Pensacola Mill - Executive Summary
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RISK MANAGEMENT PLAN
International Paper Company
375 Muscogee Road
Cantonment, FL 32533
1. Executive Summary
International Paper Company (IP) is committed to operating in a manner that is safe for IP workers, the public, and the environment. As a demonstration of that commitment, IP has developed and implemented Environmental and Workplace Health and Safety Policies to serve as guiding principles for all it's employees and operations. The Environmental Policy includes the following:
"IP strives to minimize the environmental impacts of all our operations, processes, and products in a manner responsive to the needs of our shareh
olders, customers, employees, the communities in which we operate, and the public."
The Workplace Health and Safety Policy further includes:
"The protection of our people and property as well as the prevention of all accidents, injuries, and illnesses, are core values at International Paper Company. As such, they are also key considerations in everything we do. Our success depends greatly on a work environment that is safe and healthy for all employees, visitors, contractors, and the residents of the communities in which we operate."
IP believes that following these policies is the responsibility of every employee. IP has put in place an organizational structure to demonstrate its commitment to that belief. At the corporate level, the Senior Vice President of Environment, Health, and Safety reports directly to the Chairman and Chief Executive Officer. At each of its manufacturing facilities the Environment, Health and Safety Manager reports directly to the Operations Manager.
rt of this commitment, IP 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 manage the risks at IP and that complies 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 IP. 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 IP.
The risk management program at IP consists of three elements:
1. a hazard assessment to help understand the potential offsite consequences of hypothetical accidental releases and a history of accidents that have occurred during the last five years associated with the use of substances reg
ulated by the RMP rule (regulated substances) - see topics 1.3 and 1.5
2. a prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered processes) - see topic 1.4
3. an emergency response program to help respond to accidental releases of regulated substances from covered processes - see topic 1.6
Information further describing these elements is provided in this RMPlan.
Although the risk management program at IP helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety program at IP. In fact, IP has a comprehensive safety program in place establishing many levels of safeguards against release of a hazardous substance and injuries and damage from a release of a hazardous substance.
IP limits the use of hazardous substances. Before using a hazardous substance at IP, less hazardous alternatives are considered. Part of IP'S RMP complia
nce philosophy has been the reduction of the use of hazardous substances covered under this regulation. When a hazardous substance is used, IP considers the potential for this substance to adversely affect IP workers, the public, and the environment and takes steps to prevent any such effects.
IP works to prevents releases of the hazardous substances used at the facility. When a hazardous substance is used at IP, the equipment is designed, built, and operated to reduce the likelihood of an accidental release. Industry and government standards are adhered to in the design, construction, and operation of the equipment.
IP limits damage from a release, if such a release occurs. IP trains workers to respond to an accidental release, reducing the consequences of a release if it occurs. In addition, IP works with the local fire department and with the local emergency planning committee (LEPC) to help ensure that injuries and/or environmental damage will not occur if a release does occu
The safety program at IP 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 IP that are required by the RMP rule.
1.1 Accidental Release Prevention and Emergency Response Policies
IP is committed to the safety of workers and the public, and the preservation of the environment, through the prevention of accidental releases of hazardous substances. IP implements reasonable controls to prevent foreseeable releases of hazardous substances. These controls include training programs for personnel; programs to help ensure safety in the design, installation, operation, and maintenance of processes at IP; and programs to evaluate the hazards at IP.
In the event of an accidental release, IP controls and contains the release in a manner that will be safe for workers and will help limit injury to the public or the environment. IP provides response training to IP personnel, d
esignates an emergency response coordinator to oversee response activities, and coordinates response efforts with the local fire department. The Pensacola Mill maintains a Hazardous Materials Response team that is trained and equipped to respond to on-site chemical releases. Response activities have also been discussed with the LEPC.
In order to effectively implement these policies, IP established a management system headed by the mill's Operations Manager to oversee safety-related activities.
1.2 IP and Regulated Substances
The Pensacola Mill is an integrated pulp and paper mill primarily involved in the manufacture of bleached pulp and related finished paper products. As part of this manufacturing process, IP handles regulated substances in sufficient quantities to be covered by the RMP rule, as shown in the following list of RMP-covered processes at Pensacola.
