Rayonier Fernandina Beach Dissolving Sulfite Mill - Executive Summary |
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Table of Contents 1.0 EXECUTIVE SUMMARY 1.1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 1.2 STATIONARY SOURCE AND REGULATED SUBSTANCES 1.3 OFFSITE CONSEQUENCE ANALYSIS 1.3.1 Worst Case Release Scenario - Chlorine Dioxide 1.3.2 Alternative Release Scenario - Ammonia (anhydrous) 1.3.3 Alternative Release Scenario - Chlorine 1.3.4 Alternative Release Scenario - Chlorine Dioxide 1.3.5 Alternative Release Scenario - Sulfur Dioxide (anhydrous) 1.4 PREVENTION PROGRAM - PROGRAM 3 1.4.1 Process Safety Information 1.4.2 Process Hazard Review 1.4.3 Operating Procedures 1.4.4 Training 1.4.5 Mechanical Integrity 1.4.6 Management of Change 1.4.7 Pre-Startup Review 1.4.8 Compliance Audits 1.4.9 Incident Investigation 1.4.10 Emplo yee Participation 1.4.11 Hot Work Permit 1.4.12 Contractors 1.5 FIVE-YEAR ACCIDENT HISTORY 1.6 EMERGENCY RESPONSE PROGRAM 1.7 PLANNED CHANGES TO IMPROVE SAFETY 2.0 CERTIFICATION 3.0 REGISTRATION 1.0 EXECUTIVE SUMMARY 1.1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Rayonier's Fernandina Specialty Pulp Products Mill 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. Rayonier's Fernandina Specialty Pulp Products Mill 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; and programs to evaluate possible hazards. In the event of an accidental release, Rayonier's Fernandina Specialty Pulp Products Mill implements policies and procedures to p rotect employees and prevent injury to the public and the environment. Rayonier's Fernandina Specialty Pulp Products Mill provides "First Responder" training to responsible personnel, designates an emergency response coordinator to oversee response activities, and coordinates response efforts with the Nassau County Emergency Management team and the local fire department. 1.2 STATIONARY SOURCE AND REGULATED SUBSTANCES Rayonier's Fernandina Beach, FL Specialty Pulp Products Mill is an ammonia-base dissolving sulfite pulp mill, which produces approximately 150,000 tons of highly purified specialty pulp annually. To manufacture these quality pulps to specific customer specifications, Rayonier uses four chemicals subject the Risk Management Plan (RMP). The Fernandina Mill is classified as Source Industrial Code (SIC) 2611 and is consequently subject to the Program Level 3 requirements of RMP. These same four substances are also subject to Process Safety Management (PSM) regulation s and are listed below: 1. Ammonia (anhydrous) 2. Chlorine 3. Chlorine dioxide 4. Sulfur dioxide (anhydrous) Ammonia and sulfur dioxide are used to make up cooking acid for pulps. Chlorine and chlorine dioxide are used as bleaching chemicals in the process. 1.3 OFFSITE CONSEQUENCE ANALYSIS The Rayonier's Fernandina Specialty Pulp Products Mill has four Program Level 3 processes for which offsite consequence analysis (OCA) evaluations were performed: ammonia (anhydrous), chlorine, chlorine dioxide, and sulfur dioxide (anhydrous). These were conducted to evaluate the consequences of a release of one of these chemicals. The OCA includes estimating the distances to the toxic end point and the populations affected in the event of an accidental release of a regulated toxic substance. A toxic end point is defined as the concentration of a substance in the air that a person can be exposed to for one hour without impairing their ability to take corrective action. The toxic end po int for each substance is determined by the US EPA. The only processes subject to RMP at the Fernandina facility involve toxic substances as listed previously. The RMP rule requires one worst case scenario for the toxic substance category and one alternative release scenario for each toxic subject to the rule. Rayonier's Fernandina Specialty Pulp Products Mill evaluated all four toxic chemicals for their potential for offsite consequences using EPA's RMP Comp and population estimates based on US Census data as calculated using LANDVIEW III (software developed by the US Dept of Commerce, the Economics and Statistics Admin., and the Bureau of the Census.). A summary of these results is provided below. Chemical Toxic Endpoint Worst Case Scenario Alternative Scenario Ammonia (anhydrous) 0.14 (mg/l) 5.0 miles 0.1 miles Chlorine 0.0087 (mg/l) 14.0 miles 0.3 miles Chlorine Dioxide 0.0028 (mg/l) 16.0 miles 0.9 miles Sulfur Dioxide (anhydrous) 0.0078 (mg/l) 13.0 miles 0.3 miles Note: Distances calculated using EPA's RMP Comp (Version 1.06). 1.3.1 Worst Case Release Scenario - Chlorine Dioxide Of the four RMP processes at the Fernandina Mill, the worst case release would be the failure of a 144,000 gallon tank containing 9,609 pounds of chlorine dioxide (ClO2). As defined by the RMP rule, this scenario would have the entire contents of the tank being released to the environment in 10 minutes. Under this scenario, no administrative or mitigation controls have been considered for the Fernandina Mill. Although the scenario is highly improbable and almost physically impossible, RMP Comp (Version 1.06) predicts that a release under these conditions would travel 16 miles from its origin in the pulping area of the mill before it would reach its toxic endpoint of 0.0028 mg/l. 1.3.2 Alternative Release Scenario - Ammonia (anhydrous) The alternative release scenario for ammonia (anhydrous) would be a rupture of a hose during the unloading of an ammonia railcar in the pulp mill area. In this scenario ammonia is released through the hose for 30 minutes before the flow is automatically shutoff by the excess flow valve (active mitigation) which limits the flow to 250 lbs/min. The released ammonia forms a pool and evaporates, forming a vapor cloud. The maximum distance to the toxic endpoint of 0.14 mg/l is 0.1 mile. This distance will not reach offsite. 