Georgia-Pacific Corporation, Palatka Operations - Executive Summary

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Risk Management Plan 
 
GP Palatka 
 
 
Revised 08/25/00 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Executive Summary 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Georgia-Pacific Palatka Operations 
Risk Management Plan 
 
 
1.    Executive Summary 
 
Georgia-Pacific Palatka Operations (GP/Palatka) is committed to operating in a manner that is safe for GP/Palatka 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 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 Georgia-Pacific  
in Palatka. This document is intended to satisfy the RMPlan requirements of the RMP Rule and to provide the public with a description of the Risk Management Program at the facility. 
 
The Risk Management Program at the facility consist of three elements: 
 
1. a hazard assessment to help understand (a) the potential off-site consequences of hypothetical accidental releases and (b) accidents that may have occurred during the last five years associated with the use of the substances regulated by the RMP Rule (chlorine dioxide and chlorine) - see topic 1.2 
 
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 
 
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/Palatka. 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 substances and injuries and damage resulting from the release of hazardous substances. 
 
GP/Palatka minimizes the potential releases of the hazardous substances used at the facility. When the 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/Palatka 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 works with the Local Emergency Planning Commission (LEPC) to help ensure that injuries and/or environmental damage will not occur in the event a release does occur. 
 
The safety program at GP/Palatka 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/Palatka 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 the 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 ha 
zards at the facility. 
 
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/Palatka 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. 
 
In order to effectively implement these policies, the facility has established a management system directed by the Vice President Pulp and Paper /Palatka Operations. 
 
 
1.2    Georgia-Pacific Palatka Operations and Regulated Substances 
 
Georgia-Pacific Palatka Operations is a pulp and paper mill primarily involved in the manufacture of brown/bleached pulp and paper products. As part of this manufacturing process, the facility produces and stores Chlorine Dioxide (C102) for the use of bleaching pulp. The facility stores and tr 
ansfers chlorine for use in bleaching pulp, in sufficient quantities to be covered by the RMP Rule. The Chlorine Dioxide Solution System, which includes the generation, storage and distribution of the chlorine dioxide, is considered an RMP-covered processes in Program Level 3. The Chlorine System, which includes the 90-ton railcar and distribution system for the Bleach Plant, is considered RMP-covered processes in Program Level 3.  The threshold quantity for Chlorine is approximately 90 tons during peak operations in each system.  The threshold quantity for Chlorine Dioxide is approximately 53,460 pounds (428,000 gallons at a 15 gram per liter (1.5% in solution) strength) during peak operations. 
 
 
1.3    Off-Site Consequence Analysis 
 
GP/Palatka performed an off-site consequence analysis to estimate the potential for an accidental release of the regulated substances to affect the public or the environment. The off-site consequence analysis consists of evaluating both the worst-case r 
elease 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/Palatka 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 dioxide or chlorine, most people at the endpoint distance woul 
d 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. 
 
 
 
The RMP Rule includes specific requirements for the worst-case and alternative release scenarios that must be reported by Georgia-Pacific Palatka Operations. These requirements include: 
 
* one worst-case release scenario for a toxic substance in Program Level 3 (one scenario representing chlorine) 
* one alternative release scenario for each toxic substance in Program Level 3 processes (one scenario representing chlorine and one scenario representing chlorine dioxide) 
 
 
The following information summarizes the off-site consequence analysis performed by Georgia-Pacific Palatka Operations. 
 
 
1.3.1 Program Level 3 Process - Chlorine (C12) System and the Chlorine Dioxide (C102) Solution System 
 
The worst-case release scenario for the chlorine system is the rupture of the 90-ton railcar. The railcar is  
connected to the chlorine feed system. The RMP Rule mandates that, for the worst-case scenario, the analysis assume loss of the largest storage vessel in ten minutes. The released chlorine would evaporate to form a vapor cloud. The maximum distance to the toxic endpoint concentration, based on the EPA Lookup Table approach, is greater than 25 miles. The United States Census indicates that approximately 127,596 people live within this distance from the  vessel;   several public receptors are also located within this distance (e.g., Putnam Community Hospital, St. Johns River Junior College, Putnam County Jail, Kay Larkin Airport, several industrial facilities, several public and private elementary schools and high schools, several nursing homes, several churches, several recreation parks, Palatka Shopping Mall, St. Johns River Water Management District, and numerous subdivisions). There are also several environmental receptors. 
 
The alternative release scenario for chlorine is the rupt 
ure of the chlorine unloading hose, releasing 208 pounds per minute for 10 minutes before it could be isolated. The released chlorine will evaporate to form a vapor cloud. The maximum distance to the toxic endpoint concentration, based on the EPA Lookup Table approach, is 2.0 miles. The United States Census indicates that approximately 3,725 people live within this distance from the ruptured line..  Several public receptors are also located within this distance (e.g., Putnam County Jail, St. Johns River Water Management District, Palatka Shopping Mall, Kay Larkin Airport, one public elementary school, several industrial facilities, several recreation parks, and several subdivisions). There are also several environmental receptors. 
 
The alternative release scenario for chlorine dioxide is the rupture of a chlorine dioxide solution line located at the discharge side of the C102 transfer pumps' header. During normal operations, the pump could pump approximately 880 gallons per minute fo 
r five minutes before the release might be recognized and isolated. The maximum distance to the toxic endpoint concentration, based on the EPA Lookup Table approach, is 3.0 miles. The United States Census indicates that approximately 7,500 people live within this distance from the discharge line at the chlorine dioxide solution transfer pumps.  Several public receptors are also located within this distance (e.g., Putnam County Jail, St. Johns River Water Management District, Palatka Shopping Mall, Kay Larkin Airport, several industrial facilities, several recreation parks, and several subdivisions). There are also several environmental receptors. 
.  
 
 
1.4 Accidental Release Prevention Program 
 
Georgia-Pacific Palatka Operations 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 Dioxide Solution System and the Chlorine System to comply with the 14 elem 
ents of the Occupational Safety and Health Administration'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 RMP also focuses on protecting the public and the environment. 
 
 
1.4.1 The following sections briefly describe the twelve elements of the Georgia-Pacific Palatka Operations Program Level 3 prevention program that addresses the EPA RMP rule prevention program requirements for the Chlorine Systems and Chlorine Dioxide Solution 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/Palatka employees are addressed. The facility encourages active participation from personnel in the developmen 
t 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 processes. The documents address (1) the hazards of the chemicals used in the process, (2) the technology 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/Palatka employees, and the Local Emergency Planning Committee (LEPC). All of the information and documentation for the RMP Prevention Program is maintained in the PSM/RMP Center at the facility. 
 
Material safety data sheets (MSDS) document the physical and chemical proper 
ties of the hazardous substances handled at the facility, including non-regulated substances in the 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 technology information to help with the safe operation of the process. These documents are also used (1) to train employees, (2) to perform process hazard analyses, and (3) to help maintain the equipment to the design specification. 
 
3. Process Hazard Analysis.  GP/Palatka 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 primarily uses the "Hazard and Operability" (HAZOP) and/or "What If'" techniques, 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 safety of the process are implemented. 
 
4. Operating Procedures. GP/Palatka 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, including initial start up, normal operations, normal shutdown, emergency shutdown, start up following a standby condition or emergency shutdown, and temporary operations. The facility reviews and certifies the operating procedures annually. 
 
5. Training. GP/Palatka 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 substances 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 implemented as appropriate. 
 
