Erie Mill - Executive Summary |
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INTERNATIONAL PAPER ERIE MILL RISK MANAGEMENT PLAN 6/15/1999 1. EXECUTIVE SUMMARY The International Paper Company's Erie mill is committed to operating in a manner that is safe for our employees, the public, and the environment. As part of this commitment, the Erie mill 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 the mill 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 the Erie mill. 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 the Erie mill. The risk m anagement program at the Erie mill consists of three elements: 1. A hazard assessment to help understand the potential offsite consequences of hypothetical accidental releases and accidents that have occurred during the last five years associated with the use of substances regulated by the RMP rule (regulated substances). 2. A prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered processes). 3. An emergency response program to help respond to an accidental release of regulated substances from covered processes. Information further describing these elements is provided in this RMPlan. Although the risk management program at the Erie mill helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety program at the Erie mill. The mill has a comprehensive safety program in place, establishing many levels of safeguards against a release and the injuries and damage that would accompany such an event. When using a hazardous substance, and while considering the introduction of hazardous chemicals into the workplace, the Erie mill periodically reviews the affect that less hazardous alternatives would have on our process. For example, the mill recently replaced chlorine with bleach in our water treatment process. After substituting chlorine dioxide for chlorine in our pulp bleaching process for EPA "Cluster rule" environmental compliance purposes, the mill recognized the opportunity to remove chlorine from the mill, and the community, altogether. This substitution significantly reduced the potential hazard to our employees, the community, and the environment as a result of our operations. When a hazardous substance is used at the Erie mill, the equipment is carefully designed, built, and operated to reduce the likelihood of an accidental release. Industry and government standards are closely adhered to in th e design, construction, and operation of the equipment. The Erie mill has an emergency response team trained to respond to an accidental release, reducing the consequences of the release if one were to occur. In addition, the mill works with the local fire department and with the local emergency planning committee (LEPC) to help ensure that injuries and/or environmental damage will not occur if a release does occur. The safety program at the Erie mill 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 mill's safety program that are required by the RMP rule. 1.1 Accidental Release Prevention and Emergency Response Policies The Erie mill is committed to the safety of its employees, the public, and the preservation of the environment through the prevention of accidental releases of hazardous substances. Reasonable controls are implemented to prevent foreseeable releases of hazardous su bstances. These controls include training programs for personnel; programs to ensure safety in the design, installation, operation, and maintenance of processes; and programs to evaluate the hazards at the Erie mill. In the event of accidental releases, the Erie mill controls and contains the release in a manner that will be safe for workers and will help prevent injury to the public or the environment. The Erie mill provides response training to mill personnel, designates and emergency response coordinator from our emergency response team, and coordinates response efforts with our local fire department. Response activities have also been discussed with the LEPC. In order to effectively implement these policies, the Erie mill established a management system headed by the EHS manager to oversee safety-related activities. 1.2 The Erie Mill and Regulated Substances The Erie mill is an integrated pulp and paper mill primarily involved in the manufacture of bleached hardwood pulp a nd related finished paper products. As part of this manufacturing process, chlorine dioxide is handled in sufficient quantities to be covered by the RMP rule, as illustrated below. Process Program Level Regulated Substance Process Quantity Chlorine Dioxide 3 Chlorine Dioxide 19,000 lb. Generation and Storage 1.3 Off-site Consequence Analysis The Erie mill performed an offsite consequence analysis (OCA) to estimate the potential for an accidental release of a regulated substance to affect the public or the environment. The OCA consists of evaluating both a worst-case and an alternative-case release scenario. The mill does not expect a worst-case release event to ever occur. The alternative release scenario was selected to help the LEPC improve the community emergency response plan and represents a release that might occur at the Erie mill. The main objective of p erforming the OCA is to determine the distance at which certain affects might occur to the public because of an accidental release (called the endpoint distance). The following effects could occur at the endpoint distance: coughing, wheezing, runny nose, eye and throat irritation, headache, vomiting, bronchitis, and pulmonary edema. 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, most people at the endpoint distance would be able to walk away with out any long-term health consequences, although some short-term consequences 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 the Erie mill. These requirements are: -one worst-case and one alternative relea se scenario representing the mill's program 3 process (Chlorine Dioxide Generation and Storage). 