Boise Cascade Corporation - Executive Summary
16145 LDEQ Facility ID Number |
DeRidder Paper Mill Risk Management Plan: Executive Summary
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
The DeRidder Paper Mill has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of facility processes. The Boise Cascade Corporation (Boise Cascade) policy is to implement reasonable controls to prevent foreseeable releases of substances. However, if a release does occur, trained personnel will respond to, control, and contain the release.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED
Boise Cascade owns and operates the DeRidder Paper Mill (the Mill) located in Beauregard Parish, Louisiana. The Mill produces linerboard and newsprint products. The Mill purchases pine wood grown in the region, chips the timber, utilizes mechanical an
d chemical methods to produce pulp from wood fibers and processes the pulp into linerboard and newsprint products. Methods used in the pulping process include cutting, debarking, chipping, grinding, thermomechanical processes and cooking. Some newsprint pulp is bleached. Historically, Boise Cascade has bleached with chlorine as the bleaching agent.
The Mill is implementing changes in bleaching operations to prepare to meet the upcoming Cluster Rule requirements. These changes were evaluated to determine if any new regulated flammable or toxic substances exceeding the threshold quantity would be brought into the Mill. Based on process knowledge of the changes, Boise Cascade did not identify any listed flammable substances due to the process changes. However, the process changes will result in chlorine dioxide being manufactured and stored at the Mill above the threshold quantity. These process changes, when fully implemented would also reduce the amount of chlorine that will b
e onsite. Therefore the two regulated toxic substances, chlorine and chlorine dioxide will be kept on site. Chlorine and chlorine dioxide, their largest quantity on site, and their associated threshold quantities are presented in Table 1.
Largest Quantity of Regulated Substance
Regulated Substance Largest Quantity On Site(lbs) Threshold Quantity(lbs)
Chlorine Dioxide 12,100 1,000
Chlorine 180,000 2,500
Both chlorine and chlorine dioxide are stored above threshold quantity at the Mill. Based on worst-case analysis, the distance to the endpoint of chlorine yields the greatest radius of impact which reaches public receptors. In addition, the Mill is subject to Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM). Therefore, the DeRidder Paper Mill is classified as a Program 3 process under the Accidental Release Prevention (ARP) program.
The DeRidder Paper Mill does not have any flammable substa
nces above the threshold quantity; therefore, analysis of worst-case release scenarios for flammable substances is not required.
The endpoint for a worst-case release of a chlorine is based on the Emergency Response Planning Guideline level 2 (ERPG-2) developed by the American Industrial Hygiene Association. The ERPG-2 for chlorine is 0.0087 mg/L.
The worst-case release scenario was identified to be one 90-ton railcar of chlorine. The chlorine railcar is transported on site and is utilized as a storage vessel while the chlorine is piped directly to the bleaching process. The ARP Program requirement for a toxic worst-case scenario is to assume that the total quantity is released in ten minutes.
The storage quantity, toxic endpoint, and distance to the endpoint for chlorine for the worst-case release, using the Environmental Protection Agency (EPA) equations, is presented in Table 2.
Distance to Endpoint for Worst-Case Scenario
Chemical Name Weight(lbs
) Toxic EndpointERPG-2(mg/L) Distance toEndpoint(miles)
Chlorine 180,000 0.0087 > 25
The Mill's worst-case toxic release of chlorine was calculated to have a greater than 25 miles distance to the endpoint.
Alternative Release Scenarios
Alternative release scenarios are those that are more likely to occur than the worst-case release scenario. Alternative release scenarios for toxic substances should be those that lead to concentrations above the endpoints beyond the facility's fenceline. Alternative release scenarios for flammable substances should have the potential to cause substantial damage, including on-site damage.
The following conditions are considered for alternative release scenarios:
? Release rate dependent upon scenario;
? Use of typical meteorological conditions at the stationary source;
? Actual release height; and
? Consideration of active and passive mitigation systems.
The DeRidder Paper Mill does not have any flammable substances held abo
ve the threshold quantity. Therefore, analysis of regulated flammable substances is not required.
One alternative release scenario for each toxic substance is required under the ARP program. The regulated toxic substances at the Mill are chlorine and chlorine dioxide. Hypothetical, but likely to occur, release scenarios of chlorine and chlorine dioxide have been identified for the Mill.
Chlorine is used for water treatment and is located near the power house area. There are ten one-ton chlorine cylinders attached by a common header which feeds the chlorine to the water treatment facilities. An approximately 3/8-inch diameter leak develops in the header. The release duration occurs over a 60-minute period. The release occurs without any active or passive mitigation.
The distance to the toxic endpoint for the alternative-case release of chlorine using an accidental release model is presented in Table 3. The alternative-case release of chlorine re
sulted in an 0.18-mile distance to the 0.0087 mg/L ERPG-2 endpoint.