6. Contractors.  GP/Palatka 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/Palatka 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/Palatka performs a safety review of new or modified equipment in the covered 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 safety review checklist is completed to document the review and 
to ensure that the appropriate issues have been addressed. 
 
8. Mechanical Integrity.  GP/Palatka 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/Palatka 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 mainten 
ance personnel 
 
-    documentation of maintenance activity 
 
9. Hot Work Permits.  GP/Palatka 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 to perform hot work are required to fill out the Hot Work Permit form. The supervisor reviews the completed form before work can begin. 
 
10. Management of Change.  The GP/Palatka "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 a replacement 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/Palatka 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. 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/Palatka audits the covered processes to be certain that the facility's prevention program is effectively addre 
ssing 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 operation of the process. The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented. 
 
 
1.4.3    Chemical-specific Prevention Steps 
 
In addition to the required prevention program elements, GP/Palatka has implemented safety features specific to the Chlorine Dioxide Solution System. Chlorine Dioxide is produced at the facility and stored as a diluted 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 as high as 15 gram-per-liter (1.5% by weight) 
strength in solution is absorbed. 
 
GP/Palatka plans to reduce and/or replace chlorine in the bleaching process. Plans are complete for a new Chlorine Dioxide generator, as well as new Chlorine Dioxide storages to provide the capability to produce chlorine free bleached pulp and paper.  This new system will be go on line 09/05/00.    The elimination of the use of Chlorine will occur in the year 2001. 
 
 
 
 
1.5    Five-Year Accident History 
 
 
 
 
There have been no accidental releases that have met the reportable criteria. 
 
 
 
1.6    Emergency Response Programs 
 
Georgia-Pacific Palatka Operations 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 these emergency response procedures. All the facility personnel are trained in evacuation procedures. The facility periodically conducts emergency response drills, including 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 through the Local Emergency Planning Committee. The facility maintains a regular dialogue with the local emergency response organizations and provides appropriate information to them. 
 
 
 
 
2.    REGISTRATION 
 
Facility: 
Safety Management: 
 
 
 
 
 
Name 
Georgia-Pacific Palatka Operations 
Date of Last Inspection: 
 
Address 1 
P.O.Box 919 
 
 
Address 2 
County Road 216 
Inspection Performed By: 
 
City 
Palatka 
 
 
County 
Putnam 
OSHA 
10/19/93 
State 
Florida 
EPA 
06/15/99 
Zip Code 
32178 
State EPA 
06/15/99 
Latitude deg 
29 
Fire Department 
10/96 
Latitude min 
40 
Corporate 
02/05/99 
Latitude sec 
34 
 
 
Longitude deg 
81 
 
 
Longitude min 
40 
Covered By: 
 
Longitude sec 
45 
 
 
D&B No.  
 
OSHA PSM 
Yes 
EPA Identifier 
FLD004056248 
EPCRA Section 302 
Yes 
No. of Employees 
 
CAA Title V Operating Permit 
Yes 
 
 
 
 
 
 
Part 68 Implementation: 
 
Owner/Operator: 
 
 
 
 
Contact Name 
Bobby Holt 
Name 
David Spraley 
Title 
Maintenance Superintendent/RMP Coordinator 
Address 
Georgia-Pacific Palatka Operations 
 
 
 
County Road 216 
 
 
City 
Palatka 
Emergency Contact: 
State 
Florida 
 
Zip Code 
32178 
Name 
Myra Carpenter 
Telephone No. 
904-325-2661 
Title 
Superintendent Environmental Services 
 
 
 
Telephone No. 
904-329-0918 
 
 
24-Hour Telephone No. 
904-312-1520 
Parent Company: 
 
 
 
 
 
 
Name 
Georgia-Pacific Corporation 
 
 
D&B No. 
187711692 
 
 
 
 
 
 
 
Process:  Chlorine Dioxide Solution System 
 
Description 
Boundaries 
Comments 
 
Covered 
Exempt 
Operating 
Level 
Eligible 
PSM 
SIC 
Yes 
No 
Yes 
3 
3 
Yes 
2611 
The facility manufactures, stores, and distributes chlorine dioxide (CLO2).  The Bleach Plant utilizes the chlorine dioxide as a bleaching agent in the bleaching process for the pulp. 
The boundary for the ClO2 Solution System begins at the first isolation valve of the raw materials at the generator and continues through the generation process, storage, and distribution. 
The ClO2 generator process reduces chlorate with methanol in the presence of sulfuric acid to form chlorine dioxide gas.  The chlorine dioxide gas is absorbed with 40-48 degree chilled water to produce the liquid solution. 
 
 
 
 
 
 
 
Substances 
CAS No. 
Covered 
Quantity ( 
lb) 
Exempt 
In ERP 
Comment 
 
 
Chlorine Dioxide 
10049-04-4 
Yes 
53,460 
No 
Yes 
The ClO2 is stored in two large storage tanks that are interconnected to the process. 
 
 
 
Process:  Chlorine Systems 
 
Description 
Boundaries 
Comments 
 
Covered 
Exempt 
Operating 
Level 
Eligible 
PSM 
SIC 
Yes 
No 
Yes 
3 
3 
Yes 
2611 
The facility stores and distributes chlorine.  The Bleach Plant utilizes the chlorine as a bleaching agent in the bleaching process for the pulp. 
 
The boundary for the Chlorine System  at the Bleach Plant begins at the 90-ton railcar and continues to the point of injection at the Bleach Plants.  
The chlorine car is padded with nitrogen which forces the chlorine to pass through vaporizers and then injected into the pulp at the Bleach Plant.   
 
 
 
 
 
 
 
Substances 
CAS No. 
Covered 
Quantity (lb) 
Exempt 
In ERP 
Comment 
 
 
 
Chlorine (Bleach Plant) 
 
7782-50-5 
 
Yes 
 
180,000 
 
No 
 
Yes 
There is a total facility maximum inventory of 3,960,000 lb 
s. (22  separate 90 ton railcars)  There is one railcar in use at the process. 
 
Process 
Program  
Level 
Eligible  
Level 
Accident  
History 
W-C  
Scenario 
Response  
Coordination 
PSM  
Covered 
SIC  
Targeted 
Chlorine Dioxide Solution System 
3 
3 
 
No 
Yes 
Yes 
Yes 
 
 
 
 
 
 
 
 
Chlorine System (Bleach Plant) 
3 
3 
 
Yes 
Yes 
Yes 
Yes 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3.    OFF SITE CONSEQUENCE ANALYSIS 
 
 
 
Substances Released: 
Substance 
CAS No. 
Hazard 
 
Chlorine  
7782-50-5 
Toxic 
 
 
 
 
 
Scenario: 
 
 
 
Name 
Rupture of the Chlorine Railcar 
 
 
Event Type 
Toxic Release 
 
 
Scenario Type 
Worst Case Scenario 
 
 
Methodology 
EPA OCA 
 
 
Topography  
Rural 
 
 
Selected 
Yes 
 
 
 
 
 
 
Release: 
 
Meteorology: 
 
Quantity 
180,000.0 lbs. 
Wind Speed 
1.5 m/s 
Rate 
18,000 lbs./min. 
Temperature 
25.0 (C 
Duration 
10.0 min. 
Stability Class 
F 
Physical State 
Gas 
Relative Humidity 
50.0 % 
Distance to Endpoint 
> 25 miles 
 
 
Distance to Closest Publ 
ic Receptor 
0.7 miles 
 
 
 
Scenario Description 
Basis for Assumptions 
Meteorology Justification 
EPA OCA Summary 
The Bleach Plant has a 90-ton railcar being utilized in the process. The worst case scenario would assume the loss of the entire storage vessel in ten minutes.  
 