Process Chlorine Dioxide System
Program Level 3
Regulated Substance Chlorine Dioxide
Maximum Process Quantity 51
Largest Single Vessel 17,127 pounds
1.3 Offsite Consequence Analysis
IP performed an analysis of the potential offsite consequence an accidental release of a regulated substance could have on the public or the environment. The RMP regulations require that such an analysis include an evaluation of both worst-case release scenarios and alternative release scenarios. IP does not expect a worst-case release scenario to ever occur. Our belief is based on the fact that such a release has never occurred at any IP mill. However in accordance with the RMP requirements, a worst case release analysis was conducted and the results are reported in this document.
The alternative release scenarios evaluated are intended to represent releases that might occur and were based on our experience at our mills. The alternative release scenarios were selected to help the local emergency planning committee improve community emergency response plans. An alternative release scenario represe
nts a release that (1) might occur at a facility like IP's and (2) would result in the greatest potential offsite consequences if the release occurred. While IP believes that such releases are unlikely to occur at our mill, nevertheless we have evaluated the offsite impact of the releases in accordance with the regulatory requirements. It is important to note that no release with offsite consequences has ever occurred at IP's Pensacola Mill.
IP has conducted the offsite consequence analysis for the worst-case release scenario using the EPA's guidance document which includes look-up tables that were developed to provide highest estimate of the possible offsite consequences of such releases. 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 tables were developed to provide information on the estimated distance to the toxi
c endpoint for a chemical of concern. IP has not conducted a more detailed analysis of these scenarios because we believe the potential for such releases is unlikely and because more refined analysis of such events will not provide additional information that would be useful.
While the tables provide the required data to meet regulatory requirements, they do not provide detailed information on the travel time or concentration of the chemical in the plume. IP believes such data can be valuable to local emergency planning agencies for alternative release scenarios and therefore has elected to conduct air quality modeling to characterize offsite impacts due to alternative release scenarios. A model is a mathematical estimate of the way a chemical plume moves and reacts after it is released to the air. The air quality model provides more realistic and detailed information on estimated plume dimensions, concentration of pollutants by downwind distance, time of travel and the location of t
he plume at discreet time intervals. These data have been provided to Escambia County Emergency Management to assist them in planning for any actions that should be taken if, the unlikely event of an accident should occur at the Pensacola Mill.
IP selected two models to evaluate off-site impacts: an EPA approved screening model known as SCREEN3 and TRACE. TRACE is a comprehensive hazard assessment software package for analyzing the impact of toxic, flammable and explosive chemical releases in the atmosphere. TRACE can simulate toxic chemical releases resulting from tank failures and pipe leaks for gases that are heavier than air or for neutrally buoyant gasses. TRACE has the capability to model ground level or elevated releases in the form of dense clouds or buoyant plumes. SCREEN3 was used to simulate the release of chlorine dioxide due to a loss of scrubber water flow in the bleach plant control system. TRACE was used to evaluate the release of chlorine dioxide due to a leak in
a chlorine dioxide transfer pipe.
Typical information input to the model to characterize a chemical release is:
* Physical State: gas, liquid, aerosol, and multi-phased
* Release Type: continuous, instantaneous, point (stack releases), and area (releases from a pool)
* Release Condition: height, substrate type (concrete, soil), area and height of berm, exit velocity, release diameter, and exit temperature
* Chemical Properties: molecular weight, specific gravity, vapor pressure, density, latent heat, and other properties depending upon the model
In addition to the physical parameters that characterize a release, meteorological data is needed by the model to characterize the ambient release conditions. Meteorological data is used in dispersion models to calculate the distance that the pollutant plume moves downwind and the concentration of the pollutant at any given time or distance. The meteorological variables that affect the dispersion of a chemical release are as follows:
* Wind Speed and Direction: The wind speed is used to determine the plume dilution, plume transport, plume rise, evaporation rate, and magnitude of the concentration. Wind direction defines the direction in which the plume travels.
* Temperature: Temperature is used to calculate plume rise and evaporation rates.
* Atmospheric Pressure: is used to calculate gas and liquid release rates.
* Atmospheric Stability: Stability is an indication of atmospheric turbulence. The turbulence is depended upon thermal (heating of the ground) and mechanical (surface roughness and wind speed) effects. Turbulence also acts to dilute the plume and reduce concentrations.
For the RMP modeling performed the following meteorological parameters were used for the alternate release scenarios:
Wind Speed: 3 m/s
Ambient Temperature: 68 deg F
Solar Radiation: 0.3 KW/m2
Stability Class: D
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, 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. Some people who are particularly susceptible to the substance released could be incapacitated.
