Westvaco Corporation, Chemical Division Carbon - Executive Summary |
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CONTENTS 1.0 WESTVACO CHEMICAL DIVISION ACCIDEN-TAL RELEASE AND EMERGENCY RESPONSE POLICIES 1-1 1.1 Control of Hazardous Materials 1-1 1.2 Emergency Response Coordination with the Westvaco Bleached Board Division 1-2 1.3 Risk Management System 1-3 2.0 PROCESS AND SUBSTANCE SUBJECT TO 40 CFR PART 68 2-1 3.0 RELEASE SCENARIOS 3-1 3.1 Worst-Case Release for Toxic Substances 3-1 3.1.1 Dispersion Conditions 3-2 3.1.2 Interpretation 3-2 3.1.3 Modeling Method 3-3 3.1.4 Public and Environmental Receptors 3-4 3.2 Alternative Release for Toxic Substances 3-4 3.2.1 Dispersion Conditions 3-4 3.2.2 Interpretation 3-5 3.2.3 Modeling Method 3-5 3.2.4 Public Receptors 3-5 4.0 ACCIDENT PREVENTION 4-1 5.0 FIVE-YEAR ACCIDENT HISTORY 5-1 6.0 EMERGENCY RESPONSE PROGRAM 6-1 7.0 PLANNED CHANGES TO IMPROVE SAFETY 7-1 RISK MANAGEMENT PLAN PURSUANT TO 40 CFR 68(G) Westvaco Chemical Division Carbon Department, Covington, Virginia Introd uction Westvaco Chemical Division owns and operates a plant that manufactures activated carbon in Covington, Virginia, which is subject to U.S. Environmental Protection Agency (EPA) regulations governing Accidental Release Prevention (ARP) Requirements: Risk Management Programs under Section 112(r) of the Clean Air Act (40 CFR Part 68). This Risk Management Plan (RMP) has been developed in accordance with the requirements specified under 40 CFR Part 68, Subpart G. The RMP certifies that Westvaco Chemical Division has instituted a Risk Management Program at the Covington, Virginia, facility that is in compliance with U.S. EPA ARP requirements. The RMP includes an Executive Summary and Data Elements following the format published by U.S. EPA when the rule was promulgated on June 20, 1996. This document identifies the applicable corporate policies and risk management systems, including comprehensive accident prevention and emergency response programs. In addition, this RMP identifi es a set of worst case and alternative release scenarios, the potential off-site consequences of those releases, and the facility's five year accidental release history. This RMP certifies that prevention and emergency response programs are in place so as to minimize risks to workers and the potentially affected public. RISK MANAGEMENT PLAN PURSUANT TO 40 CFR 68(G) EXECUTIVE SUMMARY REVISION LOG Revision Number Date 0 June 1, 1999 Westvaco Corporation Chemical Division Covington Carbon Plant Covington, VA RMP Executive Summary 1.0 WESTVACO CHEMICAL DIVISION ACCIDEN-TAL RELEASE AND EMERGENCY RESPONSE POLICIES 1.1 Control of Hazardous Materials Westvaco strives to conduct its business in strict confor-mity with all applicable laws and in a safe and respon-sible manner. Westvaco has always placed the very highest priority on the safety and health of its employees and members of the c ommunities in which it operates. This policy applies to the Covington, Virginia facility and to all the locations of Westvaco and its subsidiaries and to all materials which may be hazardous to health, whether solid, liquid or gaseous. It is the responsibility of the Chemical Division Manager and the Corporate Research Director to ensure that each location within their respective authority is in full compliance with the provisions of this policy. Management at each company facility, by utilizing effective process safety management, should be knowledgeable on a current basis as to materials which are present and aware of the possible risk associated with their handling, storage, use, discharge, spill, disposal, or release. Material Safety Data Sheets (MSDS) are to be maintained as required and reviewed on a current basis. Westvaco facilities are to be designed, constructed, inspected, maintained and operated in a manner so as to minimize the risk of exposure to employees and the pu blic at large to hazardous materials and in conformity with all governmental regulations and corporate guidelines. Each facility should maintain inspection records and up-to-date procedures to ensure that control of hazardous materials is maintained at all times. The procedures are to include provisions for the periodic testing, review, and update of the emergency response programs. Changes in protective technology should be monitored, and when found to be more effective, the need for change should be promptly considered. In addition, at a minimum of every three years, each affected facility will undergo a comprehensive process safety management compliance review. The functions of environmental protection, property conservation and safety and health are to be coordinated at each facility so that the most effective and practical protection of employees, public and environment from hazardous materials is achieved and regulatory reporting requirements are met. All employees should b e trained and periodically retrained in a manner appropriate to their