 
Distance to endpoint: >25 miles (.132000 feet) 
 
Toxic endpoint: 0.0087 mg/l  (3.0 ppm) 
 
Dense plume lookup table used. 
 
Release rate to atmosphere: 18000 lb/min 
 
Substances Released: 
Substance 
CAS No. 
Mass Fraction 
 
Chlorine dioxide [Chlorine oxide (ClO2)] 
10049-04-4 
0.010 
 
Water 
 
0.990 
 
Scenario: 
 
Mixture: 
 
Name 
Rupture of the ClO2 Transfer Pump Discharge Line 
Name 
ClO2-15.0 gpl 
Event Type 
Toxic Release 
Hazard 
Toxic 
Scenario Type 
Alternative Scenario 
Hazard of Interest 
Chlorine dioxide 
Methodology 
EPA OCA 
 
 
Topography  
Rural 
 
 
Selected 
Yes 
 
 
 
 
 
 
Release: 
 
Meteorology: 
 
Quantity 
550 lbs.  
Wind Speed 
3.0 m/s 
Rate 
110 lbs./min. 
Temperature 
25.0  
(C 
Duration 
5  min. 
Stability Class 
F 
Physical State 
Liquid 
Relative Humidity 
50.0 % 
Distance to Endpoint 
3.0 miles 
 
 
Distance to Closest Public Receptor 
.7 miles 
 
 
 
Scenario Description 
Basis for Assumptions 
Meteorology Justification 
EPA OCA Summary 
This alternative case scenario is the rupture of the discharge line from the CLO2 transfer pump.   
The basis for this assumption is that the CLO2 would be released at 59 degrees F..  Isolation would occur in less than 5 minutes.  Quantity is based on pump curve calculations of 880 gpm of CLO2 solution @ a rate of 110 lbs/min. of pure CLO2. Vapor pressure is based on 15 gpl at 59 degrees F.. 
 
Distance to endpoint: 3.0 miles 
 
Toxic endpoint: 0.0028 mg/l  (1.0 ppm) 
 
Dense plume lookup table used. 
 
Mixture density: 62.4 lb/cubic ft. 
 
Pool evaporation rate: 110 lb/min 
 
Release rate to atmosphere: 110 lb/min 
 
 
 
Substances Released: 
Substance 
CAS No. 
Hazard 
 
Chlorine  
7782-50-5 
Toxic 
 
 
 
 
 
Scenar 
io: 
 
 
 
Name 
Rupture of 1" Chlorine Unloading Hose 
 
 
Event Type 
Toxic Release 
 
 
Scenario Type 
Alternative Release Scenario 
 
 
Methodology 
EPA OCA 
 
 
Topography  
Rural 
 
 
Selected 
Yes 
 
 
 
 
 
 
Release: 
 
Meteorology: 
 
Quantity 
2,080.0 lbs. 
Wind Speed 
1.5 m/s 
Rate 
208.0 lbs./min. 
Temperature 
25.0 (C 
Duration 
10.0 min. 
Stability Class 
F 
Physical State 
Gas 
Relative Humidity 
50.0 % 
Distance to Endpoint 
2.0 
 
 
Distance to Closest Public Receptor 
0.7 miles 
 
 
 
Scenario Description 
Basis for Assumptions 
Meteorology Justification 
EPA OCA Summary 
The alternate case scenario would be to assume that the 1" chlorine unloading hose would rupture allowing the liquid chlorine to escape.  
Calculations are based on the temperature of the Chlorine railcar at 100 degrees F., the pressure at 145 psi.  Release would be 208 lbs. per minute.  Isolation could be accomplished in less than 10 minutes. 
 
Distance to endpoint: 2.0 miles (10800 feet) 
 
Toxic 
endpoint: 0.0087 mg/l  (3.0 ppm) 
 
Dense plume lookup table used. 
 
Release rate to atmosphere: 208 lb/min 
 
4.    PROGRAM LEVEL 3 PREVENTION PROGRAM 
 
Prevention Program Data Elements 
 
Bleach Plant Chlorine Systems 
 
SIC code:    2611 
 
Substances 
CAS No. 
Chlorine  
7782-50-5 
 
The date that safety information was last reviewed:    Dec. 1999 
 
 
PHA 
 
The completion date of the most recent PHA or update:     Jan 11, 1999  
PHA Technique Used: 
   What-If    No 
   Checklist    No 
   What-If Checklist    Yes 
   HAZOP    No 
   Fault Tree Analysis    No 
   FMEA    No 
   Other 
 
The expected completion date of any changes resulting from the PHA:    Jan. 04, 2000 
 
 
Major Hazards Identified: 
   Toxic release    Yes 
   Fire    Yes 
   Explosion    Yes 
   Runaway reaction    No 
   Polymerization    No 
   Overpressurization    Yes 
   Corrosion    Yes 
   Overfilling    Yes 
   Contamination    Yes 
   Equipment failure    Yes 
   Loss of utilities (cooling, air, etc.)    Yes 
   Earthquake    No 
   Floods (floodplain)    Yes 
   Tornado    No 
   Hurricanes    Yes 
 
Prevention Progr 
am Data Elements 
 
 
Process Controls in Use: 
   Vents    No 
   Relief valves    Yes 
   Check valves    Yes 
   Scrubbers    Yes 
   Flares    No 
   Manual shutoffs    Yes 
   Automatic shutoffs    Yes 
   Interlocks    Yes 
   Alarms and procedures    Yes 
   Keyed bypass    Yes 
   Emergency air supply    Yes 
   Emergency power    No 
   Backup pump    No 
   Grounding equipment    Yes 
   Inihibitor addition    No 
   Rupture disks    Yes 
   Excess flow device    No 
   Quench System    No 
   Purge System    Yes 
 
 
Mitigation System in Use: 
   Sprinkler system    No 
   Dikes    No 
   Fire walls    No 
   Blast walls    No 
   Deluge system    No 
   Water curtain    No 
   Enclosure    No 
   Neutralization    Yes 
 
 
Monitoring/Detection System in Use: 
   Process area detectors    Yes 
   Perimeter monitors    Yes 
   Cameras for unloading station    Yes 
 
Prevention Program Data Elements 
 
Chlorine Dioxide Solution System 
 
SIC code:    2611 
 
Substances 
CAS No. 
Chlorine dioxide 
10049-04-4 
 
The date that safety information was last reviewed:    Aug. 01,  2000 
 
PHA 
 
The completion date of the most recent PH 
A or update:     Aug. 11, 2000 
PHA Technique Used: 
   What-If    No 
   Checklist    No 
   What-If Checklist    Yes 
   HAZOP    Yes 
   Fault Tree Analysis    No 
   FMEA    No 
   Other 
 
The expected completion date of any changes resulting from the PHA:    Oct. 10, 2000 
 
 
Major Hazards Identified: 
   Toxic release    Yes 
   Fire    Yes 
   Explosion    Yes 
   Runaway reaction    Yes 
   Polymerization    No 
   Overpressurization    Yes 
   Corrosion    Yes 
   Overfilling    Yes 
   Contamination    Yes 
   Equipment failure    Yes 
   Loss of utilities (cooling, air, etc.)    Yes 
   Earthquake    No 
   Floods (floodplain)    Yes 
   Tornado    No 
   Hurricanes    Yes 
 
