Demopolis Mill - Executive Summary
1. EXECUTIVE SUMMARY |
Gulf States Paper Corporation (Gulf States) is committed to operating in a manner that is safe for our workers, the community, and the environment. As part of this commitment, Gulf States 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 involved with using hazardous substances at Gulf States 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 an executive summary in the risk management plan (RMPlan) describing the risk management program at Gulf States. This document is intended to satisfy the executive summary requirement of the RMP rule and to provide the public with a description of the risk management program at Gulf States.
he risk management program at Gulf States consists of three elements:
1. a hazard assessment designed to help us understand (a) the potential offsite consequences of hypothetical accidental releases and (b) accidents that have occurred during the last five years associated with the substances regulated by the RMP rule (regulated substances) - see topics 1.3 and 1.5
2. a prevention program to help maintain and safely operate processes containing significant quantities of substances regulated by the RMP rule - see topic 1.4
3. an emergency response program to help respond to accidental releases of regulated substances from processes covered by the RMP rule - see topic 1.6
Information further describing these elements is provided in this executive summary.
Although the risk management program at Gulf States helps ensure that our facility is maintained and operated in a safe manner, it is only one component of the safety program. In fact, Gulf States has a comprehensive safety program
that establishes many levels of safeguards against accidental releases and against the injuries and damage that could occur from accidental releases.
Gulf States limits the use of hazardous substances. Before using a hazardous substance, we always consider less hazardous alternatives. When a hazardous substance is used at Gulf States, we consider the potential for this substance to adversely affect our workers, the public, and the environment and take steps to prevent any such effects.
Gulf States prevents releases of the hazardous substances used at the facility. When a hazardous substance is used, the equipment used to contain it is carefully designed, built, and operated to reduce the likelihood of an accidental release. Industry and government standards are closely adhered to in the design, construction, and operation of the equipment.
Gulf States limits damage from a release, if such a release occurs. We work daily to prevent accidental releases from occurring. However, w
e also train our workforce to respond to accidental releases and reduce the potential consequences. In addition, Gulf States works with the local fire department and with the local emergency planning committee (LEPC) to help ensure that all emergency responders work closely together to minimize the impact of the release on our workers and the community.
The safety program at Gulf States 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 Gulf States that are required by the RMP rule.
1.1 Accidental Release Prevention and Emergency Response Policies
Gulf States 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. Gulf States implements reasonable controls to prevent foreseeable releases of hazardous substances. These controls include training programs for pe
rsonnel; programs to help ensure safety in the design, installation, operation, and maintenance of processes at Gulf States; and programs to evaluate the hazards at Gulf States.
In the event of an accidental release, Gulf States will strive to control and contain the release in a manner that will be safe for workers and will help prevent injury to the public or damage to the environment. Gulf States provides response training to our personnel, designates the maintenance superintendent or his designee to oversee response activities, and coordinates response efforts with the local fire department and/or the LEPC. Response activities have also been discussed with the LEPC.
1.2 Gulf States Paper Corporation and the Regulated Substances We Use
Gulf States is an integrated pulp and paperboard mill primarily involved in the manufacture of bleached pulp and related finished paperboard products. As part of this manufacturing process, Gulf States handles one regulated substance in sufficien
t quantities to be covered by the RMP rule, as shown in the following list of RMP-covered processes at Gulf States.
Process Regulated Substance(s)
No. 1 Bleach Plant, Chlorine dioxide
No. 2 Bleach Plant, Chlorine dioxide
Chlorine Dioxide Plant, including the Cooling Tower, Chlorine dioxide
1.3 Offsite Consequence Analysis
Gulf States performed an offsite consequence analysis to estimate the potential for accidental releases of the regulated substance that could affect the public or the environment. We evaluated both a worst-case release scenario and more reasonable (but still highly unlikely) alternative release scenario for chlorine dioxide.
Gulf States does not expect the worst-case release scenario to ever occur. This scenario is designed to estimate the maximum possible area that could be affected by a release at our facility, but is not not a realistic scenario. The alternative release scenario was selected to help the LEPC improve the community emergency response plan. An a
lternative release scenario represents a release that might occur at a facility like Gulf States.