1.3.3 Alternative Release Scenario - Chlorine The alternative release scenario for chlorine would be a rupture in a hose during the unloading of a chlorine railcar in the pulp mill area. In this scenario chlorine i s released through the hose for 30 minutes before the flow is automatically shutoff by the excess flow valve (active mitigation) which limits the flow to 250 lbs/min. The released chlorine forms a pool and evaporates, forming a vapor cloud. The maximum distance to the toxic endpoint of 0.0087 mg/l is 0.3 mile. Several houses are located within this distance from the railcar, with a total population of about 20 people; no environmental receptors are within this distance. 1.3.4 Alternative Release Scenario - Chlorine Dioxide The alternative release scenario for chlorine dioxide would be the failure of a gasket (1/8 inch thick) connected to an 8-inch diameter pipe exiting the No. 2 ClO2 Storage Tank (1.3 wt % ClO2) in the pulp mill area. In this scenario the solution is released through the hole for 30 minutes before the flow is detected and isolated by the workers; the released ClO2 solution forms a pool in a diked area; and the ClO2 evaporates from the pool and forms a vapor cl oud. The maximum distance to the toxic endpoint of 0.0028 mg/l is 0.9 mile. Several houses are located within this distance from the storage tank, with a total population of about 423 people; no environmental receptors are within this distance. 1.3.5 Alternative Release Scenario - Sulfur Dioxide (anhydrous) The alternative release scenario for sulfur dioxide (anhydrous) would be a rupture of a hose during the unloading of a sulfur dioxide railcar in the pulp mill area. In this scenario sulfur dioxide is released through the hose for 30 minutes before the flow is automatically shutoff by the excess flow valve (active mitigation) which limits the flow to 250 lbs/min. The released sulfur dioxide forms a pool and evaporates, forming a vapor cloud. The maximum distance to the toxic endpoint of 0.0078 mg/l is 0.3 mile. Several houses are located within this distance from the railcar, with a total population of about 36 people; no environmental receptors are within this distance. 1.4 PREVENTION PROGRAM - PROGRAM 3 1.4.1 Process Safety Information Rayonier's Fernandina Specialty Pulp Products Mill has compiled written Process Safety Information (PSI) before conducting any process hazard analysis as required by the Process Safety Management (PSM) standard. The PSM standard requirements for PSI are identical to those required by the RMP in 40 CFR 68.65. This compilation of written process safety information enables Rayonier and the employees involved in operating the processes to identify and understand the possible hazards posed by those processes involving toxic substances. PSI includes information pertaining to the hazards of the toxic substances used in the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process. PSI has been collected and updated for Rayonier's four RMP process systems: ammonia (anhydrous), chlorine, chlorine dioxide, and sulfur dioxide. Material Data Safety Shee ts (MSDS), block flow diagrams, piping and instrumentation diagrams (P & ID's), and equipment information are stored in the PSM Information books and equipment files. 1.4.2 Process Hazard Review Rayonier's Fernandina Specialty Pulp Products Mill has performed an initial Process Hazard Analyses (PHA) on all four covered processes as well as periodic analyses as required by PSM. The PSM standard requirements for PHA's are identical to those required by the RMP in 40 CFR 68.67. The initial PHA's are required to be completed by June 21,1999 and revalidated at least every five years. Initial PHA's have been done for Rayonier's four RMP process systems: ammonia (anhydrous), chlorine, chlorine dioxide, and sulfur dioxide. PSM required initial PHAs to be completed by May 1997. Revalidation is scheduled to start in 1999. Of the methods commonly used for analysis or reviews, the "HAZOP" and "Checklist" methods are typically used at the Fernandina mill. PHA's identify, evaluate and control hazards involved the process. Rayonier also has a system in place to address any findings and recommendations. This system ensures that recommendations are: 1. Resolved in a timely manner, 2. Documented, and 3. Communicated to the affected employees. 1.4.3 Operating Procedures Rayonier's Fernandina Specialty Pulp Products Mill has developed, implemented, and maintains clearly written detailed procedures for safely operating and maintaining a process during all operating modes. In addition to operating procedures, safe work practices have been developed and implemented for the control of hazards and include hot work, confined space entry, opening process equipment or piping, lockout/tagout, and control over the entrance into a stationary source. These safe work procedures are in place and are reviewed and revised as needed, but at least on an annual basis. 1.4.4 Training Each employee at Rayonier's Fernandina Specialty Pulp Products Mill involved in operati ng a covered process has been trained to operate it safely and understands the training. They also have been trained in the safety and health hazards of each process as required by 40 CFR 68.71 and evaluated for understanding of the training by a written test and/or on the job training. Refresher training is provided every three years or more often if necessary. Rayonier's Fernandina Specialty Pulp Products Mill also gathers input from the employees involved in operating covered processes to aid in determining the appropriate frequency of refresher training. This input is normally accomplished by the use of surveys and or interviews. 