Pope & Talbot, Inc. Halsey Pulp Mill - Executive Summary |
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EXECUTIVE SUMMARY POPE & TALBOT Pope & Talbot, Inc. (P&T) is a Kraft pulp mill which produces market pulps. The Pope & Talbot mill is located in Halsey, Oregon. The company is committed to operating in a manner that is safe for P&T workers, the public, and the environment. As part of this commitment, the company has established a system to help ensure safe operation of the processes at the Halsey mill. One component of this system is a risk management program (RMP) that helps manage the risks at P&T and that complies with the requirements of the Environmental Protection Agency's (EPA) regulation 40 CFR 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at P&T. This document is intended to satisfy the RMPlan requirement of the RMP rule and to provide the public with a description of the risk management program at Pope & Talbot. The risk management program consists of three elements: 1. A hazard assessment to help understand (a) the potential offsite consequences of hypothetical accidental releases and (b) accidents that have occurred during the last five years associated with the use of substances regulated by the RMP rule. 2. A prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered processes). 3. An emergency response program to help respond to accidental releases of regulated substances from covered processes Information further describing these elements is provided in this RMPlan. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Pope & Talbot is committed to the safety of workers and the public, and the preservation of the environment, through the prevention of accidental release of hazardous substances. The facility implements controls to prevent foreseeable releases of hazardous substa nces. These controls include training programs for personnel, programs to help ensure safety in the design, installation, operation and maintenance of processes, and programs to evaluate the hazards. In the event of an accidental release, the facility controls and contains the release in a manner that will be safe for workers and will help prevent injury to the public or the environment. Pope & Talbot provides response training to personnel, designates an emergency response coordinator to oversee response activities, and coordinates response efforts with the local fire department. In order to implement these policies, P&T established a management system directed by the Human Resource Manager to oversee safety-related activities. REGULATED SUBSTANCES Pope & Talbot is a pulp mill primarily involved in the manufacture of bleached and semi-bleached pulp. As part of this manufacturing process, the facility handles several regulated substances in sufficient quantities to be covered by the RMP rule, as shown in the following list of RMP-covered processes. Process Program Level Regulated Substance Process Quantity lbs Filter Plant 3 Chlorine 10,000 Chlorine Dioxide Plant 3 Chlorine Dioxide 19,000 OFFSITE CONSEQUENCE ANALYSIS Pope & Talbot had an air-modeling consultant perform an offsite consequence analysis to estimate the potential for an accidental release of a regulated substance to affect the public or the environment. The offsite consequence analysis consists of evaluating both worst-case release scenarios and alternative release scenarios. Pope & Talbot does not expect a worst-case release scenario to ever occur. The alternative release scenarios were selected to help local emergency response personnel to improve the community emergency response plan. An alternative release scenario represents a release that is possible but still unlikely to occur at the facility and would result in the greatest potential for offsite consequences if the release occur red. The main objective of performing the offsite 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 distance. At distances less than the endpoint distance, the effects would be greater; at distances greater than the endpoint distance, the effects would be less. When considering the release of a toxic substance such as chlorine or chlorine dioxide, most people at the endpoint distance would be 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 case release scenarios. These requirements are: ? One worst-case release scenario and an alternative release scenario for toxic substances in Program 3 processes (chlorine and chlori ne dioxide). The following information summarizes the offsite consequence analysis performed by P&T. Program 3-Chlorine The worst case toxic release at a facility is based on a release of the entire contents of the storage vessel that will result in the greatest distance to the toxic endpoint concentration. The largest chlorine storage vessel at the facility is a one ton cylinder, in which chlorine is stored as a pressurized liquid. The RMP rule requires that a worst case release of pressurized liquid be modeled as a gaseous release of the entire contents of the vessel over a period of 10 minutes. The release was modeled as a 10-minute release from the one ton cylinder using BREEZEa HAZDEGADIS dispersion model. Following the requirements of the RMP rule, the release was modeled at the highest temperature in a three-year period (103 ?Fahrenheit (?F)) for Eugene, Oregon, and at a wind speed of 1.5 meters per second. The model results showed that a worst case release of chlorine from a one ton cylinder would result in a distance to endpoint of 2.5 miles (4.0 kilometers (km)). The United States Census Bureau indicates that 400 people live within this distance from the one ton cylinders. The receptors within the distance to impact are an industrial facility (Fort James), schools, and residences. Pope & Talbot has chosen to use the same scenario for the alternative release scenario for chlorine. Program 3-Chlorine Dioxide The worst case toxic release at a facility is based on a release of the entire contents of the storage vessel that will result in the greatest distance to the toxic endpoint. For toxic liquid releases, EPA guidance requires that you assume the total quantity of the toxic liquid in the storage vessel is spilled, forming a pool. At the Pope & Talbot facility, the tanks have secondary containment. The secondary containment is