possible exposure to materials which are considered hazardous. This should include methods for detection of the presence or release of hazardous materials, the physical and health hazards of the materials, and methods for protecting themselves and co-workers. The information provided by MSDS should be reviewed with employees on a current basis. Each location should coordinate its safety and emergency response program with local community emergency response officials to insure safe, effective, and swift response to emergencies in the workplace. This includes forthrightly disclosing to the community, through its emergency response officials, facts regarding the hazards and risks in operating the facilities, the prevention techniques in place, and assistance in devising the most appropriate and effective protection plans for the community and the plant. Each Division Manager, and the Corporate Property Conservation Manager, is to be specifically assured in writing of compliance with the Control of Hazardous Materials Policy in his division on an annual basis. The Corporate Property Conservation Manager will provide annual written confirmation of compliance to the Chairman and the President. Each location is to promptly investigate, correct, and report in writing to the Division Manager and the Corporate Property Conservation Manager all incidents involving hazardous materials having caused, or having the potential for causing, injury or loss. Clear understanding and careful observance of this policy throughout the organization is of great importance to Westvaco, its employees, and the public. While line management has the primary responsibility for providing safe conditions and for creating a climate in which the whole organization shares in the concern for both employee and community safety and health, each member of the organization plays a key role in assuring success. 1.2 Emergency Resp onse Coordination with the Westvaco Bleached Board Division Westvaco Corporation operates two separate industrial operations at a site in Covington, Virginia: a pulp and paper mill operated by the Westvaco Bleached Board Division and an activated carbon plant operated by the Chemical Division. The two facilities, located on adjacent properties, belong to different SIC codes and are under separate management. Each facility has greater than threshold amounts of substances regulated under 40 CFR Part 68 promulgated under Section 112(r) of the Clean Air Act. A separate Risk Management Plan (RMP) is submitted for each facility, because each has an independent risk management program, but utilizes the same emergency response staff and a single emergency management system. The two facilities also share information on hazardous chemicals and coordinate their emergency response plans. Thus, the Westvaco Chemical Division facility has a program in place to notify the neighboring Bleached B oard Division facility in the event of an accidental release. Because it would not be necessary for the Local Emergency Planning Committee (LEPC) or other on-site emergency responders to coordinate intra-company emergency response, it is not appropriate to identify the Bleached Board Division as an off-site receptor in the hazards assessment portion of the RMP. Thus, in estimating the potential for off-site impacts associated with worst-case and alternative releases at the Chemical Division facility, the boundary of the combined Westvaco Corporation Covington site is considered. 1.3 Risk Management System Westvaco Chemical Division has developed a management system to implement and maintain compliance with the Accidental Release Prevention (ARP) and related chemical safety and emergency response programs. This management system identifies lines of responsibility for the entire program and each of its key elements. This management system is coordinated with the system developed by Westvaco's neighboring Bleached Board Division. 1-4 2.0 PROCESS AND SUBSTANCE SUBJECT TO 40 CFR PART 68 The Westvaco Carbon Plant produces activated carbon which is a microcrystalline form of carbon with internal porosity and a large specific surface area. This carbon is typically used for the purification of gas and liquid streams. Activated carbon is used widely in industrial processes for the recovery and recycling of volatile organic compounds, and can also be used as a purifying filter for breathing air. All automobiles produced in the U.S. since the early 1970s and most foreign-built automobiles are equipped with an emissions control system which utilizes activated carbon to adsorb gasoline emissions. These emissions would otherwise be released to the atmosphere and contribute to the formation of ozone, a health hazard. Activated carbon is also used in the treatment of drinking water to remove toxic and other organic material. As with most production processes, the activated carbon production process uses several different chemicals. One of these chemicals is