Leaf River Pulp Operations - Executive Summary |
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Georgia-Pacific Leaf River Pulp Operations (GP/Leaf River) is committed to operating in a manner that is safe for GP/Leaf River workers, the public, and the environment. As part of this commitment, the company 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's (EPA) Regulation 40 CFR 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a Risk Management Plan (RMPlan) describing the Risk Management Program at Georgia-Pacific in Leaf River. 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 facilit y consists of three elements: 1. 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 ) - see topic 1.3 2. a prevention program to help maintain and safely operate the processes containing more than the threshold quantity of the regulated substances (covered processes) -see topic 1.4 3. an emergency response program to help respond to accidental releases of the regulated substances from the covered processes - see topic 1.6 4. A managrment system that delineates responsibiitty for implementing and maintaining the Risk Management Plan 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 compone nt of the safety program at GP/Leaf River. 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 any injuries and damage that could occur. GP/Leaf River 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. GP/Leaf River 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 will be working with the Local Emergency Planning Commission (LEPC) to help ensure that injuries and/or environmental damage will not occ ur in the event a release does occur. The safety program at GP/Leaf River 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 the facility that are required by the RMP Rule. 1.1 Accidental Release Prevention and Emergency Response Policies GP/Leaf River 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 release in a manner that will be safe for workers and will help prevent injury to the public and/or the environment. GP/Leaf River 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 General Manager /Leaf River Pulp Operations. 1.2 Georgia-Pacific Leaf River Pulp Operations and Our Regulated Substances Georgia-Pacific Leaf River Pulp Operations is a pulp mill primarily involved in the manufacture of bleached market pulp. As part of this manufacturing process, the facility produces and stores Chlorine Dioxide for the use of bleaching pulp. The Chlorine Dioxide Solution System, which includes the generation, storage and distribution of chlorine dioxide, is considered an RMP covered process in Program Level 3. The threshold quantity for Chlorine Diox ide is approximately 414,000 gallons at a 10-gram per liter (1% in solution) strength during peak operations. 1.3 Off Site Consequence Analysis GP/Leaf River 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 a worst-case release scenarios and alternative release case 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 GP /Leaf River and (2) would result in an off site consequence if the release occurred. The alternative release scenarios will help the Local Emergency Planning Committee improve the community emergency response plan. The RMP rule includes specific requirements for the worst-case and alternative release scenarios that must be reported by Georgia-Pacific Leaf River Pulp 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 dioxide) The following information summarizes the off site consequence analysis performed by Georgia-Pacific Leaf River Pulp Operations. 1.3.1 Program Level 3 Process - Chlorine Dioxide (C102) Solution System The worst-case release scenario for the chlorine dioxide system is the rupture of one ClO2 Storage Tank. The ClO2 storage tank contains 207,000 gallons of a weak Chlorine Dioxide solution( 1.0 % by weight). The RMP Rule mandates that for the worst case scenario the analysis assumes loss of the entire contents of the tank in ten minutes. The released chlorine dioxide solution would spread to a minimum depth of 1 centimeter and evaporate to form a vapor cloud. The maximum distance to the toxic end point concentration is approximately 25 miles. The United States Census indicates that 103,000 people live within this distance from the storage tanks; several public receptors are also located within this distance (hospitals, county jails, colleges, several public and private schools, several nursing homes, several churches, several recreation parks, shopping malls and numerous subdivisions). There are also several environmental receptors. The al ternative release scenario for chlorine dioxide is the rupture of a chlorine dioxide solution line located at the discharge side of a Chlorine Dioxide transfer pump header. During normal operations, the pump could pump approximately 1,400 gallons per minute for five minutes before the release might be recognized and isolated. The released chlorine dioxide solution will form a pool a minimum depth of one cm and evaporate to form a vapor cloud. The maximum distance to the toxic end point concentration, based on the EPA Lookup Table approach, is 1.9 miles. The United States Census indicates that approximately 324 people live within this distance. Several public receptors are also located within this distance (Perry County Jail, Perry County Court House and one public elementary school). There are also several environmental receptors. 1.4 Accidental Release Prevention Program Georgia-Pacific Leaf River Pulp 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 to comply with the 14 elements of the Occupational Safety and Health Administration's 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 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. 1.5 Five - Year Accident History- 1.5.1 Chlorine Dioxide There have been no accidental releases of chlorine dioxide in the past five years that have resulted in significant property damage on-site or off-site death, Injury, evacuation, sheltering in place, property damage, or environmental damage. 1.6 Emergency Response Programs Georgia Pacific Leaf River Pulp Operations 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 response organizations and the public about accidental releases that could reasonably result in off site consequences -providing proper first aid and emergency medical 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 the facility personnel are trained in ev acuation 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 and will be 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 them. |