large enough to contain 1.5 times the tank. The secondary containment is considered passive mitigation and may be accounted for in determining pool area and evaporation rate. Following the requirements of the RMP rule, the release was modeled at the highest temperature in a 3-year period (103 ?F) for Eugene, Oregon and at a wind speed of 1.5 m/s. The model results show that a worst case release of chlorine dioxide from a 63,000 gallon tank result in a distance to endpoint of 3.6 miles (5.8 km). The US Census Bureau indicates that approximately 830 people live within this distance. The receptors within the distance to impact are an industrial facility (Fort James), schools, the Willamette River (recreational area public receptor) and residences. The alternative release scenario for chlorine dioxide is a break in an elevated section of ClO2 piping. The piping transports ClO2 from the ClO2 plant to the bleach plant. Once the pipe is severed, the ClO2 is assumed to begin spilling out and forming a 1-cm deep pool on the ground. It is also assumed that P& T personnel would be able to turn off the pump and accompanying valves within ten minutes of the incident to completely stop the flow of ClO2 through the elevated section of pipe. The release was modeled using BREEZEa HAZDEGADIS dispersion model. The meteorological conditions used in the model were based on meteorological data for Eugene, Oregon. The release was modeled at an average temperature of 53 F, an average relative humidity of 78.5%, the most frequent wind speed of 3.09 m/s and most frequent stability class of D. The modeling results showed a distance to the endpoint of 1.6 miles (2.5 km). The US Census Bureau indicates that an estimated 160 people live within this distance. The receptors within the distance to impact are an industrial facility (Fort James) and residences. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Since the mill was constructed in 1969, a prevention program has been in place to help prevent accidental releases of hazardous substances. Beginning in 1992, P&T formalized this prevention program for the filter plant to comply with the 14 elements of the OSHA process safety management (PSM) prevention program. In 1998, prior to the building of the chlorine dioxide generator, P&T began implementing OSHA process safety management. In 1996, the EPA RMP rule established two levels of prevention program requirements: Program 3 - essentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environment. The following sections briefly describe the elements of the prevention program that address the EPA RMP rule prevention program requirements. Program 3 Prevention Program The Program 3 prevention program for chlorine and chlorine dioxide consists of the following 12 elements: Process Safety Information. P&T maintains a variety of technical documents that are used to help ensure safe operation of the processes. These documents address (1) physical properties of chlorine and chlorine dioxide, (2) o perating parameters of the equipment, and (3) design basis and configuration of the equipment. These documents are also used (1) to train employees, (2) to perform process hazards analyses, and (3) to help maintain the equipment. P&T ensures that this process safety information is available to all employees, the local emergency personnel, and the fire department. Process Hazard Analysis. P&T performs and periodically updates process hazard analyses (PHA's) 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 operating and engineering personnel with process operating experience and a leader with process hazard analyses experience is assembled to analyze the hazards of the process. Pope & Talbot uses the hazard and operability (HAZOP) technique supplemented with checklists, to perform this analysis. The team prepares a written report describing the results of the analyses, inc luding a list of recommendations. Responsibility to resolve the recommendations is assigned to the process supervisory personnel and, when appropriate, changes to enhance the safety of the process are implemented. Operating Procedures. P&T personnel develop and maintain operating procedures that cover all phases of operations, including startup, normal operations, normal shutdown, and emergency shutdown. 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 process upsets. 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. Training. P&T trains workers to safely and effectively perf orm assigned tasks. The P&T training program includes both initial 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 are used to verify that an employee understands the training material before the employee can resume work in the process. Mechanical Integrity. Pope & Talbot maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public, or the environment. The mechanical integrity program includes (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 meet the design standards required for service in the covered processes. The mechanical integrity program includes: ? Specification s for inspection and testing of process equipment. ? Specifications for replacement parts and equipment ? Procedures for inspecting, testing and maintaining process equipment ? Procedures for safe work practices such as lockout/tagout, hot work, confined space entry, and line or equipment opening ? Training of maintenance personnel ? Documentation of maintenance activities Management of Change. The 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 (e.g., replacing a valve with an identical valve) are allowed without completing a full management of change program. All other changes must be confirmed through the full management of change program to help ensure that inadvertent consequences of process changes are prevented, safety consequences of changes are address ed, affected process safety information and procedures are updated, and affected employees are notified of the changes. Pre-Startup Review. The company performs a safety review of a new or modified 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 ? Safety, operating, maintenance and emergency procedures are in place ? Employee training has been completed ? A process hazard analysis has been performed if the process is new or management of change