anhydrous ammonia, a chemical most commonly used on crops to provide nitrogen for plant growth. Anhydrous ammonia is a colorless liquid or gas which is readily detectable by its extremely pungent odor. In sufficient concentrations, anhydrous ammonia is an eye, skin, and/or inhalation irritant. For this reason, anhydrous ammonia is regulated under the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Standard at 29 CFR Part 1910.119 and the EPA risk management rule at 40 CFR Part 68. Anhydrous ammonia is delivered to the site via tank truck and stored in a diked above-ground "bullet tank" with a 18,000 gallon (92,900 lb) capacity. For ammonia processes, the threshold quantity for coverage under 40 CFR Part 68 is 10,000 lb. Precautionary measures are taken to ensure the safe passage of the ammonia delivery truck through the Westvaco property to the unloading site and isolation during unloading. This is accomplished by escorting the ammonia truck from the plant entrance gate to the ammonia storage area with a Westvaco vehicle equipped with warning flashers. Once in the unloading area, Westvaco staff isolate the area from vehicular and foot traffic by engaging security gates until the transfer operation is complete. Westvaco staff and the truck operator also provide surveillance to the transfer operation. The Westvaco facility is manned 24 hours a day whenever ammonia is stored, transferred, or handled on-site. The EPA risk management regulation identifies three levels of requirements. Program Level 1 is applicable to a process for which it can be demonstrated that no public receptors (e.g., residences, parks and recreation areas, commer-cial or industrial facilities, hospitals) would be affected by a worst-case release. Otherwise, 40 CFR Part 68 requires that processes, such as those present at the Westvaco Chemical Divisio n facility, belonging to NAICS code of 325188 (all other basic inorganic chemical manufacturing) be subject to Program 3 requirements. The Carbon Plant is also subject to OSHA PSM, which became effective in 1993 and with which the Westvaco Chemical Division facility has been in continuing compliance. The Westvaco Accidental Release Prevention Program elements are adopted directly from the compliance program for the PSM standard, consistent with the Level 3 RMP Program requirements for this Westvaco facility under 40 CFR Part 68. 3.0 RELEASE SCENARIOS For the purposes of developing and maintaining adequate RMP's, the EPA has defined in its governing rules and guidance a series of modeling methods and assumptions which are to be utilized as administrative guides for planning purposes. In order to standardize and simplify to a practical level the many factors that can potentially occur in an accidental release situation, some of these assumptions may not take into account the a vailable preventive measures or mitigation methods that would diminish or even eliminate the implied risks that are suggested by "worst-case" analyses. For that reason, both the results for the standardized "worst case" defined by the EPA methods and an alternative case, which is believed by Westvaco to more realistically represent situations that may possibly, but rarely, occur within the lifetime of the facility, are presented and described. The actual incident history for this facility over the last five years has been reviewed. No accident has resulted in reportable on-site injury, off-site injury, emergency response, or damage to property or the environment However, to ensure that mitigation measures and emergency response plans are appropriate, potential release scenarios are considered. Thus, the sections of the RMP which discuss both the worst case and the alternative case, believed to be somewhat more probable, are meant to provide the data necessary to develop and evalua te possible improvements in the overall safety provided by the programs which constitute the Westvaco ARP program. 3.1 Worst-Case Release for Toxic Substances As defined by 40 CFR Part 68, a worst-case release for a gas is a 10-minute ground-level release of the entire tank contents, taking into account passive and administrative controls that limit the maximum quantity. The worst-case release scenario for the Westvaco Chemical Division facility is a gaseous release from the anhydrous ammonia storage tank dispersed under stable meteorological conditions (see section 3.1.1, below). The nominal capacity of the ammonia storage tank is 18,000 gallons. Passive controls limit the quantity of ammonia in the tank to 15,480 gallons (80,000 lb). The passive control device consists of a liquid return line to the delivery truck that prohibits filling above 86% of tank capacity. 