Donohue Industries Sheldon Mill - Executive Summary
Donohue is committed to operating in a manner that is safe for Donohue employees, for the public, and for the environment. As part of this commitment, Donohue has established a system to help ensure safe operation of the processes at this facility. One component of this system is a risk management program (RMP) that helps minimize the risks at Donohue and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the rule is to submit a risk management plan (RMPlan) describing the risk management program at the Donohue Sheldon Mill. This document is intended to summarize and communicate the RMP elements for the interested public and satisfy the RMPlan requirement of the RMP rule. |
1.1 Accidental Release Prevention and Emergency Response Policies
Donohue is committed to the safety of employees and the public and the preser
vation of the environment through the prevention of accidental releases of hazardous chemicals. These controls include: training programs for personnel; programs to help ensure safety in the design, installation, operation, and maintenance of processes at Donohue; and programs to evaluate the hazards at Donohue. In the event of an accidental release, Donohue will control and contain the release in a manner that will be safe for workers and will help prevent injury to the public or the environment.
1.2 Donohue's Regulated Substances
Donohue is an integrated pulp and paper mill primarily involved in the manufacture of recycled pulp and related finished paper products. Donohue handles chlorine in sufficient quantities to be covered by the RMP rule. Chlorine is primarily used for biological control and to disinfect water.
1.3 Offsite Consequence Analysis
The Environmental Protection Agency (EPA) requires a worst-case release scenario analysis and an alternative release scenario
analysis for chlorine. The worst-case scenario is intended to provide an estimate of the maximum possible area that might be affected under catastrophic conditions. In other words, the worst-case release is based on EPA's estimate of the worst possible accident that could occur at any given facility.
The worst-case scenario at the Donohue Sheldon Mill involves the total release of chlorine from a one ton chlorine container. The RMP rule requires Donohue to assume that all the contents of the container will be released in 10 minutes. The worst-case scenario also assumes that no safety equipment operates properly and no plant personnel respond to contain the leak. The EPA-defined endpoint for this analysis is estimated to be beyond the boundaries of the facility. Donohue does not expect the worst-case scenario to occur.
The EPA also requires facilities to estimate an alternative release scenario. Although the probability of a release remains small, the alternative release scenari
o is intended to represent what is more likely to happen in the event there is a release. For the Donohue Sheldon Mill, the alternative release scenario for chlorine involves a 5/16- inch diameter hole in the chlorine transfer line. This analysis was completed using appropriate information concerning physical location, detection methods, equipment layout, and expected response time along with the guidelines provided by the EPA. The endpoint concentration would extend slightly beyond the plant boundaries.
1.4 Accidental Release Prevention Programs and Chemical-Specific Prevention Steps
Donohue complies with the OSHA Process Safety Management rule (29 CFR 1910.119) and with the EPA RMP rule. The accident prevention programs in place at Donohue include distribution of safety information, hazard analysis and review, defined operating procedures, training of personnel, proper maintenance of systems, thorough evaluation of process changes, and safety checks of new processes.
ety Information - Donohue maintains a variety of technical documents that are used to help maintain safe operation of the processes at Donohue. Material safety data sheets (MSDS's) document the physical properties of hazardous substances handled at Donohue, including regulated substances in covered processes.
Hazard Review - Donohue performs and periodically updates hazard reviews of the covered processes to help identify and control possible accidental releases.
Operating Procedures - Donohue develops and maintains operating procedures to define how tasks should be safely performed. The operating procedures are used to train employees and to serve as reference guides for appropriate actions to take during both normal operations and process upsets.
Training - Donohue trains personnel to safely and effectively perform their assigned tasks. This includes initial and refresher training for Operations and Maintenance personnel.
Maintenance - The Donohue maintenanc
e program includes (1) procedures to safely guide workers in their maintenance tasks, (2) worker training in the maintenance procedures, (3) an inspection and testing program, and (4) a quality assurance program.
Managing Change - Donohue evaluates and approves all proposed changes to chemicals, equipment, and procedures for covered processes. Safety consequences of changes are addressed, safety information and procedures are updated, and affected employees are notified of the changes.
Pre-startup Safety Review - Donohue performs a safety review of new or modified covered processes before they are placed into service to help ensure safe operation.
Compliance Audits - Donohue performs periodic compliance audits of covered processes to verify that they are operating in compliance with the requirements of the RMP rule. A compliance audit report is prepared after each audit and any deficiencies noted by the audit are corrected in a timely manner.
ation - Donohue investigates all incidents that could have resulted in serious injury to personnel, the public, or the environment so that similar accidents can be prevented. The results of the investigation are documented, recommendations are resolved, and appropriate process improvements are implemented.
Employee Participation - Donohue involves mill personnel in the prevention program activities of all processes at the facility.
Hot Work Permits - Donohue has a hot work permit program to control spark or flame producing activities that could result in fires or explosions, as outlined in OSHA's fire prevention and protection requirements (29 CFR 1910.252).
Contractors - Donohue has a program to help ensure that contractor activities at the Donohue facility are performed in a safe manner. Donohue explains the hazards of the covered processes, safe work practices, and emergency response procedures.
Chemical-Specific Prevention Steps for Chlorine - Industry sta
ndards are followed at Donohue to help ensure safe handling of chlorine. The vendors supply chlorine in Department of Transportation (DOT) approved containers. Workers who perform operations involving chlorine receive training for the safe handling procedures for chlorine.
1.5 Five-Year Accident History
The RMP rule requires Donohue to maintain a five-year accident history of all accidental releases from covered processes that resulted in death, injury, significant on-site property damage, off-site property damage, evacuations, shelter-in-places, or off-site environmental damage. The Donohue Sheldon Mill had a chlorine release at the kraft bleaching process on January 18, 2000. Five contractors were taken to a local hospital for observation and one received breathing treatment. All were released after evaluation. The bleaching process in which the chlorine release occurred has be eliminated and is no longer in service.
1.6 Emergency Response Programs
Donohue has establishe
d a written emergency response plan that complies with the RMP rule and with other federal, state, and local contingency plan regulations. This plan has been communicated to local emergency response officials through the Local Emergency Planning Committee and local fire departments. Emergency response drills are conducted periodically.
1.7 Planned Changes to Improve Safety
Donohue is committed to the process of continuous improvement. Improvements in the safety and environmental aspects of the operation are critical components of the commitment. The following changes to improve safety are planned or have recently been completed:
- Donohue has committed to expand its recycling efforts by investing in additional deinking equipment. This additional recycling capacity does not require chlorine for bleaching and was completed during the month of April 2000. The process is currently on line and is fully operational. The chlorine bleach sequence has been eliminated and chlorin
e railcars are not used or stored at the mill.
- Donohue also evaluated each process utilizing chlorine to determine if a reduction or substitution for chlorine was viable. Based on this effort, chlorine was eliminated at the Waste Water Treatment Plant.