International Paper Pine Bluff Mill - Executive Summary
INTERNATIONAL PAPER-PINE BLUFF MILL |
RISK MANAGEMENT PROGRAM
1.0 ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICES
The International Paper-Pine Bluff Mill has a long standing commitment to operating our facility in a manner that is safe for our employees, the public, and the environment. A primary aspect of this commitment is the International Paper-Pine Bluff Mill system to help ensure the safe operation of our processes. Our commitment is also demonstrated by the resources invested in accident prevention, such as considering safety in the design, installation, operation and maintenance of our processes, as well as, extensive training of our operating personnel.
In the event of an accidental release, the International Paper-Pine Bluff Mill has procedures which are designed to control and contain the release in a manner which will be safe for our employees and will help prevent injury to the public and the environment. The International Paper-Pine Bluff Mill's
emergency response personnel receive thorough training in handling accidental releases. An emergency response coordinator has been assigned to oversee response activities and to coordinate response efforts with local emergency agencies. Communications with the Local Emergency Planning Committee (LEPC) have been ongoing throughout the preparation of this plan and policies.
In order to effectively implement these policies, the International Paper-Pine Bluff Mill established a management system headed by the Manager of Environmental, Health and Safety to ensure the proper implementation and effectiveness of our Risk Management Program (RMP).
2.0 INTERNATIONAL PAPER-PINE BLUFF MILL AND REGULATED SUBSTANCES
The International Paper-Pine Bluff Mill, located in Pine Bluff, Arkansas, is primarily involved in the manufacture of high quality coated bleached paper board. To manufacture our products, the International Paper-Pine Bluff Mill utilizes one regulated substance, chlorine dioxide, w
hich is covered by the RMP Rule. The chlorine dioxide used at the International Paper-Pine Bluff Mill, is generated on site, immediately absorbed into water, and then stored in a 0.9% solution. The RMP Rule exempts regulated toxic substances which are stored and used in solutions or mixtures of less than 1.0% by weight. However, the International Paper-Pine Bluff Mill has elected to pursue development of a RMP Plan for chlorine dioxide consistent with the requirements of the General Duty Clause of Section 112(r) of the Clean Air Act.
The regulated use of chlorine dioxide at the International Paper-Pine Bluff Mill is as follows:
Process Description: Chlorine Dioxide System
Program Level: 3
RegulatedSubstance: Chlorine dioxide
Maximum Process Quantity: 45,160 lbs.
3.0 HAZARD ASSESSMENT RESULTS
The International Paper-Pine Bluff Mill performed an offsite consequence analysis to estimate the potential impacts of an accidental release of chlorine dioxide from our pr
ocess. Chlorine dioxide was evaluated for possible worse-case scenarios and alternative release scenarios. It is important to understand that the International Paper-Pine Bluff Mill has invested extensive resources to prevent releases, and the potential for a worse-case release is extremely small. The alternative release scenarios represent a more realistic potential for occurrence and are based on historical data from our process or other similar processes. By identifying these potential releases, the International Paper-Pine Bluff Mill has prepared an extensive program to prevent such an occurrence. This program is discussed in detail in the "Prevention Program" section of this plan.
The primary objective of performing the offsite consequences analysis is to determine the distance at which the public and/or the environment might be affected because of an accidental release. This point is called the endpoint distance. At distances less than the endpoint distance, the effects wou
ld be greater; at distances greater than the endpoint, the effects would be less.
Hazard Assessment - Toxic Substances
The worst-case scenario (WCS) associated with Regulated Toxic Substances is a failure of the mill's 184,494 gallon storage tank of a 0.9% solution of chlorine dioxide and water. The spill is partially contained in secondary containment with the majority of the spill overflowing to form a pool 1 centimeter deep. The chlorine dioxide evaporates from the solution forming a toxic cloud which reaches offsite endpoints and public receptors. Although the International Paper-Pine Bluff Mill has numerous controls to prevent such releases and to manage their consequences, no credit for administrative controls or active mitigation measures was taken into account in evaluating this scenario.