3.1.1 Dispersion Conditions EPA requires that worst-case analyses be conducted using stability class F and 1.5 m/sec wind speed. Analysis of one year of meteorological data from the 10 m level of an instrumented tower maintained by Westvaco indicates that these dispersion conditions occur about 20% of the time. Meteorologists have defined six "atmospheric stability classes," A through F, each representing a decreasing degree of turbulence in the atmosphere. The most turbulent condition is stability A, which is associated with light winds and very strong solar heating. Stabilities B and C are characterized by progressively weaker solar heating and stronger winds. Neutral or D stability occurs when winds are strong or when the sky is overcast. At night the earth's surface cools, causing the lower atmosphere to stabilize and become less turbulent. Stability E (moderately stable) corresponds to partly cloudy conditions with moderate winds. Stability class F (very stable) represents a very low level of turbulence due to overnight radiational cooling and weak winds. To describe the aero dynamic surface roughness for modeling purposes, EPA has established surface roughness categories based on land-use type. 'Urban' surface roughness indicates areas where there are many obstacles, such as industrial buildings or trees. 'Rural' indicates that there are no buildings in the immediate vicinity of a facility and that the terrain is generally flat and unobstructed. The Westvaco Carbon Plant and immediate vicinity are clearly urban in nature with areas comprised of large structures, while the area surrounding is more rural, containing small buildings, parking lots, and open land. In order to report the most conservative 'distance to toxic endpoint' estimates, Westvaco has elected to model the worst-case and alternative release scenarios assuming 'rural' surface conditions. However, it should be noted that under actual conditions, plume dispersion would be enhanced by the 'urban' type surfaces located near the facility, and result in shorter distances to toxic endpoint. 3 .1.2 Interpretation The risk management rule dictates that pressurized gases must be assumed to be released in the vapor state, regardless of whether an actual release would be in the gaseous or liquefied form. Thus, while the dike under the anhydrous ammonia tank provides mitigation, it cannot be considered to have an effect on the worst-case release rate. Hypothetical events that could result in a release of comparable magnitude as this worst-case release include a complete break of the 3" line at the bottom of the ammonia storage tank or a sudden failure of the tank, perhaps due to a major earthquake. In the event of such a sudden release, however, it is likely that both gaseous and liquefied ammonia will be released simultaneously, and liquid ammonia would likely be contained in the dike. The dike would therefore substantially reduce the rate of release to the air and associated off-site migration. The dike would also isolate a liquefied ammonia release from the sewer lines to the wastewater treatment system and serve to protect any nearby workers from the cryogenic liquid. The possibility of a worst-case type of scenario is extremely remote and virtually prohibited, given the design of the ammonia storage system and inspection and maintenance measures that Westvaco has taken as part of its accident prevention program. Two factors indicate that this worst-case analysis may overstate the hazard associated with an ammonia release. First, given that the worst case is a 10-minute release with a 10-minute averaging time, the extent of the emergency response planning zone is somewhat overes-timated because the toxic endpoint used to calculate a distance is appropriate to exposures up to an hour (see section 3.1.3, below). Another factor is that under the stable light wind conditions that are used in the worst-case assessment, the direction of transport is governed by the high terrain in the area. 3.1.3 Modeling Method Worst-case dispersion modeling to determine the distance to toxic endpoint was conducted using the U.S. EPA's RMP*COMP (Version 1.06) software. RMP*COMP implements the consequence analysis calculations set forth in the EPA's Off-site Consequence Analysis Guidance (OCAG). Only passive mitigation (e.g., dikes, enclosures) and administrative controls may be accounted for in the evaluation. As seen in Figure 3-1, the resulting emergency response planning zone is defined by a circle centered at the ammonia storage area with a radius equal to 5.1 miles (27,000 ft). Beyond this distance, a release of ammonia would not be expected to pose a significant hazard to the public. The toxic endpoint chosen by the EPA for ammonia is 200 parts per million (ppm). This level is the Emergency Response Planning Guideline, Level 2 (ERPG-2), which was developed by the American Industrial Hygiene As-sociation. An ERPG-2 is "the maximum airborne con-centration below which it is believed that nearly all individuals could be exposed for up to 1 hr without experiencing or developing irreversible or other serious health effects, or symptoms which could impair an individual's ability to take protective action." Within the emergency planning zone for ammonia, the outdoor concentration at a stationary receptor, averaged over 10 minutes, could exceed 200 ppm. Because this exposure level assumes a stationary receptor, it does not account for evasive or protective action. Actions that could reduce or eliminate exposure to ammonia include avoiding the plume transport path, relocating beyond the planning zone, or seeking shelter in a building. 