The main objective for 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). For exposures to 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. Some people who are particularly susceptible to the substance released could be incapacitated. At distances less than the endpoint distance, the effects would be more severe; at distances greater than the endpoint distance, the effects would be less severe.
The following information summarizes the offsite consequence analyses performed by Gulf States.
1.3.1 Worst-case release scenario for chlorine dioxide
The worst-case release sc
enario for chlorine dioxide is a failure of a chlorine dioxide storage tank. Although the storage tank is quite large (132,000 gallons), it contains about 99% water and 1% chlorine dioxide. Even so, when we assume that (1) the storage tank is full and (2) all the chlorine dioxide is released over 10 minutes, the predicted endpoint distance to the toxic endpoint (1 ppm) is more than 25 miles from the storage tank. The U.S. Census indicates that 44,000 people live within this distance from the chlorine dioxide stoarge tanks. There are two environmental receptors within this distance: the Demopolis Wildlife Management Area and the Kinterbish Wildlife Management Area. There are also many types of public receptors such as schools, residences, hospitals, public recreational areas, one large jail in the Linden area, and several commercial industrial areas.
1.3.2 Alternative release scenarios for chlorine dioxide
The alternative release scenario for chlorine dioxide is a rupture of an exp
ansion joint in an 8-inch pipe designed to transfer chlorine dioxide solution from the storage tank to the bleaching process. This scenario assumes that the solution is released through the hole for 10 minutes before workers detect the release and isolate the line. The released chlorine dioxide solution forms a pool and the chlorine dioxide evaporates from the pool, forming a vapor cloud. The area around the chlorine dioxide storage tank is graded so that any spill is directed toward the mill's process sewer system; helping reduce chlorine dioxide in the area. The maximum distance to the toxic endpoint is 1.2 miles. The U.S. Census indicates that 62 people live within this distance from the railcars. No environmental receptors are located within this distance; however, there are public receptors within 1.2 miles, including the Tombigbee River (used for recreational purposes), several residences, the McClain of Alabama facility, and one church (the Moscow Providence Church).
Accidental Release Prevention Program and Chemical-specific Prevention Steps
Gulf States has always believed that safety is the highest priority. Beginning in 1992, Gulf States formalized this belief into a prevention program that complies with the OSHA process safety management (PSM) prevention program. For Gulf States, the prevention program requirements for EPA's RMP rule are nearly identical to the PSM rule. The following sections briefly describe the elements of Gulf States' prevention program that address the RMP rule prevention program requirements.
1.4.1 Gulf States' Prevention Program
The Gulf States accident prevention program, consists of the following 12 elements:
1. Process Safety Information. Gulf States maintains a variety of technical documents, including an emergency preparedness plan, to help ensure that our employees and local emergency responders are knowledgeable about the hazards associated with our facility. These documents address (1) physical properties
of the hazardous substances we handle, (2) operating parameters for our equipment, and (3) design basis and configuration for our equipment. Gulf States ensures that this process safety information is available to all our employees.
2. Process Hazard Analysis. Gulf States performs and periodically updates process hazard analyses (PHAs) of our covered processes to help identify process hazards and generate recommendations that might improve the safe operation of the process. A team consisting of personnel with engineering and process operating experience and a leader with PHA experience is assembled to analyze the hazards of our processes. The team painstakingly addresses the potential hazards associated with each piece of equipment, down to the smallest pipe, that carries hazardous material. The PHA team then prepares a written report describing the results of the analysis, including a list of recommendations. Responsibility to resolve the recommendations is assigned to unit per
sonnel and, when appropriate, changes to enhance the safety of the process are implemented. PHAs are revisited every five years to ensure they are current.
3. Operating Procedures. Gulf States' process engineers, operators, 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 are used to train employees and 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
4. Training. Gulf States trains workers to safely and effectively perform their assigned tasks. Our
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 training material before the employee can begin or resume work in the process.
5. Mechanical Integrity. Gulf States maintains mechanical process equipment to help prevent equipment failures that could endanger workers, the public, or the environment. Our 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 strict design standards required for service in our processes.