An alternative release scenario (ARS) for chlorine dioxide is a rupture of a six inch line that carries 0.9% chlorine dioxide solution to the storage tanks. The chlorine dioxide is rele
ased at a rate of 500 gallons per minute for 60 minutes. A pool is formed on the ground and the chlorine dioxide evaporates to form a toxic cloud. The toxic endpoint for the toxic cloud reaches just beyond the International Paper-Pine Bluff Mill property boundaries. No public or environmental receptors are impacted.
A second alternative release scenario (ARS) for chlorine dioxide is a release of 0.9% chlorine dioxide solution from a storage tank that fills up the secondary containment volume to 80%. The total volume of released solution is 6,499 gallons and the secondary containment limits the surface area of the spill to 724 ft2. The chlorine dioxide evaporates from the released material forming a toxic cloud. As with the first ARS, the toxic endpoint would not reach public or environmental receptors.
4.0 ACCIDENTAL RELEASE PREVENTION PROGRAM PROGRAM 3
The International Paper-Pine Bluff Mill Chlorine Dioxide System and other processes at the facility are covered by the OSHA P
rocess Safety Management standard. The requirements of the OSHA Process Safety Management standard are nearly identical to the RMP Rule Program 3 Prevention Program requirements. The Prevention Program for the Chlorine Dioxide System is well developed and was in place prior to the implementation of the RMP Rule.
It should also be noted that International Paper-Pine Bluff Mill received the designation of OSHA Star Facility in the fall of 1998. This designation can only be achieved by voluntarily inviting OSHA into your facility to evaluate all aspects of the safety program, including Process Safety Management. The OSHA Star designation is a clear indication of the company's commitment to preventing injuries and other incidents which may impact the employees, the public, and the environment.
The Chlorine Dioxide System Prevention Program consists of the following twelve elements.
4.1 Process Safety Information
The International Paper-Pine Bluff Mill maintains a variety of technica
l documents that help ensure the safe operation of our processes. These documents address:
* physical properties of hazardous substances handled,
* chemical properties and associated hazards of those substances,
* operating parameters and limitation(s) of the process equipment,
* design basis and configuration of the equipment, and
* specific chemical inventories.
The International Paper-Pine Bluff Mill ensures that the process safety information is available to all International Paper-Pine Bluff Mill employees, the Local Emergency Planning Committee (LEPC), and the local fire department. The Emergency Response Coordinator is responsible for maintaining and updating this information, as needed.
Chemical specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by other technical information specific for these chemicals. Continuous attention is give
n to revisions and updates on the hazards of chlorine dioxide and other chemicals used in our processes. Information regarding toxicity, environmental impacts, corrosion concerns, inadvertent mixing hazards, and other safety and health concerns are addressed and communicated to the appropriate parties.
The International Paper-Pine Bluff Mill also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes:
* materials of construction,
* design pressures,
* temperature ratings,
* electrical ratings,
* flow limits,
* block flow diagrams,
* consequences of deviation from operating limits,
* safety systems,
* applicable design codes and standards,
* process chemistry, and
* design basis for relief and ventilation systems.
When information was not available for design documents, it was developed through special project committees or during the Process Hazard Analyses (PHAs) of the Chlorine Dioxide Syst
em. Many of the operating parameters are included in the operating procedures to aid in the safe and proper operation of the process. These documents are used to:
* train employees
* perform Process Hazard Analyses (PHAs), and
* help maintain the equipment.
All the above mentioned information, in combination with written procedures and trained personnel, provide 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 Chlorine Dioxide System are not compromised.
4.2 Process Hazard Analysis
The International Paper-Pine Bluff Mill performs and periodically updates process hazard analyses (PHAs) of the Chlorine Dioxide System to help identify process hazards and generate recommendations that might improve the safe operation of the process. Within this program, the Chlorine Dioxide System is systematically examined to identify hazards and ensure that adequate controls are in
place to manage these hazards.
To perform the PHAs, International Paper-Pine Bluff Mill primarily uses the HAZOP technique, supplemented with checklists. The PHAs are conducted using a team of people with experience in engineering and Chlorine Dioxide System operation and a leader with experience in process hazard analysis techniques. This team identifies and evaluates hazards of the process as well as accident prevention and/or mitigation measures, when appropriate. The team then prepares a written report describing the results of the analysis, including a list of recommendations ranked according to relative risk ratings assigned by the team. Responsibility to resolve the recommendations is assigned to the Manager of Pulp and is tracked through completion. 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 Internationa
l Paper-Pine Bluff Mill periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the Chlorine Dioxide System is no longer in operation. The results and findings of these updates are documented and retained. The team findings are forwarded to the Manager of Pulp for consideration, and the final resolution of the findings is documented and retained.