requirements have been completed if an existing process has been modified Compliance Audit. Pope & Talbot audits covered processes to be certain that the prevention program is effectively addressing the safety issues. P&T assembles an audit team that includes personnel knowledgeable in OSHA's Process Safety Management, RMP rule and in the process. This team evaluates w hether the prevention program satisfies the requirements of the OSHA rule and the RMP rule and whether the prevention program is sufficient to help ensure safe operation of the process. The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented. Incident Investigation. P&T 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. P&T trains employees to identify and report any incident requiring investigation. An investigation team is assembled, and the investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved, and appropriate process enhancements are implemented. Employee Participation. P&T has a written employee participation program for covered processes to help ensure that the safety concerns of worker s are addressed. P&T encourages active participation of personnel in the prevention program activities of all processes at the facility. Employees are consulted on and informed about all aspects of the prevention program, including process hazard analyses and operating procedures. Hot Work Permits. P&T has a hot work permit program to control spark or flame producing activities that could result in fires or explosions in covered processes at the Halsey mill. The mill 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 Shift Supervisor reviews the completed form before work can begin. Training in the use of the Hot Work Permit Form is included in the P&T safe work practices orientation. Contractors. Pope & Talbot has a program to help ensure that contractor activities at the Halsey mill a re performed in a safe manner. The program reviews the safety record of all contractors to help ensure that only contractors who can safely perform the desired job tasks are hired. P&T explains to the contract supervisors the hazards of the process on which they and their employees will work, P&T safe work practices, and P&T emergency response procedures. P&T requires that the contractor supervisors train each of their employees who will work at the mill before that worker begins work at the Halsey mill. P&T periodically reviews contractors' training documents and work performance to help ensure that safe work practices are followed. CHEMICAL-SPECIFIC PREVENTION STEPS In addition to the required prevention program elements, P&T has implemented safety features specific to the hazardous substances used at P&T. The following paragraphs describe some of these safety features. Chlorine. Chlorine is supplied in DOT-approved 1-ton cylinders. Chlorine is used for water treatment at the filter plant. For the water treatment, chlorine is fed through piping to an eductor, where it is absorbed into process water for use in the water treatment unit. The length of piping containing chlorine is kept to a minimum to reduce the likelihood of a release. There is an area sensor that will close the valve to the 1-ton cylinder if high chlorine leaks are detected. In the pulp mill Chlorine Dioxide. Chlorine dioxide will be generated on site. The chlorine dioxide generator was designed as a fail-safe design. In emergency situations, the chemicals supplied to the generator are stopped. The reaction is quenched with chilled water. In a power failure situation, the valves for the tank with the chilled water fail open so that the reaction will immediately be quenched. Chlorine dioxide is stored at a stable temperature of 45 ?F in refrigerated tanks that are continually swept with air to remove any residual chlorine dioxide. The residual chlorine dioxide is sent back in to the generator system. FIVE YEAR ACCIDENT HISTORY Pope & Talbot has completed a five-year accident history for chlorine and chlorine dioxide. There has been one minor accident at the Fort James facility with chlorine that resulted from a 7-lb. release in the past five years. Chlorine dioxide is a new chemical that has not been previously used at the site. Chlorine dioxide generation is expected on October 24, 2000. Year Number of Reported Accidents Substance Released Consequences 1994 None 1995 None 1996 None 1997 None 1998 1 Chlorine On September 17, 1998, 7-lb. of chlorine was released as the HOCl generators were starting up after being down for maintenance. 1999 None Emergency Response Programs P&T has established a written emergency response program to help safely respond to accidental releases of hazardous substances. The emergency response plan includes procedures for: ? Notifying the local fire department and the public should there be an acciden tal release ? Providing proper first aid and emergency medical treatment to treat accidental human exposure to hazardous substances at P&T ? 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 P&T maintains an emergency response team trained in these emergency response procedures. All P&T personnel are trained in evacuation procedures. P&T periodically conducts emergency response drills on site with the Pope & Talbot emergency response teams and also coordinates drills with the local fire department. The written emergency response plan complies with other federal contingency plan regulations (e.g., the OSHA regulations 29CFR 1910.38(a)) and has been communicated to local emergency response officials through the local fire department. P&T maintains a regular dialogue with the local fire chief, and P&T pr ovides appropriate information to the fire chief. PLANNED CHANGES TO IMPROVE SAFETY P&T constantly strives to improve the safety of the processes at P&T through both the incident investigation program and a program soliciting safety suggestions from the workers. The following changes to improve safety are planned or have recently been completed. Because of the accidental release in September 1998, P&T reviewed the chlorine handling system and eliminated excessive corrosion due to water condensation in the equipment by replacing the purge air with dry nitrogen. These changes reduce the likelihood of a chlorine release caused by degraded equipment or external impact. |