs are continually reviewed and updated as part of the technician advancement program.
Port Wentworth employees involved with the operation and maintenance of the covered ClO2 process are trained periodically to ensure that their knowledge of the process and procedures is complete. This training includes training supplied by the vendor of the ClO2 technology, in this case Eka Nobel. Additionally, training and qualification is an essential element of a technicians advancement in Port Wentworth's pay and progression system. Last, all employees within the Fiberline area are trained annually on the covered process and the requirements of RMP.
5.5 Mechanical Integrity
The Port Wentworth Mill uses a computer based maintenance system, called Mapcon, to manage maintenance and mechanical integrity activitie
s. All response maintenance work orders as well as preventive maintenance inspection work orders are entered through MapCon. In addition, after the work order is completed, the results of the work, particularly for PM inspections, can be stored in the MapCon system. This allows for a good mechanical history for all equipment to be archived. In addition, the MapCon system is able to rate the priority of work requests by the priority rating which has been assigned to each process. By using this system, the PSM/RMP covered process receives the highest rating allowing prompt response to mechanical and maintenance issues as they arise. Last, the MapCon system is able to generate inspection work orders for the covered process based on frequency originally inputted into MapCon. This allows for vendor recommended routine inspections to take place on the prescribed frequency.
5.6 Management of Change (MOC)
The Port Wentworth Mill has implemented an MOC system for the ClO2 covered proce
ss such that any proposed change or modification to a covered process must first be reviewed for process safety considerations. A team comprised of operating, engineeirng, maintenance, and process control personnel meet periodically to review MOC requests. Changes to the process can only occur after the MOC team approves the request. All MOC requests are documented and filed in the RMP file system. In addition, any PSI or engineering documentation change required because of an approved MOC are noted on the MOC form for follow up.
5.7 Pre-startup Safety Reviews (PSSR)
PSSRs are conducted for any startup of projects that occur within the boundary of the covered process or after a major maintenance outage. In addition, a comprehensive PSSR was conducted prior to the initial startup of the covered ClO2 process after ownership was obtained by Willamette Industries. PSSR is conducted by operating, maintenance, engineering, and process controls personnel to ensure that all systems are
verified safe prior to start up. PSSR forms are used to facilitate the PSSR as well as document the PSSR. PSSR will verify that the physical system is as engineering drawings indicate, valving and physical controls are set according to SOPs, process controls are operating per design, and physical equipment are in a condition suitable for safe operation.
5.8 Compliance Audits
Even though Willamette Industries has recently obtained ownership of the facility, it is Willamette's intent to comply with the regulatory requirement to conduct third party audits every three years.
5.9 Incident Investigation
After each incident or near miss in a covered process, a formal incident investigation will occur. The incident investigation uses a team approach where a technical facilitator (trained in investigation or PHA facilitation) will facilitate a group of persons investigating the incident. The group will always include operating technicians and managers associated with the incident, pr
ocess controls personnel, process and project engineers, and maintenance personnel.
The investigation objective is to indentify incident root cause(s) as well as surface causes and to develop a list of recommendations designed to prevent recurrence. The list of recommendations is presented to mill management for reconciliation. In addition, the investigation and results are shared with each operating team in the affected business unit (training) with the meeting being documented.
5.10 Employee Participation
Active employee participation is essential to the success of the RMP program. Employee participation minimizes the consequences of releases of toxic, reactive, flammable, or explosive chemicals. Communication is encouraged between and among all levels of the organization. To promote and incorporate safety as a part of our business culture, at a minimum, monthly safety meetings are required for all mill employees. These safety meetings are documented for each employee. In ad
dition, employee participation is an essential element for all of the prevention items within RMP. For example, cross organization teams do PHAs and incident investigations, management and technician employees are actively involved with writing and reviewing SOPs, and all levels of the orgainzation are involved with MOC and mechanical integrity programs.
5.11 Hot Work Permits
The mill has in place a hot work permit system for all cutting and welding activities within the mill, including the ClO2 covered process. Hot work permit refresher training occurs on an annual basis for all mill and contractor personnel.
Contractors are an integral part of our business success. As such, contractors are included in all general mill safety training and safe practices as well as specific RMP safety training when working in or around the RMP process. All contractor safety training is documented.
6.0 Five Year Accidnt History
During the previous five years, the Port Wentwo
rth Mill has not experienced any incidents resulting in a significant release of chlorine dioxide.
7.0 Emergency Response Plan
The Port Wentworth Mill incorporates a compreshensive Emergency Response Plan (ERP) into its every day operations. The ERP contains 18 sections noted below:
* Introduction to Emergency Response Plan
* Overview of the ERP
* Employee Protection and Evacuation
* Medical Emergency Response
* Fire Response Guideline
* Chemical Release Response
* Severe Weather
* Utilities Outage
* Emergency Shutdown/Rapid Drain Procedure
* Mill Fatality
* Bomb Threat
* Flood Response
* Earthquake Response
* Radiological Response
* Telephone Numbers
* Protest/Demonstration Plan
* Emergency Response Forms
All mill employees and on-site contactors are required to attend annual refresher training on the mill's emergency response plan.
A key element of the mill's plan is the formation of first responders and incident commanders. Shift team leaders are identified as fi
rst responder and incident commanders for incidents that occur on the mill site. They will have the responsibility and authority to initiate first response as well as make all emergency calls. Tthe City of Port Wentworth, the City of Savannah, and the Chatham Emergency Management Association are available to aid in responding to chemical releases. These organizations are knowledgeable of the Port Wentworth Mill's RMP program.
Items and systems available in the mill to help with quick response to a chemical release or emergency include:
* Gaitronics inter- mill phone system and departemnt/mill radio system.
* Personal protective equipment requirements such that all persons working in the mill; contractor, vendor, or mill employee, are required to have a hard hat, eye protection, hearing protection, steel toed shoes, and an emergency escape personal respirator.
* Local audible and visual alarms.
* Process interlocks designed to minimize process upsets (active mitigation).
audible alarm system.
8.0 Planned Changes to Improve Safety
The Port Wentworth Mill stirves to improve safety performance by continual evaluation of mill process systems, and by motivation and managemnt of mill employee and contractor behaviors. The Port Wentworth Mill continues to emphasize safety performance through short term goals, safety promotions, and the reconciliation of unsafe behaviors or actions.