Prevention Program Data Elements 
 
 
Process Controls in Use: 
   Vents    Yes 
   Relief Devices    Yes 
   Check valves    Yes 
   Scrubbers    Yes 
   Flares    No 
   Manual shutoffs    Yes 
   Automatic shutoffs    Yes 
   Interlocks    Yes 
   Alarms and procedures    Yes 
   Keyed bypass    Yes 
   Emergency air supply    Yes 
   Emergency power    No 
   Backup pump    Yes 
   Grounding equipment    Yes 
   Inihibitor addition    No 
   Rupture disks    No 
   Excess flow device    No 
 
   Quench System    Yes 
   Purge System    Yes 
 
 
Mitigation System in Use: 
   Sprinkler system    Yes 
   Dikes    Yes 
   Fire walls    No 
   Blast walls    No 
   Deluge system    Yes 
   Water curtain    No 
   Enclosure    No 
   Neutralization    No 
 
 
Monitoring/Detection System in Use: 
   Process area detectors    Yes 
   Perimeter monitors    Yes 
 
Prevention Program 
 
1.0 INTRODUCTION 
 
At Georgia-Pacific Palatka Operations, the facility takes a systematic, proactive approach to preventing accidental releases of hazardous chemicals.  The management systems address each of the key features of successful accident prevention programs including: 
 
(    Process safety information (PSI) 
(    Process hazard analysis (PHA) 
(    Operating procedures (OP) 
(    Training (Trg) 
(    Mechanical integrity (MI) 
(    Management of change (MOC) 
(    Pre-startup review (PSSR) 
(    Compliance audits (CA) 
(    Incident investigation (II) 
(    Employee participation (EP) 
(    Hot work permits (HW) 
(    Contractors (Contr) 
 
These individual elements of the accident pr 
evention program work together to prevent accidental chemical releases.  The company and employees are committed to the standard that these management systems set for in the way the facility does business, and have specific accountabilities and controls to ensure that the facility is meeting their own high standards for accident prevention. 
 
2.0 PROCESS SAFETY INFORMATION 
 
In accordance with 40 CFR Part of the RMP Rule, the facility systematically controls the creation, updating, and retention of written documentation associated with the process chemicals, process technology, and process equipment. This information is essential for supporting all of the other elements of the Risk Management Program. The facility also use this information directly to ensure that the equipment is suitable for its intended use. 
 
2.1 Process Safety Information Details 
 
The facility maintains the following chemical process information for each regulated substance in a covered process as well as for  
other hazardous materials in both covered and non covered processes: 
 
* Toxicity information 
* Permissible exposure limits 
* Physical data 
* Reactivity data 
* Corrosivity data 
* Thermal and chemical stability data 
* Hazardous effects of inadvertent mixing of different materials that could foreseeably occur 
 
The facility uses material safety data sheets (MSDSs) to provide most of the process chemical information.  Whenever required information, such as corrosivity data or hazardous effects of inadvertent mixing, is not available in MSDSs, the facility develops the missing data from other sources and provide it in separate documents. 
 
The facility maintains the following required process technology information: 
 
* Block flow or simplified process flow diagram 
* Process chemistry 
* Maximum intended inventory 
* Safe upper and lower limits for parameters such as temperature, pressure, flow, or composition 
* Evaluation of the consequences of deviations from established oper 
ating limits 
 
Most of this information comes from the engineering design documents for the processes, but in some cases, the facility has developed such information through special projects. Additionally, operating limits, maximum intended inventories, and consequences of deviations, not available from engineering design documentation, were developed as part of PHAs. 
 
The facility also maintains the following information pertaining to equipment in the regulated processes (as well as for many of the non-regulated processes): 
 
* Materials of construction 
* Piping and instrument diagrams (P&IDs) 
* Electrical classification 
* Relief system design and design basis 
* Ventilation system design 
* Design codes and standards employed 
* Material and energy balances for processes built after 5/26/92 
* Safety systems (interlocks, detection, or suppression systems) 
 
Again, most of this information comes from the engineering design documents for the processes, as well as from the facil 
ity's own maintenance files. Whenever required information was not available, the facility obtained the information from equipment vendors and plant engineering. In conjunction with the equipment information collection efforts, the facility documented that the equipment complies with recognized and generally accepted good engineering practices. 
 
 
3.0 PROCESS HAZARD ANALYSIS 
 
In accordance with 40 CFR Part 68.67 of the RMP Rule, the facility uses process hazard analyses (PHAs) to systematically identify, evaluate, and control process hazards. The most important products of the PHA are recommendations for reducing the most significant risks of accidental chemical releases. The facility ensures that all recommendations from the PHAs are resolved appropriately, and the facility ensures that information from the PHAs (including recommended resolutions) is communicated to all potentially affected employees. 
 
3.l    Process Hazard Analysis Details 
 
The facility conducts systematic PHAs  
of the regulated processes and other hazardous processes at the facility according to an established schedule. This schedule ensures that the facility, (1) addresses each process in a prioritized order (based on the extent of process hazards, the number of potentially affected employees and/or off site population, the age of the process, and the operating history of the process) and (2) updates/revalidates each PHA at least every five years (or more often if necessary because of process changes). The facility also conducts PHAs of all new processes before those processes are placed in service. 
 
The facility primarily uses the "What-If' and "HAZOP" techniques to perform PHAs, although the facility can use other EPA/OSHA-approved techniques when they are more appropriate for specific applications. 
 
The facility PHA teams are composed of personnel with engineering and process operating experience, including at least one person who has knowledge and experience in the process to be eval 
uated and a PHA team leader trained in the application of the hazard evaluation technique used for the PHA. 
 
The facility has a system in place to promptly resolve PHA team findings and recommendations, and communicate findings/recommended resolutions to potentially affected personnel. 
 
PHAs are implemented in a written report for each analysis soon after the analysis meetings are completed. The managers review and resolve the PHA recommendations after receiving the report. The facility maintains a written action plan tracking the resolution status of each recommendation, including the assignment of an individual responsible for resolving each recommendation and a target completion date. The facility documents the final resolution of each recommendation, and advises the PHA team of any recommendations that are rejected. 
 
4.0 OPERATING PROCEDURES 
 
In accordance with 40 CFR Part 68.69 of the RMP Rule, the facility uses operating procedures to define how process-related job tasks  
assigned to personnel should be performed to avoid incidents. The facility uses these procedures to (1) train employees before they perform tasks in the field, (2) serve as reference guides for personnel performing tasks, and (3) specify what to do if a process upset or operating emergency occurs. 
 
4.1    Operating Procedures Details 
 
The facility's engineers, operators, and shift supervisors work together to develop and maintain operating procedures for all phases of operations including: 
 
* Initial start-up 
* Normal operations 
* Temporary operations 
* Emergency shutdown, including the conditions under which emergency shutdown is required and assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner 
* Emergency operations 
* Normal shutdown 
* Start-up following a turnaround or an emergency shutdown 
 
The facility development teams use PSI information from process designers/equipment manufacturers, an 
d their own experience to create and validate the procedures. 
 
