Champion - Quinnesec Mill - Executive Summary |
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The Executive Summary has been attached in an electronic file named EXECSUM.TXT. Please note, Champion may have left certain data fields blank if the information requested is not applicable or if the subject activity pre-dated the effective date of the requirement. All data in the fields identified as required fields have been completed. RISK MANAGEMENT PLAN CHAMPION INTERNATIONAL CORPORATION QUINNESEC, MICHIGAN 1. Executive Summary Champion International Corporation (CHAMPION) is committed to operating in a manner that is safe for CHAMPION workers, the public, and the environment. As a demonstration of that commitment, CHAMPION 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: "CHAMPION 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 Champion International Corporation. 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." CHAMPION believes that following these policies is the responsibility of every employee. CHAMPION 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 Operati ons Manager. As part of this commitment, CHAMPION 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 CHAMPION 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 CHAMPION. 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 CHAMPION. The risk management program at CHAMPION 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 fi ve years associated with the use of 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 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 CHAMPION helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety program at CHAMPION. In fact, CHAMPION 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. CHAMPION limits the use of hazardous substances. Before using a hazardous substance a t CHAMPION, less hazardous alternatives are considered. Part of CHAMPION'S RMP compliance philosophy has been the reduction of the use of hazardous substances covered under this regulation. When a hazardous substance is used, CHAMPION considers the potential for this substance to adversely affect CHAMPION workers, the public, and the environment and takes steps to prevent any such effects. CHAMPION works to prevents releases of the hazardous substances used at the facility. When a hazardous substance is used at CHAMPION, 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. CHAMPION limits damage from a release, if such a release occurs. CHAMPION trains workers to respond to an accidental release, reducing the consequences of a release if it occurs. In addition, CHAMPION works with the local fire department and with the local em ergency planning committee (LEPC) to help ensure that injuries and/or environmental damage will not occur if a release does occur. The safety program at CHAMPION 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 CHAMPION that are required by the RMP rule. 1.1 Accidental Release Prevention and Emergency Response Policies CHAMPION 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. CHAMPION 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 CHAMPION; and programs to evaluate the hazards at CHAMPION. In the event of an accidental release, CHAMPION controls and co ntains the release in a manner that will be safe for workers and will help limit injury to the public or the environment. CHAMPION provides response training to CHAMPION personnel, designates an emergency response coordinator to oversee response activities, and coordinates response efforts with the local fire department. The Qunnesec 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, CHAMPION established a management system headed by the mill's Operations Manager to oversee safety-related activities. 1.2 CHAMPION and Regulated Substances The Quinnesec 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, CHAMPION handles regulated substances in sufficient quantities to be covered by the RMP rule, as shown in the following list of RMP-covered processes at the Quinnesec Mill. Process Chlorine - Raw Water Program Level 3 Regulated Substance Chlorine Maximum Process Quantity 16,000 pounds Largest Single Vessel 2,000 pounds Process Chlorine - Clearwell Program Level 3 Regulated Substance Chlorine Maximum Process Quantity 16,000 pounds Largest Single Vessel 2,000 pounds Process Chlorine Dioxide System * Program Level 3 Regulated Substance Chlorine Dioxide Maximum Process Quantity 20,000 pounds Largest Single Vessel 10,000 pounds * 1.2% w/w water solution of chlorine dioxide 1.3 Offsite Consequence Analysis CHAMPION 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. CHAMPION does not expect a worst-case release scenario to ever occur. 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 represents a release that (1) might occur at a facility like Champion's and (2) would result in the greatest potential offsite consequences if the release occurred. While Champion 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. Champion has conducted the offsite consequence analysis for the worst-case release scenario using the EPA's guidance document which includ es 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 toxic endpoint for a chemical of concern. Champion 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. Champion believes such data can be valuable to local emergency planning agencies for alternative release scenario s 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 the plume at discreet time intervals. These data have been provided to the Dickinson County LEPC to assist them in planning for any actions that should be taken if, the unlikely event of an accident should occur at the Quinnesec Mill. Champion 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 fro m 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 the scrubber control system on the chlorine dioxide generator. TRACE was used to evaluate the release of chlorine dioxide due to a leak in a chlorine dioxide transfer pipe. The same model was also used to evaluate the potential off-site impact of a potential release of chlorine due to a leak in a valve on a 2000 lb. chlorine storage container. 