Chorine dioxide is generated on site and stored in two 78,000-gallon storage tanks at an approximately 93% capacity. For chlorine dioxide, the ARS is defined as a rupture of a 4-inch diameter transfer line leading from a 1% ClO2 solution storage tank to the bleach plant. The transfer pump operates at 200 gallons per minute (gpm). The spill is assumed to proceed at the pump rate. Because of the high vapor pressure of ClO2 and the turbulent action of the spill, all of the CLO2 is assumed to volatilize as soon as the solution impacts the ground.
The distance to the toxic endpoint for the alternative-case release of chlorine dioxide using RMPComp* is presented in Table 3. The alternative-case release of chlorine dioxide resulted in a 0.50-mile distance to the 0.0028 mg/L EHS-LOC equivalent (IDLH) endpoint.
Distance to Endpoint for Alternative Release Scenario
Chemical Name Storage Capaci
ty(lbs.) Toxic Endpoint (mg/L) Distance toEndpoint(miles)
Chlorine dioxide 6,050 0.0028 * 0.50
Chlorine 20,000 0.0087** 0.18
* Toxic endpoint basis is EHS-LOC equivalent (IDLH)
** Toxic endpoint basis is ERPG-2
GENERAL ACCIDENT RELEASE PROGRAM
The following is a summary of the of the accident prevention program in place at the DeRidder Paper Mill. Because the processes at the plant that are regulated by the EPA's Risk Management Program (RMP) regulation are also subject to OSHA's PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.
Active employee participation and involvement in the development and implementation of the DeRidder Paper Mill's PSM program is an important step toward achieving the objective to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. Employee involvement will help to
ensure that all perspectives regarding PSM are considered, and that the best ideas are implemented. Open communication is encouraged between supervisors and employees regarding all safety and health issues.
The Mill strongly promotes employee involvement in safety issues through existing programs. These programs include Hazardous Materials Team (HazMat Teams), regularly scheduled safety meetings, tail-gate safety meetings, Hazard Communication, Safety Suggestion Forms, "near-miss" reporting, and special training programs (emergency response training, first aid, etc.).
The DeRidder Paper Mill actively seeks employee involvement in the development and conduct of all accident prevention activities through the appropriate existing safety programs. Accident prevention is discussed at the regularly scheduled safety meetings and/or during special training sessions if necessary. Employees are encouraged to discuss accident prevention with their supervisors if they have questions, comments
, or suggestions.
Process Safety Information
Complete and accurate written process safety information (PSI) concerning process chemicals, process technology, and process equipment is essential to effective PSM and RMP programs and to completing and maintaining a process hazard analysis (PHA). The PSI will be useful to the operators; the team performing the PHA; those in charge of training; contractors; those conducting pre-startup safety reviews; and those in charge of updating the emergency preparedness plans. Process safety information is readily available to all employees.
The Mill keeps a variety of technical documents that are used to help maintain safe operation of the process. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerat
ions, is provided in material safety data sheets (MSDSs).
The Mill also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised.
Process Hazard Analysis (PHA)
The DeRidder Paper Mill has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.
The Mill uses the hazard and operability (HAZOP) analysis
technique to perform these evaluations. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.
The PHA team findings are forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios that are assigned the highest risk receive immediate attention. All approved mitigation options in response to PHA team findings are tracked until they are completed. The final resolution of each finding is documented and retained.
To help ensure that the process controls and/or process hazards do not
eventually deviate significantly from the original design safety features, the PHA team periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained.
The DeRidder Paper Mill maintains written procedures that address various modes of process operations, such as: (1) startup, (2) normal operations, (3) emergency shutdown, (4) normal shutdown, (5) initial startup of a new process, and (6) emergency operation and start up after emergency shutdown. These procedures provide guidance for experienced operators and also provide the basis for training new operators. Operating procedures are periodically revi
ewed. The review process involves both operators and technical staff.
The intent of the operating procedures is to provide workable, useful, and clearly written instructions for conducting operating activities. To have effective operating procedures, the task and procedures directly and indirectly related to the covered process must be appropriate, clear, consistent, and most importantly, communicated to employees. Operating procedures are specific instructions or details on what steps are taken or followed in carrying out the stated procedures. The specific instructions include the applicable safety precautions and appropriate information on safety implications.
In addition to training on operating procedures, the DeRidder Paper Mill has a comprehensive training program for all employees involved in operating the process. New employees receive basic training in pulp and paper operations. In addition, all operators periodically receive refresher training on the operating
procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least annually. All of this training is documented for each operator including the means used to verify that the operator understood the training.
The DeRidder Paper Mill uses contractors during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the Mill has procedures in place to ensure that contractors: (1) perform their work in a safe manner, (2) have appropriate knowledge and skills, (3) are aware of the hazards of their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site specific safety rules, and (6) inform Mill personnel of any hazards that they find during their work.
This is accomplished by providing contractors with an orientation session that covers (1) a process overview, (2) information about safety and
health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to beginning their work. In addition, the Mill evaluates contractor safety programs and performance during the selection of a contractor. Mill personnel periodically monitor contract performance to ensure that contractors are fulfilling their safety obligations.