The procedures address the following information: 
 
* Steps for safely conducting activities 
* Safe operating limits 
* Consequences of process deviations, as well as steps required to correct or avoid such deviations 
* Safety and health considerations including, (1) properties of, and hazards presented by, the chemicals used in the process, (2) precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment, (3) control measures to be taken if physical contact or airborne exposure occurs, (4) quality control for raw materials and control of regulated substance inventory levels, and (5) any special or unique hazards 
* Safety systems and their functions 
 
In addition to the process-specific procedures, the facility also develops and maintains more widely applicable safe work practices addressing issues such as lockout/tag out, confined space entry,  
opening process equipment or piping, and control over entry to processes. These safe work practices apply to employees and contractors. 
 
The facility has a formal review process to approve procedures and changes to procedures. Furthermore, the facility annually reviews existing procedures, make any needed revisions, and certify the procedures as current and accurate. The facility keeps procedures in locations that are readily accessible to employees who may need access to the information. 
 
5.0 TRAINING 
 
In accordance with 40 CFR Part 68.71 of the RMP Rule, the facility trains employees to safely perform their assigned tasks. The training program includes initial training as well as periodic refresher training and training updates when major process/equipment changes are made. As part of the training, the facility includes provisions for ensuring that employees understand the training (written tests, field demonstrations, etc.). 
 
 
5.1 Training Details 
 
The facility provides t 
he operators with initial and refresher training, which includes a general overview of the process, properties of chemicals in the process, and safety and health hazards, as well as a detailed understanding of the process operating procedures and safe work practices. The facility provides initial training to new operators before they are allowed to work independently as operators. 
 
Periodically, at least every three years, the facility provides the operators with refresher training that, depending on job classification, can include operating procedure training, equipment-specific training, and/or advanced (beyond HAZCOM) chemical-specific training. The refresher training courses emphasize process overview information, safe work practices, operating procedures that are rarely used such as emergency shutdown, emergency operation and start-up following an emergency shutdown, and any operating issues requested by the shift group. The operators are consulted annually with a written questi 
onnaire on the frequency of refresher training, and their input is documented and considered when preparing training schedules. 
 
All training is certified by some form of evaluation to verify that the training has been understood. The facility uses a combination of physical demonstration of skills, oral reviews using a one-on-one format, and written tests. The facility reviews the information missed by an employee who does not pass all testing requirements, and does not allow resumption of work until minimum testing requirements are met. 
 
Alt training is documented and includes the employee's name, date of training, and the means used to verify that the employee understood the training. 
 
 
6.0 MECHANICAL INTEGRITY 
 
In accordance with 40 CFR Part 68.73 of the RMP Rule, the facility maintains the mechanical integrity of the process equipment using an inspection and testing program and a quality assurance program, and ensures that the equipment is designed and installed correctly  
so that it operates properly. The facility trains maintenance personnel in the hazards of the process, and also provides additional training on procedures for maintaining the ongoing integrity of the process equipment so that job tasks are performed safely. 
 
6.1 Mechanical Integrity Details 
 
The facility considers all process-related equipment and safety systems that are critical for preventing and/or mitigating releases of regulated substances to be covered by the MI program. Examples include: 
 
* Pressure vessels and storage tanks 
* Piping systems including valves 
* Relief and vent systems and devices 
* Emergency shutdown systems 
* Controls such as monitoring devices, sensors, alarms, and interlocks pumps 
 
The MI program uses preventive maintenance activities to identify equipment that is deteriorating and needs repair or replacement before failure occurs. This program also specifies the repairs (or parts replacement) needed to return deteriorated equipment to acceptable s 
pecifications. The facility maintains written procedures that support the MI program as follows: 
 
* Standard maintenance procedures describe the methods that mechanics use to perform repairs, replacements, and installations. 
 
* Procedures for safe work practices and safety policies specify safe practices for performing maintenance tasks such as lockout/tag out, hot work, confined space entry, line or equipment opening, and control over entry for a covered process by plant and/or contract maintenance personnel. 
 
* The inspection, test, and preventive maintenance procedures describe the methods used by mechanics to perform inspections, tests, and preventive maintenance tasks on process equipment. These procedures follow generally accepted good engineering practices. The equipment inspection and test frequency is based on mean time to failure estimates provided by the manufacturer, adjusted by the facility's own experience. 
 
The facility documents all inspection, test, and prevent 
ive maintenance activities including: 
 
* Date of inspection, test, or preventive maintenance 
* Person performing the activity 
* Equipment identifier 
* Description of the activity performed 
* Results of the activity (including any deficiencies noted) 
 
The facility identifies equipment deficiencies through the inspection, test, and preventive maintenance activities or from routine operating and maintenance tasks and corrects them promptly. If the facility cannot immediately correct identified equipment deficiencies, the facility implements protective measures to ensure safe operation until repairs can be made. 
 
The facility has a quality assurance program that addresses new facilities, equipment, maintenance materials, and spare parts. The program seeks to verify proper fabrication of new equipment, proper installation of new or repaired/replaced equipment, and use of suitable maintenance materials and spare parts in the preventive maintenance and repair tasks. 
 
The facility  
has a comprehensive training program covering all MI issues. The program uses the procedures described previously. For example, all mechanics, maintenance supervisors, and maintenance engineers are trained on hazards for all RMP-covered processes and on safe work practices. The maintenance personnel also receive training on safe maintenance procedures, preventive maintenance practices, and special skills requiring craft certification. All training, as described above, occurs before employees perform tasks in RMP-covered areas independently. 
 
7.0 MANAGEMENT OF CHANGE 
 
In accordance with 40 CFR Part 68.75 of the RMP Rule, the facility evaluates and approves all proposed changes (i.e., modifications that are not replacements in kind) to covered process chemicals, technology, equipment, and procedures prior to implementation through the management of change program. This program helps ensure that inadvertent or unintended changes are prevented, that any safety and health impacts are ad 
dressed, that affected procedures are updated, and that employees and contract employees are informed of, and trained in, the approved changes. The facility uses this close scrutiny of all changes to help ensure that changes do not adversely impact employees, public safety, or the environment. 
 
7.1 Management of Change Details 
 
The facility analyzes each proposed change and confirms that: 
 
* The technical basis for the change is appropriate 
* The safety and health impacts of the change are understood and appropriate controls are in place 
* The procedures are modified as appropriate for the change 
* The permissible time period is established for temporary changes.   
* The change is authorized by appropriate personnel 
 
The MOC procedure contains a step-by-step description of the confirmation process. It defines and provides examples of changes and replacements-in-kind.  Also, it describes in detail the requirement for each confirmation step based on the type of change being c 
onsidered.  The facility uses a Management of Change form to document each step in the confirmation process. Changes that pass the confirmation criteria are communicated to the employees who are affected by the change before the change is implemented.  When approved changes require updates to the process safety information and/or operating procedures, the facility revises these documents and trains employees on these changes before operations resume. All training is documented as formal operator training. 
 
 
8.0 PRE-STARTUP REVIEW 
 
In accordance with 40 CFR Part 68.77 of the RMP Rule, the facility performs pre-startup safety reviews as a final check to ensure the safety of a new or modified process before it is placed in service. 
 
 
8.1 Pre-Startup Review Details 
 
The facility performs pre-startup reviews on new stationary sources and on modified stationary sources when the modification is significant enough to require a change in the process safety information. The pre-startup 
review is completed before regulated substances are brought into the process and only after the facility has confirmed that: 
 
* Construction and equipment are in accordance with design specifications 
* Safety, maintenance, operating, and emergency procedures are in place and are adequate 
* PHAs have been performed on new stationary sources and all recommendations have been resolved 
* MOC requirements have been satisfied for modified processes 
* Training has been completed (and documented) for affected employees 
 
The facility uses a Pre-Startup Safety Review Checklist as an aid in documenting the performance of the pre-startup reviews. The checklist contains a list of safety questions covering process considerations that must be addressed prior to start-up. The person responsible for the project prepares the Pre-Startup Safety Review Checklist and Approval Form and provides the names of the reviewer responsible for confirmation of each of the pre-startup review safety questions 
. Each reviewer signs off on the checklist and approval form when satisfied that all assigned safety questions are complete and no problems exist. All reviewers must sign off on the Pre-Startup Safety Review Checklist and Approval Form before start up can be authorized. 
 