1.3.1 Program 3 Process (Chlorine Dioxide Generation and Storage): The worst-case release scenario is the failure of the 191,000 gal. Chlorine Dioxide storage tank in the Chlorine Dioxide generation and storage process. The released chlorine dioxide evaporates and forms a vapor cloud that could have offsite impacts to receptors such as schools, residences, hospitals, and recreational areas. The alternative release scenario for Chlorine dioxide is a leak or failure in a ClO2 process flange connection. The flange leak location is in the ClO2 tank dike area. This scenario assumes that the solution is released for 30 minutes before workers detect the leak and isolate the line. The released chlorine dioxide forms a pool and the chlorine dioxide evaporates from the pool, forming a vapor cloud that would not have any offsite affects on the mill's near neighbors, though it would impact recrea tional users of Lake Erie in very close proximity to the mill. 1.4 Accidental Release Prevention Program and Chemical-specific Prevention Steps Beginning in 1992, the Erie mill formalized its chemical accident prevention program to comply with the 14 elements of the OSHA process safety management program (PSM). IN 1996, the EPA RMP rule established a prevention program that is essentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environment. The following sections briefly describe the elements of the Erie mill's Program 3 prevention program that address the EPA RMP rule prevention program requirements. 1.4.1 Program 3 Prevention Program The Erie mill's Program 3 Prevention program, which applies to the chlorine dioxide generation and storage process, consists of the following 12 elements: 1. Process Safety Information. The Erie mill maintains a variety of technical documents that are used to help ensure safe operations of the process. These documents address the physical properties of hazardous substances handled at the mill, operating parameters of the equipment at the mill, and the design basis and configuration of the equipment at the mill. The mill ensures that this process safety information is available to all mill employees, the LEPC, and the fire department. Material safety data sheets (MSDSs) document the physical properties of hazardous substances handled at the mill, including regulated substances in covered process. The information available for each hazardous substance typically includes: -toxicity information and permissible exposure limits -physical data -reactivity and corrosivity data -thermal and chemical stability data -hazards of mixing substances in the process MSDSs for hazardous substances handled in each process are available in each department so that operators have ready references to this information. In addition, MSDSs are provided to the LEPC and the fire departmen t for use in helping formulate emergency response plans. The engineering design documents include the operating parameters and the design basis and configuration of the equipment in each covered process. The available information includes: -operating parameters -block flow or simplified process flow diagrams -process chemistry -maximum intended inventories -safe upper and lower limits for parameters such as temperature, pressure, and flow -consequences of deviations from established operating limits -design basis and configuration of equipment -piping and instrument diagrams, including materials of construction -electrical classification -safety systems -applicable design codes and standards -design basis for relief and ventilation systems When important information was not available from the design documents, it was developed through special projects or, in the case of operating parameters, during process hazard analyses. Many of the operating parameters are included in the opera ting procedures to help with the safe operation of the process. These documents are used to train employees, to perform PHAs, and to help maintain the equipment. 2. Process Hazards Analyses. the Erie mill performs and periodically updates process hazards 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 hazards analyses experience is assembled to analyze the hazards of the process. The Erie mill primarily uses the hazard and operability technique (HAZOP), 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 are assigned to unit personnel and, when appropriate, changes to enhance the safety of the process are implemented. 3. Operating Procedures. The Erie mill process engineers, operators, 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 are used to train employees and to serve as reference guides for appropriate actions to take during both normal and upset conditions. Operating procedures include: -steps for safely conducting activities -applicable process safety information -safety and health considerations Erie mill personnel develop and maintain operating procedures that cover all phases of operations. The operating procedures are used both to help in operating the mill process and as a training guide. 4. Training. The Erie mill trains workers to safely and effectively perform their assigned tasks. The training program includes both initial and refresher training that covers a general overview of the process, the properties and hazards of the subs tances in the process, and 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 training material before the employee can resume work in the process. 5. Mechanical Integrity. The Erie mill maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public, or the environment. The mechanical integrity program includes an inspection and testing program to help identify equipment deterioration and damage before the equipment fails, and a quality assurance program to help ensure that new and replacement equipment meets the design standards required for service in Erie mill processes. The program includes: -specifications for inspection and testing of process equipment -specifications for replacement parts and equipment -procedures for inspecting, testing, and maintaining process equipment -procedures for safe wor k practices -training of maintenance personnel -documentation of maintenance activities 6. Management of Change. The Erie mill management of change (MOC) 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 are allowed without completing a full MOC. All other changes must be confirmed through the full MOC 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. The Erie mill performs a safety review of a new or modified process before the process is placed into service to help ensure that the process has been prepared to operate safely. This review confirms that: -cons truction and equipment are in accordance with design specifications -adequate safety, operating, maintenance, and emergency procedures are in place -employee training has been completed -for a covered process, a PHA has been performed if the process is new, or MOC requirements have been completed if an existing process has been modified A pre-startup review checklist is completed to document the review and to ensure that appropriate issues have been addressed. 