1.4.5 Mechanical Integrity Rayonier's Fernandina Specialty Pulp Products Mill already has a mechanical integrity system in place due to the requirements of PSM. Under the RMP rule 40 CFR 68.73, Rayonier has adopted this mechanical integrity system. The system ensures that the process equipment and instrumentation are designed, constructed, ins talled, and maintained to minimize the risk of hazardous releases. It includes written procedures, training, inspection, and testing, correcting system deficiencies and quality assurance. These tasks are discussed further in the PSM Mechanical Integrity manual. 1.4.6 Management of Change A Management of Change (MOC) system is in place at Rayonier to prevent changes in the process and supporting equipment from introducing unacceptable hazards to workers. This MOC system has written procedures for managing changes, which need to be made to a PSM/RMP covered process. The procedures require review prior to the change with a special emphasis on safety and training of employees and contractors. Process Safety Information (PSI) and procedures must be updated when a change is made and is addressed with this MOC system. 1.4.7 Pre-Startup Review Prior to starting up any new covered process or modified covered process, Rayonier performs a pre-startup safety review when the modifi cation is significant enough to require a change in the process safety information. This review ensures all requirements are met before the introduction of any highly hazardous chemical into a new or modified process. This review is done before startup just in case safety items have not been verified. This final pre-startup review aids in making sure the changes in the system are ready for startup. 1.4.8 Compliance Audits At least every three years, Rayonier evaluates the effectiveness of the PSM system. Audits are performed to determine that the system complies with the provisions in the PSM standard and that the systems procedures and practices are adequate and are being followed. PSM audits are retained until all action items are completed and two subsequent audits are performed. Rayonier's Fernandina Specialty Pulp Products Mill performed a compliance audit in June 1997. 1.4.9 Incident Investigation Rayonier investigates every incident, which results in or could reasonably have resulted in a catastrophic release of a regulated substance. The investigation starts as soon as possible but not later than 48 hours after an incident. The incident report is then retained for five years. 1.4.10 Employee Participation Rayonier has developed a written plan of action regarding the implementation of employee participation in evaluating covered processes. Rayonier consults with and involves employees and their representatives to obtain feedback to the details of each covered process. This written plan is located in the PSM documentation. Employees participate in PHA's, gathering information, incident investigations, training, written operating procedures, and the other elements as needed. 1.4.11 Hot Work Permit Rayonier issues hot work permits for any hot work operations conducted on or near covered processes. Each permit documents that the fire prevention and protection requirements in 29 CFR 1910.252 (a) have been implemented prior to beginning the hot work operations. They also indicate the date(s) and time authorized for hot work and the identity of the object on which hot work is to be performed. After the hot work job is completed, the area is inspected for any smoldering fire hazards. If none are found, the hot work permit is closed out. Each permit is kept on file until completion of the hot work operations and inspections. 1.4.12 Contractors Rayonier selects contractors who perform maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process by obtaining and evaluating their safety performance and programs. Each contractor is informed of any known hazards related to the contractor's work and the process and any applicable emergency response procedures. Rayonier has implemented safe work practices to control the entrance, presence, and exit of each contractor in covered process areas. Rayonier periodically evaluates the performance of each contractor in fulfilling their obligations. Contractors are obligated to: 1. Assure that each contract employee is trained in the work practices necessary to safely perform his/her job; 2. Assure that each contract employee is instructed in the known potential fire, explosion, or toxic release hazards related to his/her job and the process, and all applicable emergency response procedures; 3. Document that each contract employee has received and understood the required training; 4. Assure that each contract employee follows safety rules and safe work practices; 5. Advise Rayonier of any unique hazards presented by the contractor's work or of any hazards found. 