9.0 COMPLIANCE AUDITS 
 
In accordance with 40 CFR Part 68.79 of the RMP Rule, the facility audits the RMP-covered processes to be certain that the prevention programs are effective. The compliance audit program seeks to confirm that RMP prevention program practices for the covered process are consistent with written programs, that the programs adequately address all requirements of the RMP regulations, and that management systems are in place to ensure continued compliance. 
 
 
 
 
9.1  Compliance Audit Details 
 
The facility conducts and certifies compliance audits of the prevention program for RMP-covered processes at least every three years. The facility integrates these audits into PSM audits. The audit teams  
consists of a team leader and an appropriate number of team members based on the size and complexity of the processes to be audited. The audit team collectively possesses the following skills and knowledge: 
 
* Ability to understand the prevention program requirements of the RMP Regulation (49 CFR Part 68) 
* Capability to conduct interviews and collect audit data 
* Capability to document audit results 
* Knowledge of the process to be audited 
 
The audit team members receive training in RMP regulatory requirements, interview techniques, and methods for data collection before participating in an audit. They use a protocol or a check sheet that contains a series of questions that systematically address each requirement of the RMP Regulation. The team leader assigns each auditor specific RMP elements to cover in the audit. Information obtained through field observations, interviews, and document reviews is documented, and deficiencies or noncompliances are identified. At the conclusio 
n of the audit, the audit team prepares a report that identifies any specific noncompliance issues that need to be addressed. 
 
The facility promptly reviews the audit findings, determines an appropriate response for each finding, assigns responsibility for implementation of a corrective action, and assigns a target completion date. The corrective actions are placed in a tracking system and progress is monitored quarterly until open issues are resolved. The facility retains the two most recent audit reports. 
 
10.0 INCIDENT INVESTIGATION 
 
In accordance with 40 CFR Part 68.81 of the RMP Rule, the facility performs incident investigations to help ensure that incidents with catastrophic magnitude or potential are thoroughly investigated, root causes are identified and corrected, and relevant findings are communicated throughout the organization to help prevent a recurrence. 
 
 
10.1 Incident Investigation Details 
 
The facility investigates all incidents (including near misses) that 
result in, or could reasonably have resulted in, a large uncontrolled release of a regulated substance, serious injuries to employees or the public, and/or damage to the environment. The facility trains employees to identify occurrences requiring investigation and to notify the appropriate person should such an event occur. If the incident meets RMP-classification criteria, the facility initiates an investigation within 48 hours. The facility assembles an investigation team consisting of: 
 
* At least one person knowledgeable in the process or activity involved 
* A contract employee if the incident or near miss incident involved the work of a contractor or had acute, adverse health effects on contract employees 
* Others with appropriate knowledge and skills to thoroughly investigate and analyze the event 
 
The facility trains investigation team leaders in investigation techniques, including root cause analysis. The investigation team follows a written investigation protocol that a 
ddresses the key steps of fact finding, determination of cause, and development of recommendations/actions to be taken. From the raw data collected, the incident investigation team prepares the text for an incident summary report, which contains: 
 
* Date and time of the event 
* Date and time the investigation started 
* Description of the event 
* Identification of contributing factors 
* Recommendations from the investigation 
 
The facility resolves the report recommendations and develops action plans that are tracked to completion. The facility reviews the incident investigation report and action plan items with employees (and contract employees, as appropriate) who work in the affected area and/or perform job tasks relevant to the investigation findings. The facility accomplishes this review by discussing the event at the next safety meeting or in shift meetings. The facility retains incident reports for at least five years. 
 
11.0 EMPLOYEE PARTICIPATION 
 
In accordance with 4 
0 CFR Part  68.83 of the RMP Rule, the employee participation plan helps ensure that all employees have appropriate involvement in developing and implementing the RMP Rule. 
 
 
11.1 Employee Participation Details 
 
The facility has a written employee participation program that meets RMP Requirements.  In this document, the facility describes in detail the many different ways that employees participate in each element of the RMP Regulations.  The facility periodically updates this document as changes occur. 
 
The facility consults with employees and their representatives on ways to improve participation in implementation of the RMP Rule. 
 
 
 
12.0 HOT WORK PERMITS 
 
In accordance with 40 CFR Part 68.85 of the RMP Rule, the facility uses a hot work permit program to ensure that OSHA's fire prevention and protection precautions, specified in 29 CFR Part 1910.252(a), are in place before hot work (work involving electric or gas welding, cutting, brazing, or similar flame or spark-prod 
ucing operation) begins on or near an RMP-covered process. 
 
 
12.1    Hot Work Permit Details 
 
The facility studied OSHA's fire prevention and protection regulation, 29 CFR Part 1910.252(a), and developed a procedure that addresses these requirements. The facility also created a Hot Work Permit Form to document job requirements, the dates for the hot work, and the object on which the work is to be performed. New employees are trained on the hot work permit procedure as part of the safe work practices orientation. The Manager of Maintenance audits completed Hot Work Permit Forms to ensure that any errors in preparation or approval are identified and brought to the attention of those involved to prevent recurrence. 
 
13.0 CONTRACTORS 
 
In accordance with 40 CFR Part 68.87 of the RMP Rule, the facility has a contractor screening procedure to help ensure that the facility hires and uses only contractors who accomplish the desired job tasks without compromising the safety and health of p 
lant employees, the public, or the environment. 
 
 
13.1    Contractor Details 
 
The facility has a detailed contractor safety program that applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to an RMP-covered process. This program does not apply to contractors providing incidental services that do not influence process safety. 
 
The facility selects contractors based on prior site work history and on information that they are required to provide as part of the bid process. The bid information includes their current safety programs (i.e., safety organization, employee education and training, and accident prevention program) and their prior safety performance (i.e., OSHA injury rates, property loss experience, regulatory compliance history, and worker's compensation insurance experience). Bidders that do not provide all of the requested information, that do not have the desired skills, or that have an unsatisfactory saf 
ety record are dropped from further consideration. Contractors that meet the minimum safety requirements are then judged to determine which one can provide a quality job at the lowest cost. If a contractor currently working in the plant is under consideration, the facility reviews recent safety audits and contacts plant personnel on the job site to verify satisfactory job performance before the facility authorizes the purchase order. 
 
The facility provides a safety orientation for Contractor Supervisors before they begin work on- site. The facility requires these Contractor Supervisors to provide this same safety orientation to their employees who will work in the facility.  The facility uses the orientation meeting to familiarize contractors with the type of operations and associated hazards in the areas in which they will be working. The facility provides copies of the Contractor Safety Manual, which contains plant safety rules/policies, safe work practices, a material hazards summ 
ary, and an outline of emergency actions for contractors. The facility provides MSDSs for the hazardous materials that may affect the contractor work area, copies of plant safe work practices and policies, and emergency response actions associated with the contractor's work. The facility then takes the Contractor Supervisors on a tour of the job site to point out the hazards discussed in the meeting, introduce personnel with whom they will communicate, and show where medical attention may be provided. 
 