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 curbing, exit velocity, release diamet er, 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: 3.0 meters/second * Stability: D * Temperature: 60 deg. F. 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, such as chlorine or chlorine dioxide, most peopl e 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 CHAMPION. These requirements are: * one worst-case release scenario for each Program 1 process (the Quinnesec Mill does not have any processes meeting the Program 1 definition) * one worst-case release scenario for the class of toxic substances in Program 3 processes (i.e., one scenario representing the Chlorine Dioxide process) * one alternative release scenario for each of the toxic substances in a Program 3 process (i.e. one scenario representing the Chlorine Dioxide process, one scenario for the Chlorine - Clearwell process and one scenario for the Chlorine - R aw Water process) * one worst-case and one alternative release scenario for the class of flammable substances in Program 2 and Program 3 processes (the Quinnesec Mill does not have any process chemicals meeting the flammable substance definition) The following information summarizes the offsite consequence analysis performed by CHAMPION. 1.3.1 Program 3 Processes - Toxic Substances The worst-case release scenario for toxic substances is the instantaneous release of the entire contents of a 100,000 gal (417 ton) chlorine dioxide solution (1.2% chlorine dioxide - by weight) storage tank in the Chlorine Dioxide System. The solution is assumed to flow beyond containment curbing and sewers and form a pool of chlorine dioxide solution, which evaporates and forms a vapor cloud. The actual quantity of chlorine dioxide in the solution (10,000 lbs.) would be released to atmosphere over a 60 minute period. The scenario results in off-site impacts to both public and environmental receptors. The alternative release scenario for the Chlorine Dioxide System is a valve or flange leak from the piping system. Operators would be notified of a release by chlorine dioxide monitors located throughout the process area. Local drains and sewers would limit the extent of spread of the water solution, limiting the vaporization of chlorine dioxide. Approximately 300 lbs. of chlorine dioxide would be released from the time the incident began, until emergency responders would stop the leak 30 minutes later. While the event results in off-site impact, there are no public or environmental receptors located within this distance. The alternative release scenario for the Chlorine - Clearwell process is shearing off a valve on a 1-ton chlorine container. Operators are immediately notified of a release by chlorine monitors located in the process area. Approximately 250 lbs. of chlorine would be released from the time the incident began, until emergency responders would stop the leak 30 minute s later. The off-site impact would affect public receptors, but does not affect any environmental receptors. The alternative release scenario for the Chlorine - Raw Water process, located 1 1/2 miles south of the main mill complex, would be the same as above, except for the off-site impact. While the event results in off-site impact, there are no public or environmental receptors located within this distance. 1.4 Accidental Release Prevention Program and Chemical-specific Prevention The Quinnesec Mill has always focused on ways to prevent accidental releases of hazardous substances. Beginning in 1992, CHAMPION formally implemented the 14 elements of OSHA's Process Safety Management (PSM) prevention program. In 1996, the EPA RMP rule established Program 2 and Program 3 prevention requirements, CHAMPION has implemented the Program 3 prevention requirements, which are as follows: Program 3 - 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, and is the most rigorous prevention program. It has been established for the Chlorine - Raw Water, Chlorine - Clearwell and Chlorine Dioxide System. The following sections briefly describe the elements of CHAMPION'S prevention program that address the EPA RMP rule prevention program requirements. 1.4.1 Program 3 Prevention Program The Quinnesec Mill Program 3 prevention program, which applies to Chlorine - Raw Water, Chlorine - Clearwell and Chlorine Dioxide System, consists of the following 12 elements: 1. Process Safety Information: CHAMPION 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 process equipment. Material safe ty data sheets (MSDSs) document the properties of hazardous substances handled at Champion, including regulated substances in covered processes. Information on the technology and engineering design of the covered processes include the operating parameters and the design basis and configuration of the process equipment. 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 Quinnesec 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 haz ards of the process. CHAMPION primarily uses the hazard and operability (HAZOP) technique, supplemented with 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: CHAMPION 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. CHAMPION personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operations, normal shutdown, emergency shutdo wn, 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 CHAMPION 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 th e operators are reviewed, and changes to the training program are implemented, as appropriate. 5. Mechanical Integrity: CHAMPION maintains 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 CHAMPION 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: CHAMPION 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: CHAMPION audits covered processes to be certain that the CHAMPION prevention program is effectively addressing the safety issues for the covered processes. CHAMPION 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: CHAMPION investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment so that similar incidents can be prevented. CHAMPION 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 Quinnesec Mill developed a written employee participation program for covered processes to help ensure that CHAMPION 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, as well as access to information on the covered processes. 