The RMP rule includes specific requirements for the worst-case and alternative release scenarios that must be reported by IP. These requirements are:
* one worst-case release scenario for each Program 1 process.
* one worst-case release scenario for the class of toxic substances in Program 2 and Program
3 processes (i.e., one scenario representing ClO2 Generation and Distribution)
* one alternative release scenario for each of the toxic substances in a Program 2 or Program 3 process (i.e., ClO2 Generation and Distribution)
* one worst-case and one alternative release scenario for the class of flammable substances in Program 2 and Program 3 processes.
The following information summarizes the offsite consequence analysis performed by IP.
1.3.1 Program 3 Processes - Toxic Substances
The worst-case release scenario for toxic substances is rupture of the 172,000-gal (714-ton) chlorine dioxide solution (1.2 wt%) storage tank in the Chlorine Dioxide Generation and Distribution Process. This scenario would result in offsite consequences.
The alternative release scenario for chlorine dioxide is an expansion or pipe joint leak in the chlorine dioxide distribution piping leading to the bleaching process. This scenario assumes that 3600 gal. (15 tons) of solution is released in a 30 minu
te period. This scenario could result in very minor offsite consequences.
1.4 Accidental Release Prevention Program and Chemical-specific Prevention
The Pensacola Mill has always focused on ways to prevent accidental releases of hazardous substances. Beginning in 1992, IP formally implemented the 14 elements of OSHA's Process Safety Management (PSM) prevention program. In 1996, the EPA RMP rule established two levels of prevention program requirements. IP has implemented the prevention program requirements, which are as follows:
Program 3 level processes - essentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environment. Program 3 requires 12 of the 14 elements of the OSHA PSM regulation. This prevention program has been established for the chlorine dioxide generation and distribution process.
The following sections briefly describe the elements of IP'S prevention program that address the EPA RMP rule prevention program requir
1.4.1 Program 3 Prevention Program
The Pensacola Mill Program 3 prevention program, which applies to the chlorine dioxide generation and distribution process, consists of the following 12 elements:
1. Process Safety Information. IP maintains a variety of technical documents that are used to help ensure safe operation of the covered processes. These documents address (1) physical properties of hazardous substances handled in these processes, (2) operating parameters of the equipment/process and (3) design basis and configuration of the equipment in a part. This process safety information is available to all IP employees, and the local emergency planning committee (LEPC).
Material safety data sheets (MSDSs) document the properties of hazardous substances handled at IP, including regulated substances in covered processes. Information on the technology and engineering design of the covered process includes the operating parameters and the design basis and configuration of
the process equipment.
When important information was not available from the design documents, it was developed through special projects or, in the case of operating parameters, during process hazard analyses of the process. Many of the operating parameters are included in the operating procedures to help with the safe operation of the process. These documents are used (1) to train employees, (2) to perform process hazards analyses, and (3) to help maintain the equipment.
2. Process Hazard Analysis. The Pensacola Mill 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 leader with process hazard analyses experience is assembled to analyze the hazards of the process. IP primarily uses the hazard and operability (HAZOP) technique, supplemented wi
th checklists, to perform this analysis. The PHA team prepares a written report describing the results of the analysis, including a list of recommendations. Responsibility to resolve the recommendations is assigned to area personnel and, when appropriate, changes to enhance the safety of the process are implemented.
3 Operating Procedures. IP operators, process engineers and supervisors work together to develop and maintain 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 process upsets.
IP personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operations, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations. The operating procedures are used both
to help in operating the covered processes and as a training guide for both new and experienced operators. Operating procedures are updated at least annually to ensure they reflect current operating conditions.
4. Training. The mill trains workers to perform their assigned tasks safely and effectively. The IP 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. Oral reviews and written tests are used to verify that an employee understands the process operation prior to job assignment.
The operators are consulted annually during operating procedure reviews to evaluate the effectiveness and need for additional training. Recommendations from the operators are reviewed, and changes to the training program are implemented, as appropriate.
5. Mechanical Integrity. IP maintain
s the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public, or the environment. This is accomplished by: (1) an inspection and testing program to help identify equipment deterioration and damage before the equipment fails, (2) a quality assurance program to help ensure that new and replacement equipment meet the design standards required for service in the covered processes and (3) utilizing personnel who are specially trained to maintain process equipment.
6. Management of Change. The IP 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 management of change form. All other changes must be reviewed through the full
management of change program, to help ensure that inadvertent consequences of process changes are prevented, safety consequences of changes are addressed, affected process safety information and procedures are updated, and affected employees are notified of the changes.