The facility requires contractors to perform the following tasks to help ensure process safety: 
 
* Train each of their employees in the work practices necessary to safely perform the contracted work 
* Provide each of their employees with the same safety orientation that the facility provided for contract Supervisors 
* Train each of their employees on the plant's safe work practices 
* Document that each of their employees has received and understands the training  
* Ensure that ea 
ch of their employees follows the plant safety rules and safe work practices 
* Report to the facility's staff any hazards created or found by their employees at the job site 
* Provide access and responses to the facility's personnel who may appear at the job site to evaluate contractor safety performance 
* Provide information on contract employee job site injuries/illnesses to the facility's designated representative 
 
5.    EMERGENCY RESPONSE PROGRAM 
 
Emergency Response Data Elements 
 
Do you have a written emergency response plan? 
Yes 
Does the plan include specific actions to be taken in response to an accidental release of a regulated substance? 
Yes 
Does the plan include procedures for informing the public and local agencies responsible for responding to accidental releases? 
Yes 
Does the plan include information on emergency health care? 
Yes 
The date of the most recent review or update of the emergency response plan: 
06/15/99 
The date of the most recent emergency respo 
nse training for employees: 
Annual 
 
Local Agency with which the Plan is Coordinated: 
Agency:    Local Emergency Planning Committee/County Emergency Response     Organizations     
Phone Number:    904-329-0129 
 
 
Subject To: 
   OSHA 1910.38    Yes 
   OSHA 1910.120    Yes 
   Clean Water Act/SPCC    Yes 
   RCRA    Yes 
   OPA-90    No 
   State EPCRA Rules/Law    Yes 
 
Emergency Response Program 
 
1.0 INTRODUCTION 
 
In accordance with 40 CFR Parts 68.90 and 68.95 of the RMP Rule, Georgia-Pacific Palatka Operations maintains an integrated contingency plan (ICP), which consolidates all of the various federal regulatory requirements for emergency response planning. The ICP provides the essential planning for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, the facility coordinates the plan with applicable community emergency response plans and local responders. 
 
2.0 EMERGENCY RESPONSE PLAN ELEMENTS 
 
Georgia-Pacific Palatka Operation's Emergency Response Plan  
was developed using the Comprehensive Emergency Response Plan Guidance and addresses all of the elements of a comprehensive, integrated plan, including: 
 
( Plan introduction 
- Purpose and scope 
- Table of contents 
- Current revision date 
- General facility identification information 
( Core plan elements 
- Discovery 
- Initial response 
- Sustained actions 
- Termination and follow-up actions 
( Annexes 
- Facility and locality information 
- Notifications 
- Response management system 
- Incident documentation 
- Training and exercises/drills 
- Response critique, plan reviews, and modification process 
- Prevention 
- Regulatory compliance and cross-reference matrixes 
 
The facility has designed a strategy for implementing these elements to work together to provide effective planning for, and control of, emergency response actions. 
 
 
 
 
 
 
2.1 Plan Introduction 
 
The Plan begins with a brief overview of facility operations and describes the physical area and nature of h 
azards/events to which the plan is applicable. This overview helps Plan users quickly assess the relevance of the Plan to particular types of emergencies in specific locations. The facility maintains a list of applicable emergency response regulations to be certain that the facility meets the regulatory obligations. The facility also maintains a brief profile of the facility and its key personnel to facilitate rapid identification of key administrative information that may be needed during an emergency. 
 
 
2.2 Core Plan 
 
The core of the Plan focuses on the range of emergency response actions from discovery of an incident through termination and follow-up actions at the end of emergency response. 
 
 
2.2.1 Discovery 
 
The facility emphasizes recognition, basic assessment, and initial reporting/notification of incidents by employees in the Plan. The facility's goal is to ensure that all employees effectively identify and report incidents for further response action under the Plan. 
 
 
 
2.2.2 Initial Response 
 
The facility Plan outlines detailed procedures and protocols for initial responses to reported incidents that vary according to incident types. Specific initial response issues that the facility will address are included in the Plan: 
 
* Internal/external notifications 
* Response management systems 
* Preliminary assessment of the situation 
* Objectives and priorities for response to specific incidents (such as tactical planning, mitigation actions, and resources required for response) 
* Implementation of a tactical plan 
* Mobilization of resources 
 
 
2.2.3 Sustained Actions 
 
The facility Plan addresses the transition from initial response tasks to sustained response actions where more prolonged mitigation and recovery are in progress under a response management structure. 
 
2.2.4 Termination and Follow-Up 
 
Finally, the Plan addresses how and when a response action ends (and potentially other regulatory requirements begin). The Plan also outli 
nes demobilization of response resources (including decontamination), as well as follow-up activities such as incident investigation, response critique, Plan review, and follow-up reports. 
 
 
2.3 Annexes 
 
The facility uses annexes to the plan to provide key supporting information for conducting emergency response under the Core Plan, as well as to document compliance with regulatory requirements. These annexes (1) augment the Plan with information too detailed for direct inclusion in the Plan and (2) highlight linkages with other internal/external response plans. 
 
2.3.1 Facility and Locality Information 
 
This annex provides detailed information for responders about the layout of the facility and the surrounding environment through the following: 
 
* Facility maps 
* Facility drawings 
* Facility description/layout, including identification of facility hazards, vulnerable resources, and populations on and off the facility that may be impacted by an incident 
 
 
2.3.2 Notificat 
ions 
 
This annex details the process of making people aware of an incident, including: 
 
* Internal notifications 
* Community notifications 
* Federal and state agency notifications 
 
 
2.3.3 Response Management System 
 
This annex contains a general description of the facility's response management system, as well as specific information necessary to guide or support the actions of each response management function. The facility addresses all response management functions in this annex, including: 
 
* Command 
* Operations 
* Planning 
* Logistics 
 
The annex focuses on roles and responsibilities, as well as the location of supporting lists, records, and other documentation. 
 
 
2.3.4 Incident Documentation 
 
This annex contains the facility's procedures for performing incident investigations. The annex also identifies where the facility's incident history is kept. 
 
2.3.5 Training and Exercises/Drills 
 
This annex contains a description of the emergency response training  
and exercise program used at the facility. The annex also identifies where training records are kept. 
 
2.3.6 Response Critique, Plan Review, and Modification Process 
 
This annex outlines the procedures for updating the Plan based on critiques of incidents/exercises (lessons learned) and formal reviews of the Plan. This annex includes procedures for critiquing an actual or simulated response. This annex is part of the continuous improvement philosophy at the facility. 
 
2.3.7 Prevention 
 
This annex briefly outlines the facility's management systems and implementation efforts for preventing incidents. This annex provides references to further details on the prevention efforts. 
 
 
2.3.8 Regulatory Compliance and Cross-Reference Matrixes 
 
This annex documents how the elements of the Emergency Response Program satisfy applicable emergency response requirements. 
 
3.0 COORDINATION 
 
The facility coordinates the Emergency Response Plan with the Local Emergency Planning Committee  
and other emergency response officials, providing all of the information they request for inclusion in community emergency response plans. 
 
 
6.    CERTIFICATlON 
 
 
 
General Certification. To the best of my knowledge, information, and belief formed after reasonable inquiry, the information submitted in this RMPlan is true, accurate, and complete. 
 
