Buckeye Florida, Limited Partnership - Executive Summary |
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EXECUTIVE SUMMARY FOR BUCKEYE FLORIDA We at Buckeye Florida are committed to operating our processes in a manner that is safe for our workers, the community, and the environment. As part of this commitment, we have 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 involved with using regulated hazardous substances at our facility and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit an executive summary in the risk management plan (RMPlan) describing the risk management program at Buckeye Florida. This document is intended to satisfy the executive summary requirement of the RMP rule and to provide the public with a description of our risk management program. Our risk management program consists of three elements: 1. A hazard assessment designed to help us understand (a) the potential offsite consequences of hypothetical accidental releases and (b) accidents that have occurred during the last five years associated with the substances regulated by the RMP rule - see Sections 3 and 5 2. A prevention program to help maintain and safely operate processes containing significant quantities of substances regulated by the RMP rule - see Section 4 3. An emergency response program to help respond to accidental releases of regulated substances from processes covered by the RMP rule - see Section 6 Information further describing these elements is provided in this executive summary. Although our risk management program helps ensure that our facility is maintained and operated in a safe manner, it is only one component of the safety program. In fact, we have a comprehensive safety program that establishes many levels of safeguards against accidental rel eases and against the injuries and damage that could occur from accidental releases. Limiting the use of hazardous substances. Before using a hazardous substance, we always consider less hazardous alternatives. When we must use a hazardous substance, we consider the potential for this substance to adversely affect our workers, the public, and the environment and take steps to prevent any such effects. Preventing releases of the hazardous substances used at the facility. When a hazardous substance is used, the equipment used to contain it is carefully designed, built, and operated to reduce the likelihood of an accidental release. Industry and government standards are closely adhered to in the design, construction, and operation of the equipment. Limiting damage from a release, if such a release occurs. We work daily to prevent accidental releases from occurring. However, we also train our workforce to recognize accidental releases, quickly assess the severity of a release, and re spond to mitigate and stop the release, if one would occur. We work closely with Taylor County Emergency Management to ensure appropriate plans are in place to minimize the impact of the release on our workers and the community. Our safety program consists of a number of elements, only some of which are required by the RMP rule. This RMP Plan is primarily intended to describe those parts of the safety program required by the RMP rule. 1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES We are committed to the safety of workers and the public, and the preservation of the environment, through the prevention of accidental releases of hazardous substances. We take reasonable steps to prevent foreseeable releases of hazardous substances. These steps include 1) training programs for personnel, 2) programs to help ensure safety in the design, installation, operation, and maintenance of our processes and 3) programs to evaluate the hazards of our processes. In the event of an accidental release, we will strive to control and contain the release in a manner that will be safe for workers and will help prevent injury to the public or damage to the environment. We provide Incident Command response training to our personnel so that they are well prepared to handle emergency situations and execute emergency response actions. 2. REGULATED SUBSTANCES WE USE Our facility is a pulp and paper mill primarily involved in the manufacture of specialty pulp. As part of this manufacturing process, we handle regulated substances in sufficient quantities to be covered by the RMP rule, as shown in the following list of RMP-covered processes. Process Regulated Substance(s) Sulfur dioxide area #1 Mill purification Area R8 Water treatment #2 Mill purification #1 Mill purification Sulfur dioxide Chlorine Chlorine dioxide Chlorine Chlorine dioxide Chlorine dioxide 3. OFFSITE CONSEQUENCE ANALYSIS We performed an offsite consequence analysis to estimate the potential for accide ntal releases of regulated substances that could affect the public or the environment. We evaluated one worst-case release scenario and more reasonable (but still highly unlikely) alternative release scenarios for each regulated substance. We do not expect a worst-case release scenario to ever occur. This scenario is designed to estimate the maximum possible area that could be affected by a release at our facility, but it is not a realistic scenario. An alternative release scenario was analyzed to provide emergency responders with information that should help them to improve the community emergency response plan. An alternative release scenario represents a release that could foreseeably occur at a facility like Buckeye Florida. The main objective for performing the offsite consequence analysis is to determine the distance at which certain effects on the public might occur due to an accidental release (called the endpoint distance). For exposures to chlorine, chlorine dioxide, and su lfur dioxide, most people 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 possible. Some people who are particularly susceptible to the substance released could experience more serious effects. At distances less than the endpoint distance, the effects would be more severe; at distances greater than the endpoint distance, the effects would be less severe. The following information summarizes the offsite consequence analysis. 