Georgia-Pacific Crossett Paper Operations - Executive Summary

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Georgia-Pacific Crossett Operations 
Risk Management Plan 
1.0    Executive Summary 
Georgia-Pacific Crossett Paper Operations (G-P/Crossett) is committed to operating in a manner that is safe for G-P/Crossett workers, the public, and the environment. As part of this commitment, G-P/Crossett 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 (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 G-P/Crossett. 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 consists of four elements: 
? 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). 
? a prevention program to help maintain and safely operate the processes containing more than the threshold quantity of the regulated substances (covered processes). 
? an emergency response program to respond to accidental releases of the regulated substances from the covered processes.  
? a management system that delineates responsibility for implementing and maintaining the Risk Management Program. 
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 G-P/Crossett. 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 substance and injuries and damage resulting from the release of a hazardous substance. 
G-P/Crossett minimizes the potential releases of the hazardous substances used at the facility. When 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. 
G-P/Crossett 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 closely with the Local Emergency Planning Commission (LEPC) to help ensure that 
injuries and/or environmental damage will not occur in the event that a release does occur. 
The safety programs at G-P/Crossett consist 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 
G-P/Crossett 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 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 hazards at the facility. 
In the event of an accidental release, the facility will control and contain the r 
elease in a manner that will be safe for workers and will help prevent injury to the public and/or the environment. G-P/Crossett 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 Crossett Paper Operations. 
1.2    Georgia-Pacific Crossett Operations and Our Regulated Substances 
G-P/Crossett is a pulp and paper mill primarily involved in the manufacture of brown/bleached paper products. As part of this manufacturing process, the facility produces and stores Chlorine Dioxide (Cl02) for the use of bleaching pulp. The facility also stores and uses chlorine in one-ton cylinders for water treament. The Chlorine Dioxide Solution System, which includes the generation, storage and distributi 
on of chlorine dioxide, is considered an RMP covered process in Program Level 3.  
The current plan reflects a revision to the orginial RMP Plan submitted June 1999 for elimination of chlorine, which includes all railcars, in the bleach plant and an increased storage capacity for chlorine dioxide.  The data associated with chlorine use in Prevention Program ID 4, remains in the plan for historical reference only. 
1.3    Off - Site Consequence Analysis 
G-P/Crossett performed an off- site consequence analysis to estimate the potential for an accidental release of regulated substances to affect the public or the environment. The off site consequence analysis consists of evaluating both the worst-case release scenarios and alternative release  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 G-P/Crossett and, (2) would result in an off- site consequence if the re 
lease 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 end- point 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 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 release scenarios that must be reported  
by Georgia-Pacific Crossett Operations. These requirements include: 
? one worst-case release scenario for a toxic substance in Program Level 3 (one scenario representing chlorine dioxide) 
? 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 G-P/Crossett. 
1.3.1     Program Level 3 Processes - Chlorine Dioxide (Cl02) Solution System and chlorine water treament. 
a.  The worst-case release scenario for chlorine dioxide is the failure of a a 158,000 gallon storage  vessel located in the Bleach Plant.  The RMP Rule mandates, that for the worst-case scenario involving a covered substance that the analysis assumes loss of the entire contents of the largest storage vessel in ten minutes.  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 30,000 people live within this distance from the vessel; several public receptors are also located within this distance (e.g., several industrial facilities, several public and private elementary schools and high schools, several nursing homes, several churches, several recreation parks, and numerous subdivisions). There are also several environmental receptors. 
b.  The alternative release scenario for chlorine is the failure of a one inch diamter transfer line, allowing chlorine to be released from a pressurized 1 ton cylinder (100 psig) at the rate of 150 lb/min for 13.0 minutes. The maximum distance to the toxic end point concentration, based on the EPA Lookup Table approach, is approximately 1.7 miles. The United States Census indicates that approximately 4,000 people live within this distance. Several public receptors are also located within this distance (public elementary school, several industria 
l facilities, several recreation parks, and several subdivisions). There are also several environmental receptors. 
c.  The alternative release scenario for chlorine dioxide is the rupture of a chlorine dioxide solution line located at the discharge side of the ClO2 transfer pumps' header.  The pump could pump approximately 10,008 lb/min for 5 minutes before the release would be stopped by the automated shut-off valves. The released chlorine dioxide solution will form a pool of minimum depth (1 cm) and evaporate to form a vapor cloud. The maximum distance to the toxic endpoint concentration, based on the EPA Lookup Table approach, is approximately 3.1 miles. The United States Census indicates that approximately 10,000 people live within this distance.  Several public receptors are also located within this distance (several industrial facilities, several recreation parks, and several subdivisions). There are also several environmental receptors. 