Signature      Title:      Date:     
 
 
Management System 
 
1.0 OVERALL RESPONSIBILITY 
 
The Georgia-Pacific Palatka Pulp and Paper Operations Vice President has the overall responsibility for ensuring that the facility operates in a safe and reliable manner. This responsibility includes overseeing the implementation of the elements of the Risk Management Program. To ensure that the Risk Management Program is appropriately developed and implemented, the (Plant Manager) has the responsibility for the development, implementation, and integration of the EPA RMP elements and the elements of OSHA's PSM program as required under 40 CFR Part 68.15 of 
the RMP Rule. 
 
The PSM/RMP Coordinator serves as the chairman of the facility's PSM/RMP Committee. This committee comprises members with responsibilities for developing and managing specific elements of the Risk Management and Process Safety Management Programs. The members of this committee are assigned by the PSM/RMP Sponsor based on recommendations from the Fiberline PSM/RMP Coordinator. 
 
The following sections identify the specific responsibilities for each aspect of the Risk Management and Process Safety Management Programs. 
 
2.0 HAZARD ASSESSMENTS 
 
The Superintendent of Environmental Services, in coordination with the Manager of Maintenance, has the responsibility for (1) ensuring that off-site consequence analysis for each regulated process are consistently performed and documented in accordance with 40 CFR Parts 68.20 through 68.39 and (2) selecting the scenarios that will be reported in the facility RMPlan as required under 40 CFR Part 68.165. The Superintendent of En 
vironmental Services, in coordination with the PSM/RMP Coordinator and the Manager of Safety, is also responsible for ensuring that the accident history for each covered process is appropriately documented and maintained in accordance with 40 CFR Parts 68.42 and 68.168 of the RMP Rule. 
 
3.0 PREVENTION PROGRAMS 
 
The Plant Manager has the responsibility for ensuring that the facility has an integrated, effective, and compliant prevention program that meets 40 CFR parts 68.65 through 68.87 of the RMP Rule and OSHA PSM requirements. 
 
 
3.1 Process Safety Information 
 
The responsibility for process safety information  (40 CFR Part 68.65 of the RMP Rule) is divided into three areas. The Manager of Safety has responsibility for process chemical information, the PSM/RMP Coordinator has responsibility for process technology information, and the Manager of Maintenance has responsibility for equipment information. The PSM/RMP Coordinator has the responsibility of ensuring that all of this 
information is readily accessible for use. 
 
 
3.2 Process Hazard Analysis 
 
In accordance with 40 CFR Part 68.67 of the RMP Rule, the PSM/RMP Coordinator has the responsibility for ensuring that process hazard analyses (PHAs) are scheduled, conducted, and documented by trained personnel for all regulated processes. The PSM/RMP Coordinator identifies candidate PHA team leaders from within the facility and ensures that they receive appropriate training before leading PHAs.  Other members of the PSM/RMP Committee are responsible for (1) ensuring that the information and personnel necessary to conduct PHAs are available according to the PHA implementation schedule and (2) resolving recommendations that are assigned to their respective areas. 
 
 
3.3 Operating Procedures 
 
In accordance with 40 CFR Part 68.69 of the RMP Rule, the PSM/RMP Coordinator has the responsibility for ensuring that complete and accurate operating procedures are in place for all regulated processes. The Manager 
of Safety develops and maintains the facility's safe work practices. 
 
 
3.4 Training 
 
In accordance with 40 CFR Part 68.71 of the RMP Rule, the PSM/RMP Coordinator has the responsibility for (1) ensuring that operations employees receive and understand training applicable to their specific jobs and the associated processes and (2) documenting the training. The Manager of Safety has the responsibility for (1) ensuring that all facility employees receive and understand training in safe work practices applicable to their jobs and (2) documenting the training.  The Manager of Maintenance addresses training for maintenance workers under the mechanical integrity program. 
 
 
3.5 Mechanical Integrity 
 
In accordance with 40 CFR Part 68.73 of the RMP Rule, the Manager of Maintenance has the responsibility for the overall mechanical integrity program, with specific emphasis on written procedures, maintenance training, the equipment and instrumentation inspection/test program and document 
ation, and equipment deficiency resolution. The Manager of Engineering and the Manager of Purchasing, work with the Manager of Maintenance to define and maintain appropriate quality assurance procedures for all types of equipment acquisitions/installations/repairs. 
 
3.6 Management of Change 
 
In accordance with 40 CFR Part 68.75 of the RMP Rule, the Manager of Maintenance has the responsibility for the overall management of change program in the regulated processes. 
 
 
3.7 Pre-Startup Review 
 
In accordance with 40 CFR Part 68.77 of the RMP Rule, the PSM/RMP Coordinator has the responsibility for the overall pre-startup safety review program for the regulated processes, which is closely related to the Management of Change Program. 
 
 
3.8 Compliance Audits 
 
In accordance with 40 CFR Part 68.79 of the RMP Rule, the Manager of Maintenance has the responsibility for ensuring that compliance audits regularly occur (and are documented) to verify that the prevention program is worki 
ng and meets EPA/OSHA requirements. 
 
 
3.9 Incident Investigation 
 
In accordance with 40 CFR Part 68.81 of the RMP Rule, the Manager of Safety has the responsibility for designing the incident investigation program. The PSM/RMP Coordinator is responsible for tracking resolution of investigation findings and recommendations. The Manager of Maintenance also has the responsibility of ensuring that only trained personnel lead the investigations. The Manager of Maintenance has the responsibility for ensuring that all incidents in his/her areas are reported and investigated, and the investigation findings are resolved, documented, and communicated to affected personnel. 
 
 
3.10 Employee Participation 
 
In accordance with 40 CFR Part 68.83 of the RMP Rule, the Manager of Human Resources, working with the employee representative on the PSM/RMP Committee, has the responsibility of involving employees in the planning and implementation of the facility's prevention program elements. 
 
 
3 
.11 Hot Work Permits 
 
In accordance with 40 CFR Part 68.85 of the RMP Rule, the Manager of Safety, working closely with the Fire Chief and Manager of Maintenance, has the responsibility of developing and maintaining the facility's hot work permit program. 
 
3.12 Contractors 
 
In accordance with 40 CFR Part 68.87 of the RMP Rule, the Manager of Engineering has the overall responsibility for the contractor program; however, the Manager of Safety is responsible for ensuring that the requirements of the safety program are implemented. 
 
4.0 EMERGENCY RESPONSE PROGRAM 
 
In accordance with 40 CFR Parts 68.90 and 68.95 of the RMP Rule, the Superintendent of Environmental Services and Incident Commander are responsible for (1) designing, implementing, and maintaining the facility's Emergency Response Plan, (2) ensuring that all associated training is conducted and documented as necessary, and (3) responding to local emergency planners/responders when questions arise. 
 
5.0 RMPlan PREPAR 
ATION AND SUBMISSION 
 
The PSM/RMP Coordinator is responsible for preparing the RMPlan for the facility. After review and approval by the Vice President Pulp and Paper/Manager Palatka Operations, the Superintendent of Environmental Services will submit the RMPlan as required under 40 CFR Parts 68.150 through 68.185 of the RMP Rule. 
 
6.0 RMPlan COMMUNICATION 
 
The Communications Manager, in coordination with the Manager of Maintenance, has the responsibility of providing RMPlan information (other than the required EPA submission) to employees and the public as required under 40 CFR Part 68.210 of the RMP Rule. The RMPlan documentation will be maintained in the PSM/RMP Center. 
 
 
 
 
 
 
 
Facility Report 
 
Program Level Report
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