4.3 Operating Procedures
International Paper-Pine Bluff Mill engineers, operators, and supervisors work together to develop and maintain written operating procedures to define how tasks related to the Chlorine Dioxide System operation should be safely performed. These written procedures address various modes of process operations, such as:
* unit startup,
* normal operations,
* temporary operations,
* emergency shutdown,
* normal shutdown, and
* initial startup of a new process.
The written operating procedures include:
* steps for safely conducting process tasks,
* applicable process safety information, such as safe operating limits and consequences of process deviations, and
* safety and health considerations, such as chemical hazards, personal protective equipment requirements, and action(s) to take in the event of an exposure to a hazardous substance.
The International Paper-Pine Bluff Mill trains workers to safely and effectively perform their assigned tasks. The International Paper-Pine Bluff Mill training program includes both initial and refresher training that covers:
* a general overview of the Chlorine Dioxide System,
* the properties and hazards of the substances in the process, and
* a detailed review of the process operating procedures and safe work practices.
In addition to the above mentioned classroom training, each operator is required to work for a period of time with an experienced operator until clear understanding of the operating procedures is demonstrated.
Refresher training is conducted annually as part of the International Paper-Pine Bluff Mill's ongoing safety training effort.
4.5 Mechanical Integrity
The International Paper-Pine Bluff Mill maintains the mechanical integrity of Chlorine Dioxide System equipment to help prevent failures that could endanger workers, the public, or the environment. The International Paper-Pine Bluff Mill mechanical integrity program includes:
* an inspection and testing program to help identify equipment deterioration and damage before the equipment fails,
* a quality assurance program to help ensure that the new and replacement equipment meet the design standards required for service in our process,
* procedures for safe work practices such as lockout/tagout, hot work, confined space entry and line or equipment opening,
* training of maintenance personnel, and
* documentation of maintenance activities.
4.6 Management of Change
The International Paper-Pine Bluff Mill has a comprehensive program
to manage changes to processes. Under this program, all proposed changes to chemicals, equipment, and procedures for the Chlorine Dioxide System must be evaluated and approved to help ensure the change does not negatively affect safe operations. 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, and procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided with any necessary training related to the change.
4.7 Pre-startup Review
The International Paper-Pine Bluff Mill performs a safety review of all new or modified processes prior to their being placed into service to ensure that these processes have been prepared to operate safely. This review is designed to confirm:
* construction and equipment are in acco
rdance with design specifications,
* adequate safety, operating, maintenance, and emergency procedures are in place,
* employee training has been completed, and
* for covered processes, a PHA has been performed for new processes and management of change requirements have been completed for modified processes.
A pre-startup review team uses checklists to verify all aspects of readiness. The review involves field verification of the construction elements and serves as a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.
4.8 Compliance Audit
The International Paper-Pine Bluff Mill conducts periodic audits of the Chlorine Dioxide System to ensure the International Paper-Pine Bluff Mill Prevention Program has been effectively implemented and addresses the safety issues of our operations. Compliance audits are conducted at least every three years by a team of hourly and management personnel from the Pine Bluff Mil
l, corporate health and safety consultants, and Process Safety Management sister site auditors who are knowledgeable of the RMP Rule and the Chlorine Dioxide Process. The team evaluates the International Paper-Pine Bluff Mill Prevention Program and other aspects of the International Paper-Pine Bluff Mill RMP. The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the Prevention Program are implemented. The International Paper-Pine Bluff Mill maintains records of at least the last two audits conducted.
4.9 Incident Investigation
The International Paper-Pine Bluff Mill promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent recurrence of the incident or a similar incident. The results of the investigat
ion are documented, recommendations are resolved, and appropriate process enhancements are implemented.
4.10 Employee Participation
The International Paper-Pine Bluff Mill developed a written employee participation program for the Chlorine Dioxide System and other aspects of our operations to ensure that the safety concerns are addressed. The International Paper-Pine Bluff Mill encourages the active participation of our employees in the Prevention Program for all processes and tasks at our facility. Employees are consulted on and informed of all aspects of the International Paper-Pine Bluff Mill RMP and participate on PHA and Compliance Audit teams.