6. Management of Change. We evaluate and specifically approve all proposed ch
anges to chemicals, equipment, and procedures to help ensure that the change does not negatively affect safe operations. All changes other than replacement-in-kind (e.g., replacing a valve with an identical valve) must be confirmed through the full management of change program. This helps 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. Gulf States recognizes that new or newly modified processes are historically more likely to be involved in accidental releases. Therefore, we perform safety reviews of new or modified processes before placing them into service to help ensure their safe operation. This review confirms that:
? construction and equipment are in accordance with design specifications
? adequate safety, operating, maintenance, and emergency procedures are in place
mployee 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
8. Compliance Audit. One of the cornerstones of an effective prevention program is a regular, thorough assessment. We audit our covered processes every three years to be certain our prevention program is effectively addressing the safety issues of Gulf States operations. We assemble an audit team that includes personnel knowledgeable in the PSM and RMP rules and in our process designs, and this team evaluates whether the prevention program satisfies the requirements of these two rules and whether it 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.
9. Incident Investigation. Gulf States investigates all incidents that could re
asonably have resulted in a serious injury to personnel, the public, or the environment so that similar accidents can be prevented in the future. We train our 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. Gulf States has a written employee participation program for covered processes to help ensure that the safety concerns of our workers are addressed. We encourage 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 our accidental release prevention program.
11. Hot Work Permits. Gulf States has a hot work permit program to control spark- or flame-producing activities that could res
ult in fires or explosions in our facility. We reviewed OSHA's fire prevention and protection requirements 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 appropriate supervisor reviews the completed form before work can begin. Training in the use of the Hot Work Permit Form is included in our safe work practices orientation.
12. Contractors. We have a program in place to help ensure that contractor activities at our facility are performed in a safe manner. This program reviews the safety record of all our contractors to help ensure that we hire only contractors who can safely perform the desired job tasks. We explain to the contract supervisors the hazards of the processes on which they and their employees will work, our safe work practices, and our emergency response procedures. We require that the Contractor Supervisors train each of their employees who will wo
rk at the facility before that worker begins work at our facility. Gulf States periodically reviews contractors' training documents and work performance to help ensure that safe practices are followed.
1.4.3 Chemical-specific Prevention Steps
In addition to the required prevention program elements, Gulf States has implemented safety features specific to the hazardous substances used at our facility. The following paragraphs describe some of these safety features.
Chlorine Dioxide. Chlorine dioxide is produced at the Gulf States facility and stored in a mixture that is 99% water and 1% chlorine dioxide. This avoids the necessity of transporting large quantities of the solution, and storing this substance as a solution helps to reduce the consequences of a release. Any release of chlorine dioxide that does occur will quickly wash into the process sewer, where it will be mixed, diluted, and treated by a scrubber.
1.5 Five-Year Accident History
Gulf States has compiled a five-year
accident history that indicates continuous safe operation over the last five years. All five recorded accidental releases resulted in exposing one or more employees to a toxic vapor. Although several of these employees became ill as a result of this exposure, no long-term impairment has resulted. The number of accidental releases has generally been decreasing over the last five years.
Year - Number of Reported Accidents - Substance Released - Consequences
1996 - 1 Chlorine & 2 Chlorine dioxide - Chlorine and Chlorine dioxide inhalation - four employees injured
1997 - None
1998 - 1 Chlorine dioxide - Chlorine dioxide inhalation - two employees injured
1999 - 2 - Chlorine and Chlorine dioxide inhalation - three contractors injured
2000 - None
1.6 Emergency Response Programs
Gulf States 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 LEP
C about accidental releases that could reasonably result in offsite consequences
? providing proper first aid and emergency medical treatment for accidental human exposure to hazardous substances
? 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
At Gulf States, maintenance teams are trained to respond to emergency situations and the maintenance superintendent is in charge of coordinating emergency actions. All Gulf States personnel are trained in evacuation procedures. The Director of Technical and Environmental Services is responsible for apprising the Marengo County LEPC of the emergency situation, and the LEPC is responsible for notifying the public, if necessary.
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 a copy of the plan has been provided to the LEPC and the fire department. Gulf States maintains a regular dialogue with local emergency planners.