3.1.4 Public and Environmental Receptors The worst-case planning zone encompasses a resident population of approximately 11,000, based on the 1990 Federal Census, and estimated by applying EPA's LANDVIEW II program. Public receptors were identified using 1:24,000 scale U.S.G.S maps, which were supplemented with a local map of the Covington area (Mapquest, GeoSystems Global Corp. , 1997). The potential worst-case planning zone includes schools, public recreation areas and a commercial area (shopping center). The George Washington National Forest which surrounds the Covington area is the only environmental receptor identified. However most of the National Forest is in elevated terrain that would not be reached by an ammonia release during stable conditions. Since the resulting planning zone predicted for the worst-case toxic release potentially affects public receptors, the regulated process at the Westvaco Chemical Division facility is subject to Program 3 requirements. 3.2 Alternative Release for Toxic Substances The alternative release examined for anhydrous ammonia corresponds to an accident occurring during transfer from a tanker truck. A review of the ammonia receipt log from October 1992 to October 1997 found approximately 90 ammonia transfers. The average delivery size over this period was 30,000 lb. Liquefied ammonia could spill into a genera lly unconfined area outside of the dike, due to a hose rupture or coupling failure. The rate has been estimated to be equal to the normal transfer rate of 150 gallons/min (774 lb/min). This corresponds to a hose rupture of approximately 1.7 inches in diameter. Release of liquefied gas to the air was conservatively assumed to be at the same rate as the spill because the portion that does not initially flash to a gas upon release would rapidly spread out into a shallow pool until the spill rate equaled the evaporation rate. The spill is assumed to continue for 10 minutes before the truck operator or Westvaco personnel is able to activate the remote emergency shut-off valve. 3.2.1 Dispersion Conditions The alternative scenario was simulated using meteorological conditions that are typical of the Covington, Virginia area. Data based on 30 years of meteorological measurements for the area indicate an average high temperature of 68 degrees F (20 degrees C). As discussed below, the alternative ammonia release that was selected would occur during ammonia delivery operations, which take place during the daytime hours. Therefore, weather conditions between 6 a.m. and 6 p.m. were analyzed. According to meteorological measurements by Westvaco at the Covington site, the most common conditions of atmospheric turbulence during the day are neutral to unstable. A neutral condition gives less dispersion than an unstable condition, so neutral stability was selected as a conservative choice for modeling downwind dispersion. EPA suggests meteorological conditions for alternative releases of D stability and a wind speed of 3 m/sec. Stability Class D represents conditions of neutral stability, or moderate atmospheric turbulence. Using on-site data, it was verified that the average wind speed for neutral conditions in Covington is 3 m/sec. The wind rose for the on-site data, based on the year 1989, indicates that the predominant directions of transport are to the south, southeast and northeast. 3.2.2 Interpretation Alternative releases are intended to represent releases that generally have a greater likelihood than the worst-case release and that occur during typical rather than worst-case meteorological conditions. Unlike the worst-case release, alternative releases can account for both passive and active mitigation systems. In accordance with EPA Guidance, the alternative release does not necessarily represent the type of release that the PSM hazard analysis and/or accident history indicate is the most likely to occur, but rather a release that is somewhat more likely than the worst-case release and that generally still has the potential to affect off-site receptors. 3.2.3 Modeling Method Alternative dispersion modeling to determine the distance to toxic endpoint was conducted using the U.S. EPA's RMP*COMP (Version 1.06) software. As discussed in Section 3.1.1, the modeling was performed using the conservative assumption of rural surf ace roughness. The resulting planning zone is defined by a circle centered at the ammonia storage area with a radius equal to the distance to toxic endpoint (0.5 miles, 2,600 ft). 