4.11 Hot Work Permits
The International Paper-Pine Bluff Mill established a Hot Work Permit program to control spark or flame producing activities that could result in fires or explosions in the processes at our facility. The International Paper-Pine Bluff Mill utilizes a Hot Work Permit form designed after the OSHA fire prevention
and protection requirements found in 29 CFR 1910.252(a). Personnel who are to perform the Hot Work are required to complete the form which is reviewed by the area supervisor. The Form must be approved before work can proceed. Training in the use of the Hot Work Permit form is provided to all affected personnel.
The International Paper-Pine Bluff Mill established a program to help ensure that contractors who are used to supplement the workforce during periods of increased maintenance or construction conduct their work in a safe manner. Under the program, the record of all contractors is reviewed to ensure that International Paper-Pine Bluff Mill hires contractors who can safely perform work on or near covered process equipment. Our program ensures that contractors:
* perform their work in a safe manner,
* have the appropriate knowledge and skills,
* are aware of the hazards in the workplace,
* understand what to do in the event of an emergency,
* understand and
follow the International Paper-Pine Bluff Mill's safety rules, and
* inform International Paper-Pine Bluff Mill personnel of any hazards identified during their work.
Program efforts are accomplished by providing contractors with:
* a process overview,
* information about safety and health hazards,
* emergency response plan requirements, and
* safe work practices prior to beginning work.
5.0 CHEMICAL SPECIFIC PREVENTION STEPS
In addition to the required prevention program elements, the International Paper-Pine Bluff Mill has implemented safety features specific to the hazardous substances used at our facility. These safety features for Chlorine Dioxide include:
The rate of chlorine dioxide which evaporates from the 0.9% solution is proportional to the temperature - The higher the temperature, the more chlorine dioxide released. A chilled water system has been installed to keep the solution cool and to use for spraying on released material to minimize the evaporation rate.
l chlorine dioxide generators and storage tanks are equipped with explosion hatches which rise to relieve the sudden pressure resulting from an explosion.
6.0 FIVE-YEAR ACCIDENT HISTORY
The International Paper-Pine Bluff Mill has completed a five-year accident history study of the Chlorine Dioxide System process. No incidents have occurred in the Chlorine Dioxide System process which resulted in offsite or onsite injuries or property damage.
7.0 EMERGENCY RESPONSE PROGRAMS
The International Paper-Pine Bluff Mill maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released.
The International Paper-Pine Bluff Mill emergency response program includes procedures for:
* informing the local LEPC, fire department, and public abou
t accidental releases that could reasonably result in offsite consequences,
* providing proper first aid and emergency treatment for accidental human exposure to hazardous substances,
* evacuation plans and methods for accounting for personnel after an evacuation,
* controlling and containing accidental releases of hazardous substances, including the use of emergency response equipment,
* inspecting and maintaining emergency response equipment,
* post-incident cleanup and decontamination requirements, and
* reviewing and updating the emergency response plan.
The International Paper-Pine Bluff Mill maintains an emergency response team trained in these emergency response procedures. Over 100 International Paper-Pine Bluff Mill employees are competently trained as Hazardous Material Technicians. All International Paper-Pine Bluff Mill personnel are trained in evacuation procedures. Drills are conducted periodically to test our evacuation and emergency response procedures. Annual drill
s are conducted with local emergency response agencies to ensure emergency plans are properly coordinated.
8.0 PLANNED CHANGES TO IMPROVE SAFETY
The International Paper-Pine Bluff Mill continuously strives to improve the safety of our processes through incident investigation, Process Hazard Analysis, and employee suggestions. Our engineering and technical personnel stay abreast of technology advancements which may improve the safety of our processes. As a result of these efforts, the International Paper-Pine Bluff Mill has planned the following changes in our processes to improve safety:
Update the Chlorine Dioxide System Process Hazard Analysis. This update may provide information for improving the safety of the process.
Improve maintenance procedures according to our action plan.
To the best of my knowledge, information, and belief formed after reasonable inquiry, the information submitted in this RMP Plan is true, accurate, and complete.
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