3.1 Worst-case Release Scenario The worst-case release scenario is a failure of a 90-ton chlorine railcar. When we assume, as required by the regulations, that (1) the railcar is full and (2) all the chlorine is released from the railcar over a 10-minute time period, the predicted distance to the toxic endpoint (3 ppm) extends off site, and public receptors are within the distance to the endpoint. 3.2 Alternative R elease Scenarios The alternative release scenario for chlorine is a 0.5-inch unloading hose rupture on a 90-ton chlorine railcar. In this scenario, a Buckeye Florida employee will stop the leak by closing remotely operated isolation valves. The resulting distance to the endpoint does not extend off site. The alternative release scenario for sulfur dioxide is a 2-inch unloading hose rupture on a sulfur dioxide tank truck. In this scenario, a Buckeye Florida employee will stop the leak by closing remotely operated isolation valves. The resulting distance to the endpoint does not extend off site. The alternative release scenario for chlorine dioxide is a 1-inch instrument line rupture downstream of the chlorine dioxide transfer pump. In this scenario, a Buckeye Florida employee will stop the leak by shutting off the pump and closing remotely operated isolation valves. The resulting distance to the endpoint does not extend off site. 4. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICA L-SPECIFIC PREVENTION STEPS We have always believed that safety is the highest priority. Beginning in 1992, we incorporated this belief into a prevention program that complies with the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) rule. For Buckeye Florida, the prevention program requirements of EPA's RMP rule are nearly identical to the PSM rule. The following sections briefly describe the elements of our prevention program that address the RMP rule requirements. 4.1 Prevention Program Our accident prevention program consists of the following 12 elements: 1. Process safety information. We maintain a variety of technical documents, including the Buckeye Contingency Plan and the Environmental Procedures Manual, to help ensure that our employees and local emergency responders know about the hazards associated with our facility. These documents address (a) physical properties of the hazardous substances we handle, (b) operating parameters for our equipment, and (c) design basis and configuration for our equipment. We ensure that this process safety information is available to all our employees. 2. Process hazard analysis. We perform and periodically update process hazard analyses of our covered processes to help identify process hazards and make recommendations that might improve the safe operation of the process. A multidisciplinary team is assembled to analyze the hazards of our processes. This team includes personnel with engineering and process operating experience and a leader with process hazard analysis experience. The team systematically addresses the hazards associated with operation of the equipment in the covered process areas. The team then prepares a written report describing the results of the analysis, including a list of recommendations. Responsibility for resolving the recommendations is assigned to area personnel, and, when appropriate, changes to enhance the safety of the process are implemented. Each analysis is revisited at least every five years to ensure it is current. 3. Operating procedures. Our process engineers, operators, and managers 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 serve as reference guides for appropriate actions to take during both normal operations and process upsets. Operating procedures include: * Steps for safely conducting activities * Applicable process safety information, such as safe operating limits and consequences of process deviations * Safety and health considerations, such as chemical hazards, personal protective equipment requirements, and actions to take if exposure to a hazardous substance occurs 4. Training. We train workers to safely and effectively perform their assigned tasks. Our training program includes both initial and refresher training that covers (a) a general overview of the process, (b) the properties and hazards of the substances in the process, and (c) a detailed review of the process operating procedures and safe work practices. Computer-based training and demonstrations are used to help train employees, and oral reviews are used to verify that an employee understands the training material before the employee can begin or resume work in the process. 5. Mechanical integrity. We maintain our process equipment to help prevent equipment failures that could endanger workers, the public, or the environment. Our mechanical integrity (preventive maintenance) program includes (a) an inspection and testing program to help identify equipment deterioration and damage before the equipment fails and (b) a quality assurance function to help ensure that new and replacement equipment meet the strict design standards required for service in our processes. 6. Management of change. We evaluate and specifically approve all proposed changes to chemicals, equipment, technology, and procedures to help ensure that the change does not negatively affect safe operations. All changes other than replacement-in-kind (e.g., replacing a valve with an identical valve) must be approved through the full management of change program. This helps 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 safety review. We recognize that new or newly modified processes are historically more likely to be involved in accidental releases. Therefore, we perform safety reviews of new or modified processes before placing them into service to help ensure their safe operation. This review confirms that: * Construction and equipment are in accordance with design specifications * Adequate safety, operating, maintenance, and emergency procedures are in place * Employee training has bee n completed * For a covered process, a process hazard analysis has been performed if the process is new, or management of change requirements have been completed if an existing process has been modified 8. Compliance audit. One of the cornerstones of an effective prevention program is a regular, thorough assessment. We audit our covered processes every three years to be certain our prevention program is effectively addressing the safety needs of our operations. We assemble an audit team that includes personnel knowledgeable in the PSM and RMP regulations and in our process designs, and this team evaluates whether the prevention program satisfies the requirements of these two regulations and whether it is sufficient to help ensure safe operation of the process. The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented. 