7. Pre-startup Review. IP performs a safety review of a new or modified process before the process is placed into service to help ensure that the process is safe to operate. This review confirms that an employee has completed the requisite training. The review also confirms that adequate safety, operating, maintenance, and emergency procedures are in place and that construction and equipment are in accordance with design specifications. A pre-startup review checklist is completed to document the review and to ensure that appropriate issues have been addressed.
8. Compliance Audit. IP audits covered processes to be certain that the IP prevention program is effectively addressing the safety issues for the covered
processes. IP assembles an audit team that includes personnel knowledgeable in the RMP rule and in the process. This team evaluates whether the prevention program satisfies the requirements of 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 improvements to the prevention program are implemented.
9. Incident Investigation. IP 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. IP 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 improvements are implemented.
10. Employee Participation.
The Pensacola Mill developed a written employee participation program for covered processes to help ensure that IP workers participate in the development and continuous improvement of these prevention program elements. Employees are consulted on and informed about various aspects of the RMP rule prevention program, including PHAs and operating procedures.
11. Hot Work Permits. IP uses a hot work permit program to control spark- or flame-producing activities that could result in fires or explosions in covered processes at the Pensacola Mill. IP 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 IP safe work practices orientation.
12. Contractors. IP has es
tablished Contractor Guidelines for Safety and Health to outline expectations related to contractor work, at Pensacola Mill including work on the covered processes. The program reviews the safety record of all contractors to help ensure that IP only hires contractors who can safely perform the desired job tasks. IP explains to the contract supervisors the hazards of the process on which they and their employees will work, IP safe work practices, and IP emergency response procedures. IP requires that the contractor supervisors also train each of their employees prior to beginning their work on a covered process. IP periodically reviews contractors' training documents and work performance to help ensure that safe practices are followed.
1.4.2 Program 2 Prevention Program
There are no Program 2 processes at IP's Pensacola Mill.
1.4.3 Chemical-specific Prevention Steps
In addition to the required prevention program elements, IP has implemented safety features specific to the hazar
dous substances used at IP. The following paragraphs describe some of these safety features.
Chlorine dioxide gas is produced in the chlorine dioxide generator and piped to a water absorber column, where a 1.2 wt % chlorine dioxide solution is generated. Chlorine dioxide is produced at the IP-Pensacola Mill and stored as a dilute water solution to avoid transporting large quantities of the solution. Storing the chemical in a water solution greatly reduces the potential for off-site impact. Containment diking and sewers are provided in all areas where chlorine dioxide is used. Detectors and alarms provide continuous monitoring in all areas where the potential for chlorine dioxide exists, providing early detection and helping to ensure a quick response in the event of a leak.
1.5 Five-Year Accident History
IP has completed a five-year accident history for the chlorine dioxide generation and distribution process at the Pensacola Mill. There have been no accidents or releases involv
ing a reportable quantity of chlorine dioxide at the Pensacola Mill in the last five years. In fact, there has never been a release of a reportable quantity of chlorine dioxide at the Pensacola Mill.
1.6 Emergency Response Programs
IP 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 fire department and the public about accidental releases that could reasonably result in offsite consequences
* providing proper first aid and emergency medical treatment to treat accidental human exposure to hazardous substances at IP
* 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 Pensacola Mill maintains an emergency response team trained in these emergency resp
onse procedures. All IP personnel are trained in evacuation procedures. IP periodically conducts emergency response drills, The written emergency response plan complies with other federal contingency plan regulations (e.g., the OSHA regulations 29 CFR 1910.38(a), 29 CFR 1910.120(a)) and has been communicated to local emergency response officials through the local fire department. IP maintains a regular dialogue with the local fire chief, and IP provides appropriate information to the fire chief.
1.7 Planned Changes to Improve Safety
The Pensacola Mill constantly strives to improve the safety of the processes through both the incident investigation program and a program soliciting safety suggestions from the workers. The following changes to improve process safety are planned or have recently been completed.
* IP has eliminated the use of anhydrous ammonia at the Pensacola Mill. A water based nitrogen solution is now utilized for Wastewater Treatment Plant nutrient supplement.
This eliminates the risk of employee exposure and off site impacts that could have resulted from an accidental release of anhydrous ammonia.
* IP continuously explores new technologies, additives and processes to reduce the quantity of chlorine dioxide used in the bleaching process.