3.2.4 Public Receptors The residential population within a circular area of this radius centered at the point of release is estimated to be approximately 220. No environmental receptors would be affected. 4.0 ACCIDENT PREVENTION The processes subject to the Risk Management Regulation are also subject to the OSHA PSM Standard with which the Westvaco Chemical Division facility is in compliance. PSM governs the same processes and regulated substances at the site that are subject to 40 CFR Part 68. As such, because Westvaco Chemical Division has complied with PSM, it is also in compliance with the Prevention Program requirements of 40 CFR Part 68. Westvaco has in-place specific operational programs to address PSM/RMP Prevention Program requirements. Descriptions of the following programs reside on -site at the Carbon Plant. o Preventive Maintenance Program o Tank Integrity Program o Regular Process Hazards Analysis (HAZOP Studies) and Pre-Startup Safety Checks for Changes as Part of Management of Change Program o Incident Review, Diagnosis and Correction (to Prevent Recurrence) o Written Operating Procedures o Operator Training and Qualification Program 5.0 FIVE-YEAR ACCIDENT HISTORY In conjunction with the current ARP and PSM programs in place at the Westvaco Chemical facilities, there is a standard management practice that requires immediate internal reporting of unusual events, including those in which any abnormal emission of regulated chemicals is observed or suspected. The incident information is reviewed by supervisory staff and a determination is made as to whether a reportable quantity on any chemical listed as requiring reports to regulatory authorities is involved. If so, the appropriate authorities are promptly notified. During the past 5 yea rs (June 1994 to June 1999), there has been no accident involving any RMP regulated substance that qualifies for reporting under 40 CFR Part 68. This means that no accident has resulted in reportable on-site injury, off-site injury, off-site evacuation or sheltering in place, or damage to property or the environment. 6.0 EMERGENCY RESPONSE PROGRAM It is the policy of the Westvaco Chemical Division, Carbon Department to place the highest priority on employee safety and health and on protection of the community from all plant-induced environmental conditions. An emergency response plan has been developed to provide protection by providing prompt action to control an emergency and minimize the amount of toxic material released and lessen or eliminate the hazards to employees and the community. Experience has shown that proper planning and an organized approach will reduce the effects of emergency events. Prompt internal and external communications, emergency equipment, and tra ined personnel are the key ingredients of this plan. Westvaco's policy provides for external communications with local and county-wide response agencies. The Westvaco Chemical and Bleached Board Divisions in Covington, Virginia have in-place detailed coordinated emergency plans to protect both the plant operation-al integrity and the safety of its workers and neighbors. The provisions of Emergency Preparedness Plan for the Carbon Plant address chemical releases as well as a wide range of natural and man-made events, including fire, explosion, utility failures, earthquakes and extreme meteorological events. Procedures are established to quickly classify events to expedite effective emergency shutdown. Emergency response is coordinated by the Plant Protection and Rescue Squad who will designate an emergency command center, direct area (on-site) evacuation, notify appropriate emergency response teams, evacuate the area, plant, or facility as appropriate utilizing facility-wide alarm system, summon emergency medical service and provide first aid. The Chemical Division coordinates off-site emergency notification through the Bleached Board Division. 7.0 PLANNED CHANGES TO IMPROVE SAFETY Westvaco Chemical Division, under the recent RMP program, as well as its existing PSM and earlier Superfund Amendments and Reauthorization Act (SARA) Title III Community Right-to-Know Act compliance programs, has organized its manageme-nt system to effectively address all hazards and potential risks. Both the advanced planning aspects of process design, operating procedures, emergency prepared-ness, and the operational elements of system maintenance, safe operating practices and ongoing personnel training are necessary to support a continual improvement in facility safety. These programs are all documented so that needed information about the safe handling of all chemicals present at the facility is continuously available to employees, and can be readily interpreted by emer gency response team staff and the Site Emergency Coordinator when questions arise from public safety officials on potential risks to the community. All of these features of the RMP and the integrated risk management program at this site lead to operations that are safe today, but will be even safer tomorrow. |