1.4 Accidental Release Prevention  
Georgia-Pacific Crossett 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 elements of the Occupational Safety and Health Administration (OSHA) 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 program also focuses on protecting the public and the environment. 
1.4.1    Program Level 3 Prevention Program - The following sections briefly describe the elements of the Georgia-Pacific Crossett Operations Program Level 3 Prevention Program that addresses the EPA RMP Rule Prevention Program requirements  
for the Chlorine Systems and Chlorine Dioxide Solution Systems. 
A. Employee Participation The facility has developed a written employee participation program for the covered processes to help ensure that the safety concerns of G-P/Crossett employees are addressed. The facility encourages active participation from personnel in the development 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. 
B. 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 technical data of the process, and (3) the design basis and configurations of the equipment used in the processes. The facility ensures that this proces 
s safety information is maintained, accurate, and available to all G-P/Crossett employees, the LEPC, and the Crossett Fire Department.   
Material safety data sheets (MSDS) document the physical and chemical properties 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/available to the LEPC, Crossett Fire Department and Plant Emergency Response teams for use in helping formulate emergency response plans 
Many of the operating parameters are included in the technical information to help with the safe operation of the process. These documents are also used (1) to train employees, (2) to perform process hazard analysis, and (3) to help maintain the equipment to the design specification.  The available information includes: 
? operating paramete 
? block flow or simplified process flow diagrams 
? process chemistry 
? maximum inventories  
? safe limits for parameters such as temperature, pressure, or flow 
? consequences of deviations from established operating limits 
? design basis and configuration of equipment 
? piping and instrumentation diagrams, including materials of construction 
? area classification 
? safety systems 
? applicable design codes and standards 
? relief and ventilation systems 
C. Process Hazard Analysis.  G-P/Crossett 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'" technique, suppleme 
nted with checklist, 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. 
D. Operating Procedures. G-P/Crossett 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, emergency shutdown, and temporary operations. The facility reviews and certifies the operating procedures annually. 
E. Training. G-P/Crossett 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 substance in the process, and (3) a detailed review of the process operating procedures and safe work practices. Written test and oral reviews are used to verify that the employee understands the training materials before the employee can operate the process. 
The oper 
ators 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. 
F. Contractors.  G-P/Crossett 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. G-P/Crossett 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. 
G. Pre-startup Safety Reviews.  G-P/Crossett 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. 
H. Mechanical Integrity.  G-P/Crossett maintains the mechanical integrity of the covered process equipment to help prevent equipment failures that could endanger workers, the public, o 
r 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 meet the design standards required for service in G-P/Crossett 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, confined space entry 
? training of maintenance personnel 
? documentation of maintenance activity 
I. Hot Work Permit.  G-P/Crossett 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 be initiated. 
J. Management of Change.  The G-P/Crossett "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. 
K. Incident Investigations.  G-P/Crossett 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. 
L. Compliance Audits.  G-P/Crossett audits the covered processes to be certain that the facility's prevention program is effectively addressing 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 operations of the process. The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented. 
1.4.2     Chemical-specific Prevention Steps (Chlorine Dioxide)  In addition to the required prevention program elements, G-P/Crossett 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 14.0 gram- per- liter (1.4 wt.%) strength in solution is absorbed. 
1.5    Five - Year Accident History- 
Georgia-Pacific has not had any off-site accidents in the past 5 years.  There were four on site accidents involving chlorine or chlorine dioxide solution. 
Year     Number of Reported Accidents     Substance Released     Consequences 
1996     0     None     No Off site Impact 
1997     0     None     No Off site Impact 
1998     1/G-P employee     Chlorine<1 lb     Chemical burn eyes  
1999     1/G-P employee     Chlorine dioxide107 lb      Inhalation/acute 
1999 1 no injuries chlorine dioxide evacuated employees in Tissue work area 
2000 1 3/G-P employees chlorine dioxide inhalation/acute  
For each of the above incidents, we have conducted formal incident investigations to identify and correct the root causes of the events. 
1.6    Emergency Response Programs 
Georgia Pacific Crossett Operations has established a written Emergency Response Program to safely respond to accidental releases of hazardous substances. The Emergency Response Plan includes procedures for the following: 
?  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 medica 
l 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 personnel are trained in evacuation procedures. The facility periodically conducts emergency response drills, including an annual drill coordinated with the local fire department. 
The written Emergency Response Plan complies with other federal contingency plan regulations (e.g., OSHA 29 CFR 1910.38(a), 29 CFR 1910.120(a)) and is 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 the 
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