11. Hot Work Permits: CHAMPION 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 Quinnesec Mill. CHAMPION 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 performing hot wor k are required to have an approved permit prior to beginning their work. Training in the use of the Hot Work Permit Form is included in the CHAMPION safe work practices orientation. 12. Contractors: CHAMPION has established Contractor Guidelines for Safety and Health to outline expectations related to contractor work, at the Quinnesec Mill including work on the covered processes. The program reviews the safety record of all contractors to help ensure that CHAMPION only hires contractors who can safely perform the desired job tasks. CHAMPION explains to the contract supervisors the hazards of the process on which they and their employees will work, CHAMPION safe work practices, and CHAMPION emergency response procedures. CHAMPION requires that the contractor supervisors also train each of their employees prior to beginning their work on a covered process. CHAMPION periodically reviews contractors' training documents and work performance to help ensure that safe practices are fol lowed. 1.4.2 Program 2 Prevention Program The Quinnesec Mill has no processes which qualify for the Program 2 Prevention Program. 1.4.3 Chemical-specific Prevention Steps In addition to the required prevention program elements, CHAMPION has implemented safety features specific to the hazardous substances used at the Quinnesec Mill. The following paragraphs describe some of these safety features. Chlorine Processes: Chlorine is supplied to the Quinnesec Mill in DOT-approved 1-ton containers. Chlorine is fed through a short length of piping to an eductor, where it is safely absorbed into process water. This vacuum operated system provides a high degree of reliability and safety. Our chlorine systems are located indoors within isolated room areas, which further reduces the potential for a chlorine release impacting the surrounding area. Chlorine detectors and alarms are provided in areas where chlorine could be present if a release occurs. These alarms sound at the chlorin e room areas, and also on operator control displays, which are constantly monitored to help ensure quick response. Chlorine Dioxide System: Chlorine dioxide gas is produced in the chlorine dioxide generator and piped to a water absorption column, where a 1.2 wt % chlorine dioxide solution is generated. Chlorine dioxide is produced at the Quinnesec Mill and stored as a dilute water solution to minimize the potential for serious incident or off-site impact. The process is located almost entirely indoors, which further reduces the hazard. Storage tanks are engineered specifically for chlorine dioxide service. Inventory is limited to an 8 hour supply for bleaching. The process uses an advanced control system, with emergency shutdowns, to ensure safe operation. Containment sewers and curbing are provided to minimize the extent of potential leaks. Detectors and alarms provide continuous monitoring for chlorine dioxide in the event of a release, providing early detection and helping to ensure quick response if an incident were to occur. 1.5 Five-Year Accident History CHAMPION has completed a review for incidents occurring in the five-year period prior to the submittal date for the regulation. During the five year period prior to June, 1999, there have been no incidents involving the regulated processes which have resulted in on-site or off-site impacts. The Quinnesec Mill is committed to maintaining this high level of safety performance. 1.6 Emergency Response Programs CHAMPION has established a written emergency response program to help safely respond to accidental releases of hazardous substances. The emergency response plan includes procedures for: * clear identification of communication, roles and responsibilities during an emergency event. * informing the LEPC 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 substa nces at CHAMPION * controlling and containing accidental releases of hazardous substances, including the use of specially trained Hazardous Material Response Teams and emergency response equipment * inspecting and maintaining emergency response equipment * reviewing and updating the emergency response plan The Quinnesec Mill maintains an emergency response team trained in these emergency response procedures. All CHAMPION personnel are trained in evacuation procedures. CHAMPION 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 and local fire departments. CHAMPION maintains a regular dialogue with the local fire officials and provides response information, as appropriate. 1.7 Planned Changes to Improve Safety The Quinnesec Mill constantly strives to improve th e safety of the regulated processes by following recommended safe practices, soliciting safety suggestions from employees, conducting hazard analysis studies and investigating process incidents. The following changes either have been recently completed or are planned to improve safety: * Elimination of anhydrous ammonia from the mill, resulting in approximately 80,000 lbs of hazardous chemical being removed from the mill site. * Upgrading the chlorine dioxide alarm system to improve worker safety and provide quicker response in the unlikely event of a leak. * Continual evaluation to find cost-effective and technically feasible alternatives to chlorine gas for water treatment. * Process modifications to further reduce the use of chlorine dioxide in the bleaching process. * Potential participation in Michigan's Voluntary Protection Program (VPP). 1.8 RMP Data Reporting to EPA The chlorine dioxide system is reported on the basis of it being a single process. This system includes th e chlorine dioxide generator, storage tanks, and distribution piping. However it is considered one process because the components are interconnected. While two separate HAZOP studies were performed on this process, the elements of the prevention programs are the same. Therefore the decision was made to report it as one process covered by one prevention program. |