1.5 FIVE-YEAR ACCIDENT HISTORY Rayonier keeps thorough records for all significant accidental chemical releases which occur at the Fernandina facility. RMP defines accidental releases from covered process as those that resulted in deaths, injuries, or significant property damage on-site, or known off-site consequences such as d eath, injury, evacuation, sheltering in place, property damage, or environmental damage. For the five year reporting period, Rayonier's Fernandina Specialty Pulp Products Mill had no offsite consequences. There was one release per the rule definition which occurred July 22, 1996 at 11:30 pm for approximately 15 minutes when a 1/2 inch chlorine line developed a small leak releasing approximately one pound of chlorine. While there was no offsite impact there was an employee who required medical attention. The wind direction carried the chlorine release to a production area. An employee working in the area recognized that there had been a chlorine release and immediately exited the area. The employee notified an operator who activated the chlorine emergency shut-off valve. Activating the emergency shut-off valve mitigated the release. Two workers were exposed; one was sent to the local hospital for precautionary reasons. The employee was treated and released the same evening. T he other employee was administered oxygen at our first aid office on-site and did not require medical attention. Following the incident, a formal investigation was conducted and corrective measures were implemented to improve the process. The root cause was identified and corrective actions were taken to prevent similar releases from occurring in the future. This was accomplished by covering the chlorine line with a protective coating and setting up the line for an annual inspection for corrosion during the maintenance shut down. Additional corrective actions included replacement of chlorine piping on a routine frequency and establishing a protective coating program. No significant releases have occurred for any of the other three RMP chemicals (chlorine dioxide, sulfur dioxide, and ammonia) over the last five years. 1.6 EMERGENCY RESPONSE PROGRAM Rayonier has a written emergency response plan for the Fernandina facility to aid in safely responding to accidental releases o f hazardous chemicals. This emergency response plan includes procedures for: 1. Training responsible employees on procedures for being the "First Responder" in the event of a release. 2. Providing proper first aid and emergency medical treatment to treat accidental human exposure to hazardous substances. 3. Controlling and containing accidental releases of hazardous substances, including the use of emergency response equipment. 4. Informing the local Nassau County Emergency Management team, which is responsible for responding to accidental releases, which could reasonably result in off site consequences. 5. Procedures for informing the public when necessary. 6. Inspecting and maintaining emergency response equipment. 7. Reviewing and updating the emergency response plan. Rayonier's Fernandina Specialty Pulp Products Mill maintains an emergency response team trained in these emergency response procedures. All personnel are trained in evacuation procedures. Rayonier periodi cally conducts emergency response drills. The written emergency response plan complies with other federal contingency plan regulations [i.e. OSHA regulations 29 CFR 1910.38(a) and 29 CFR 1910.120(a)] and has been communicated to the local emergency response officials. Rayonier's Fernandina Specialty Pulp Products Mill also maintains a regular dialogue with the local fire chief and routinely provides required information. 1.7 PLANNED CHANGES TO IMPROVE SAFETY Rayonier's Fernandina Specialty Pulp Products Mill constantly strives to improve the safety of the workers and the community. There are many systems in place to achieve this goal. Currently, the entire mill is undergoing extensive training for "Behavior Based Safety" (BBS) to improve overall safety performance. This program is entitled "H.A.W.K." (Halting Accidents With Knowledge) and is underway with a steering committee guiding the effort while training each employee. The H.A.W.K. concept is based on changing worker b ehavior by individually conducting observations and providing feedback to other employees as they perform their duties. Incident investigations are also performed to improve safety. These investigations are conducted whenever an incident has the potential to affect the safety of workers. There is also a program to solicit safety suggestions from workers. As a result of these activities, improvements can be achieved. The following is a list of process safety improvements, which are planned or have recently been completed. 1. Rayonier's Fernandina Specialty Pulp Products Mill is currently moving the sulfur dioxide railcar unloading station to a permanent location with a bridge to provide safer access for the trained chemical unloader. 2. Hose specifications for railcar unloading have been reviewed and are being refined to adopt a larger hose. This was done to ensure that there would be enough flow through the hose to utilize the excess flow valve (i.e. the valve will shutdown th e flow when it reaches a specified rate) in the unlikely event that a hose is accidentally severed. Major efforts to improve safety are also underway with Rayonier's "Job Safety Analysis" (JSA) program. The program consists of systematically analyzing jobs from a safety perspective. This is accomplished by identifying all the jobs performed and breaking each job down into the steps taken to complete each task. The potential accidents and hazards of each task are identified and recommendations are then provided on how to prevent these hazards from occurring. Employees participate in this program by providing input on each analysis. The resulting JSA's are used in training each employee on how to do the job safely. 2.0 CERTIFICATION Refer to the attached form. 3.0 REGISTRATION Refer to the attached form. |