8. Compliance Audit. International Paper has a corporate audit team that audits covered processes to be certain that the prevention program is effectively addressing the safety issues of mill operations. The audit team is composed of personnel that are knowledgeable in the requirements of the PSM, the RMP, and the process. This team evaluates whether the prevention program satisfies the requirements of PSM and the RMP rule and whether the prevention program is sufficient to ensure safe operation of the process. The result s of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented. 9. Incident Investigation. The Erie mill investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment so that similar accidents can be prevented. The mill 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 enhancements are implemented. 10. Employee Participation. The Erie mill developed a written employee participation program for covered processes to help ensure that the safety concerns of Erie mill workers are addressed. The mill encourages active participation of personnel in the prevention program activities of the facility. Employees are consul ted on and informed about all aspects of the RMP rule prevention program including PHAs and operating procedures. 11. Hot work Permits. The Erie mill established a hot work permit program to control spark or flame-producing activities that could result in fires or explosions in covered processes at the mill. The Erie mill reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252 (a) and created a Hot Work Permit to comply with the requirements. Personnel who are to perform hot work are required to fill out the permit. The form is then reviewed and signed off on by the maintenance job coordinator, a production department representative, and the employee performing the job. Training in the use of the hot work permit system is included in the Erie mill safe work practices orientation. 12. Contractors. The Erie mill established a program to help ensure that contractor activities at the mill are performed in a safe manner. The program reviews the safety reco rd of all contractors to help ensure that the mill only hires contractors who can safely perform the desired job tasks. The mill explains to the contract supervisors the hazards of the process on which they and their employees will work, Erie mill safe work practices, and mill emergency response procedures. The mill requires that contractor supervisors train each of their employees who will work at the mill before that worker begins work at the site. Contractors' training documents and work performance are periodically reviewed to help ensure that safe practices are followed. 1.4.3 Chemical-specific Prevention Steps Chlorine dioxide is produced at the Erie mill and stored as a dilute aqueous solution to avoid the necessity of transporting large quantities of the solution. Chlorine dioxide is produced in the chlorine dioxide generator and piped to an absorber column, where a <1 wt% solution is generated. Storing this substance as a solution helps to reduce the consequences of a release. A diked area around the storage tank, constructed to deflect a train derailment, further reduces the consequences of a release. 1.5 Five-Year Accident History The Erie mill completed a five-year accident history that indicates that there have been zero (0) releases with off-site consequences. There were two incidents that resulted in three OSHA recordable illnesses where mill employees were exposed to gaseous chlorine dioxide and experienced flu-like symptoms as a result. Both instances were believed to have resulted in the release of less than 1 pound of chlorine dioxide, however, due to limitations in the RMP submittal program 1 pound (the minimum amount the program would accept) was entered in the quantity released section of the RMP . The first incident occurred in the mill's bleach plant when chlorine dioxide was over-applied to the pulp at the mill's final bleaching stage. This over-application resulted in a high chlorine dioxide residual on the bleached pulp in the pulp press area where it affected two operators. Response to the incident indicated a weakness in the mill's evacuation training program as the employees did not evacuate the area after getting alarms on portable chlorine dioxide monitors. Since this incident the mill's belaching sequence has been changed such that chlorine dioxide is no longer added to the final stage, and this incident could no longer occur. Immediate corrective action involved the installation of a chlorine dioxide area monitor as well as the reinforcement of mill training procedures that were communicated to all crews regarding appropriate reactions to chlorine dioxide monitors. The second incident occurred when a maintenance employee working on a roof drain in the bleach plant was affected by chlorine dioxide from an unknown cause. Inappropriate reaction to a chlorine dioxide alarm resulted in the employee's exposure. Corrective action included a review of the bleach plant for possible sources of the chlorine dioxide exposure, as well as a review of response procedures with all affected employees to chlorine dioxide alarm activation. 1.6 Emergency Response Program The Erie mill has established a written emergency response program to help safely respond to accidental releases of hazardous substances. The emergency response program includes procedures for: -informing the local fire department and the public 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 substances at the Erie mill. -controlling and containing accidental releases of hazardous substances , including the use of emergency response equipment -inspecting and maintaining emergency response equipment -reviewing and updating the emergency response plan The Erie mill maintains an emergency response team trained in emergency response procedures. All Erie mill personnel are trained in evacuation procedures. The Erie mill periodically conducts emergency response drills, including annual drills coordinated with the local fire department. The written emergency response plan complies with other federal contingency plan regulations and has been communicated to local emergency response officials through the local fire department and the LEPC. The Erie mill maintains a regular dialogue with the local fire chief and LEPC, and provides them with appropriate information. |