9. Incident investigation. We investigate all incidents that could reasonably hav e resulted in serious injury to personnel, the public, or the environment so that similar accidents can be prevented in the future. We train our 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. We have a written employee participation program for covered processes to help ensure that the safety concerns of our workers are addressed. We encourage active participation of personnel in the prevention program activities of all processes at the facility. Employees are consulted on and informed about all aspects of our accidental release prevention program. 11. Hot work permits. We have a hot work permit program to control spark- or flame-producing activities that could result in fires or explosions in ou r facility. We reviewed OSHA's fire prevention and protection requirements and created a hot work permit form to comply with these requirements. Personnel who are to perform hot work are required to fill out the form, and the appropriate supervisor reviews the completed form before work can begin. Training on hot work activities and on the requirements of the hot work permit program is included in our safe work practices orientation. 12. Contractors. We have a program in place to help ensure that contractor activities at our facility are performed in a safe manner. We explain to the contract supervisors (a) the hazards of the processes on which they and their employees will work, (b) our safe work practices, and (c) our emergency response procedures. The contractor is required to ensure that training has been performed for each of their employees who will work at the facility before that worker begins work at our facility. 4.2 Chemical-specific Prevention Steps In addition to t he required prevention program elements, we have implemented safety features specific to the regulated substances used at our facility. The following paragraph describes some of these safety features. Chlorine is supplied in 90-ton railcars that are approved by the Department of Transportation (DOT) and designed and maintained in accordance with good engineering practices established by the Chlorine Institute. Chlorine is fed through braided metal flexible hoses into process piping. We have installed video cameras near likely release points (e.g., at the chlorine unloading station) to alert operators of a release of hazardous material. The sulfur dioxide handling equipment uses remotely operated manual shutoffs, automatic shutoffs, and emergency air supply to help prevent or mitigate releases of sulfur dioxide. For the chlorine dioxide system, manual shutoffs, emergency air supply, and excess flow devices are used to help prevent or mitigate releases of this substance. 5. FIVE-YEA R ACCIDENT HISTORY Our accident history demonstrates the continuous safe operation of our chemical processes over the last five years. Two recorded accidental releases resulted in exposing three employees to chlorine in sufficient quantity to require medical attention. One recorded accidental release resulted in exposing an employee to sulfur dioxide in sufficient quantity to require medical attention. However, none of these employees suffered long-term health effects due to their exposure, and neither the public, the community, nor the environment were affected in any way. There have been other releases of hazardous chemicals used at Buckeye Florida in the past. Although none of these releases were severe enough to meet the requirements for reporting in the RMP five-year accident history, they were investigated as accidents. As a result of the investigations, additional safeguards have been put into place to help reduce the likelihood of a catastrophic release. 6. EMERGENCY RESP ONSE PROGRAMS We have established a written emergency response program to help ensure the safety of personnel who respond to accidental releases of hazardous substances. The emergency response plan includes procedures for: * Informing Taylor County Emergency Management about accidental releases that could reasonably result in offsite consequences * Providing proper first aid and emergency medical treatment for accidental human exposure to hazardous substances * Obtaining outside assistance to control and contain 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 We have trained our employees to recognize and report emergency situations. All of our personnel are trained in evacuation procedures. Taylor County Emergency Management is responsible for notifying the public of the emergency situation, if necessary. The written emergency response plan complies with other federal contingency plan regulations [e.g., OSHA regulation 29 CFR 1910.38(a)], and a copy of the plan has been provided to the fire department. Also, a Hazardous Material Storage and Location Plan has been provided to Taylor County Emergency Management, and Buckeye Florida maintains a regular dialogue with local emergency planners. 7. PLANNED CHANGES TO IMPROVE SAFETY We constantly strive to improve the safety of our processes using recommendations developed through the prevention program and a program soliciting safety suggestions from our employees. Currently, all recommendations developed for safety improvements have been implemented. BUSINESS CONFIDENTIAL 1-1 BUSINESS CONFIDENTIAL DRAFT ATTACHMENT (cont'd) 1-2 |