Pre-startup Safety Review (PSSR)
The DeRidder Paper Mill conducts a PSSR on any new facility or facility modification that requires a change in process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with design specification and that all-supporting systems are operationally ready. The PSSR involves field verification of the construction and serves a quality assurance function by requiring verificat
ion that accident prevention program requirements are properly implemented.
The Mill has well established practices and procedures for maintaining process equipment. The basic aspects of this program include (1) training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting equipment deficiencies when identified, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process.
Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans and, (5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner.
Another integral part of mechanical integrity program is quality assurance. The Mill incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipmen
t is suitable for its intended use and that proper materials and spare parts are used when repairs are made.
Safe Work Practices
The DeRidder Paper Mill has long standing safe work practices in place to help ensure worker and process safety. Examples of these include: (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous and toxic substances before process piping and equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely.
Management of Change
The DeRidder Paper Mill has a comprehensive system to man
age changes to all covered processes. This system requires that changes to items such as process equipment, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as operating/management procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change.
The Mill promptly investigates all incidents that resulted in or reasonably could have resulted in a fire or explosion, a toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to gather the facts,
determine the root cause, and develop corrective action to prevent the reoccurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendation to prevent a recurrence, and forwards these results to the business management team for resolution.
To help ensure that the accident prevention program is functioning properly, the DeRidder Paper Mill periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every three years. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to Mill management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the appropriate enhancements to the prevention program ar
Chemical Specific Prevention Steps
The processes at the Mill have hazards that must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility.
Universal Prevention Activities
The accident prevention program summarized previously is applied to the RMP-covered process at the DeRidder Paper Mill. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors.
Specialized Safety Features
The DeRidder Paper Mill has safety features on many units to help (1) contain or control a release, (2) quickly detect a release, and (3) mitigate a release. The following types of safety features are used in the RMP covered process:
1. Chlorine sensors with audible alarms are located in the hyporoom and in the secondary vaporizer/chlorine washer are
2. Chlorine sensors with audible alarms are located at Mill water reservoir.
3. Chlorine dioxide detectors are in ClO2 generation building.
1. Pressure relief valves on railcars designed to relieve at 225 or 375 psi.
2. Key manual valves are chained and padlocked in their critical (open/closed) position.
3. Automated shutdown systems activated by high temperature sensors that close the steam flow control valves on the vaporizers if the temperature of exiting chlorine gas reaches 200?F.
4. Excess flow check valves designed to plug the outlet if outflow reaches equivalent of 7000 pounds per hour.
5. Two expansion chambers for each unloading line with one on standby to handle minor overpressures.
6. Safety relief valve designed with audible alarms to indicate a release.
7. Derailers and chock blocks to prevent rail car movement.
8. Interlocks for pressure, low and high flow, and temperature will automatically shutdown the ClO2 system if out of range of opera
1. Standard operating procedures that control, isolate, and terminate leaks.
2. Water fog streams employed at the origin of the leak.
3. Personnel trained in emergency procedures.
4. Personal protective equipment (e.g., escape respirator, self-contained breathing apparatus, and supplied-air breathing apparatus).
5. Ventilate contaminated areas.
Five Year Accident History
Since the ClO2 process is new to the Mill, there is no accident history involving this process. The Mill has an excellent record of accident prevention over the past five years for chlorine. There have been no incidents involving a release of chlorine, which have had any off site effects nor on site effects (as mandated in 40 CFR 68.42(a)). There were two incidents that did not have effects defined by 40 CFR 68.42(a) but were investigated very carefully to determine ways to prevent similar incidents from recurring. The recommendations from these investigations were implemented.
Emergency Procedure Information
The DeRidder Paper Mill maintains a written emergency procedure, which is in place to protect worker and public safety as well as the environment. The procedures account for the possibility of a toxic substance being accidentally released, as well as for the possibility of a fire or explosion. The procedures address notification of local emergency response agencies if a release occurs, and post incident cleanup and decontamination requirements.
Employees receive training in emergency procedures. The emergency procedure is updated when necessary based on modifications made to Mill facilities. The emergency procedure changes are administered through the Management of Change (MOC) process, which includes informing and/or training affected personnel in the changes.
The overall emergency procedure program for the Mill is coordinated with the Beauregard Parish, Louisiana, Local Emergency Planning Committee (LEPC). This coordination includes periodic mee
tings of the committee, which involves local emergency response officials, local government officials, and industry representatives.
The Mill has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident as well as facilitating quick response to an incident.
In addition to periodic LEPC meetings, the Mill conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the Mill provides periodic refresher training to local emergency responders regarding the hazards of regulated substances in the plant.
Planned Changes to Improve Safety
The DeRidder Paper Mill resolves all findings from PHA's, some of which result in modifications to the process. The following types of changes are planned over the next few years in response to PHA: safety audit and incident investigation findings.