Buckeye Technologies - Memphis Plant - Executive Summary

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Memphis Plant 
Risk Management Plan 
Executive Summary 
1.0    Accidental Release Prevention and Emergency Response Policy 
At Buckeye Technologies Inc.- Memphis Plant, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner.  We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment.  This Executive Summary provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: 
*   A description of the Memphis Plant and use of chlorine, which is regulated by EPA's RMP regulation, 
*   A summary of results from our assessment of the potential off-site consequences from accidental chemical releases, 
*   An overview of our accidental release preve 
ntion programs, 
*   A five-year accident history for accidental releases of chlorine, 
*   An overview of our emergency response programs, 
*   An overview of planned improvements at the Memphis Plant to help prevent accidental chlorine releases from occurring and adversely affecting our employees, the public, and the environment, 
*   The certification that EPA's RMP rule requires us to provide, and, 
*   The detailed information (called data elements) about our risk management program. 
2.0    Stationary Source and Regulated Substances 
Buckeye Technologies Inc., Memphis Plant, produces purified alpha cellulose from cotton fibers (linters).  The Memphis Plant mechanically sizes, cleans, and fluffs raw cotton linters prior to combining with water.  This is then placed in a digester, which uses steam and caustic soda to purify and reduce to a raw slurry.  The raw slurry is then further purified prior to being delivered to one of the finishing (drying) operations.   
In our processes, we  
use the following chemicals that EPA has identified as having the potential to cause significant off-site consequences in the unlikely event of a substantial accidental release: 
Chlorine is stored on-site in a 90-ton rail car.  This chemical is used to brightening the cotton linter cellulose. 
The Memphis Plant does not use any RMP-regulated flammable chemicals. 
Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. 
3.0    Key Offsite Consequence Analysis Scenarios 
EPA's RMP rule requires that Buckeye provide information about the worst-case release scenario and alternative release scenario for the Memphis Plant.  The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: 
e Release Scenario - Chlorine 
The EPA defines worst-case release as the largest quantity of a regulated substance from a vessel failure that results in the greatest distance to a specified endpoint.  By this definition, the extremely unlikely event would be a failure of a 90-ton railcar, releasing its contents over a 10-minute period.  Using EPA's RMP*COMP software, this scenario would result in an estimated exposure distance of 14 miles before the chlorine would no longer pose a significant hazard to the public. 
Alternative Release Scenario - Chlorine 
The alternative scenario for chlorine is a release as a result of a 0.5-inch diameter hole in unloading hose.  Under this scenario, automatic valves are activated which limit the release duration to 30 minutes at 25 pounds/minute (750-pound total release).  The resulting distance to the endpoint is 0.1 mile using EPA's RMP*COMP software.  Administrative controls and mitigation measures are discussed in Sections 4.0 (Accident Preventio 
n Program) and 6.0 (Emergency Response Program.) 
Worst-case and Alternative Release Scenarios - Regulated Flammable Chemicals 
Not applicable since regulated flammable chemicals are not used or stored at the Memphis Plant. 
We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. 
4.0    General Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
Buckeye Technologies takes a systematic, proactive approach to preventing accidental releases of hazardous chemicals.  Our management systems address each of the key features of successful prevention programs including: 
*  Process safety information 
*  Process hazard analysis 
*  Operating procedures 
*  Training 
*  Mechanical integrity 
*  Management of change 
*  Pre-startup review 
*  Compliance audits 
*  Incident investigation 
*  Employee participation 
*  Hot work permit 
*  Contractors 
As part of our  
prevention efforts, we have implemented the following chemical-specific prevention steps for chlorine: 
1.  Chlorine Railcar Staging 
a.  Derailers, chocks, sign placements to prevent accidental movement 
b.  Unique unloading site that is specific for chlorine 
2.  Hose and Gasket Leaks 
a.  Written Mechanical Integrity Program 
b.  Color-coded lines/hoses 
c.  Chlorine sensors that alarm on detection of chlorine vapor 
d.  Video monitoring of railcar continuously 
e.  Excess Flow Check Valves block flow if overpressurized 
f.  Unique fittings prevent improper connections 
g.  Daily Preventive Maintenance Checks of unloading system 
h.  Numerous interlocks and redundant valves 
3.  Training 
a.  Maintenance & Operating personnel trained on procedures specific to chlorine 
   (1) Specific Skill Blocks for advancement 
   (2) Testing & Certification process 
   (3) Work Instructions give specific step-by-step procedures 
   (4) Job Plans developed for non-routine maintenance 
b.  All Plant employees given chlor 
ine awareness training 
c.  Site specific training for Memphis Fire Department Hazardous Materials Team 
4.  Inspections 
a.  Routine inspections by Department of Transportation 
b.  Daily maintenance checks 
c.  Daily operational rounds 
c.  Annual maintenance of entire system 
d.  Annual inspection of tanks 
5.  Emergency Action Plan 
a.  Quarterly drills test notification, response, and evacuation procedures 
b.  Monthly alarm tests 
These individual elements of our prevention program work together to prevent accidental chemical releases.  Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention.  
5.0    Five-year Accident History 
We keep records for all significant accidental chemical releases that occur at our facility.  The following is a brief summary of accidental chemical releases involving mater 
ials covered under EPA's RMP rule during the past five years: 
We have had no releases during the past five years that were significant or meet the reportability criteria under the RMP Program.  We had one release on 8/9/95 of 77 pounds that was reported under CERCLA.  However, this release did not have any significant on-site consequences and was contained on-site. 
For all incidents or non-routine events, we conduct formal incident investigations to identify and correct the root causes. 
6.0    Emergency Response Program 
Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations.  Furthermore, we coordinate our plan with the community emergency response plans, including the Memphis/Shelby County LEPC and the Memphis Fire Department HAZMAT Response Team.  Joint training and drills have been conducted with each of these response agencies.  Our Emergency Action Plan includes procedures for: 
Notifying the Memphis/Shelby County LEPC, Memphis Fire Department, and the surrounding community of an accidental release that could have off-site consequences, 
*   Safely evacuating employees, contractors, and visitors, 
*   Inspecting and maintaining emergency response equipment, 
*   Maintaining a secure perimeter around the release area, and 
*   Treating individuals exposed to released materials. 
7.0    Planned Changes to Improve Safety 
Buckeye has several programs designed to review, audit, and test equipment and procedures.  These programs function to continually assess and improve hazardous systems.  Current initiatives are underway to evaluate and implement appropriate recommendations from our recently completed Process Hazard Analysis. 
8.0    RMP Data Elements 
The following pages present additional information about the Buckeye Technologies Inc., Memphis Plant risk management program that EPA's RMP rule has asked us to provide.  This information is categorized as follows: 

*   Offsite consequence analysis 
*   Five-year accident history 
*   Program 2 prevention program (Omitted; No Process has Program 2 Applicability) 
*   Program 3 prevention program 
*   Emergency response program
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