Inland Eastex - Executive Summary |
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Inland Eastex Risk Management Plan 1. EXECUTIVE SUMMARY Inland Eastex is committed to operating in a manner that is safe for Inland Eastex employees, the public, and the environment. As part of this commitment, Inland Eastex 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 risks at Inland Eastex, and also 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 Inland Eastex. 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 Inland Eastex. The risk management program at Inland Eastex consists of three elements: 1. A hazard assessment to help understand: (a) the potential offsite consequences of hypothetical accidental releases (b) accidents that have occurred during the last five 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 Inland Eastex helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety program at Inland Eastex. In fact, Inland Eastex has a comprehensive safety program in place establishing many le vels of safeguards against release of a hazardous substance and injuries or damage from a release of a hazardous substance. Inland Eastex limits the use of hazardous substances. Before using a hazardous substance at Inland Eastex, less hazardous alternatives are considered. When a hazardous substance is used at Inland Eastex, Inland Eastex considers the potential for this substance to adversely affect Inland Eastex employees, the public, and the environment and takes steps to prevent any such effects. Inland Eastex prevents releases of the hazardous substances used at the facility. When a hazardous substance is used at Inland Eastex, 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 the design, construction, and operation of the equipment. Inland Eastex limits damage from a release, if such a release occurs. Inland Eastex trains employees to respond to an acciden tal release, reducing the consequences of a release if it occurs. In addition, Inland Eastex 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 Inland Eastex 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 Inland Eastex that are required by the RMP rule. 1.1 Accidental Release Prevention and Emergency Response Policies Inland Eastex is committed to the safety of employees and the public, and the preservation of the environment through the prevention of accidental releases of hazardous substances. Inland Eastex 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, installat ion, operations, and maintenance of processes at Inland Eastex, and programs to evaluate the hazards at Inland Eastex. In the event of an accidental release, Inland Eastex controls and contains the release in a manner that will be safe for employees and will help prevent injury to the public or the environment. Inland Eastex also provides response training to employees, designates an emergency response coordinator to oversee response activities, and coordinates efforts with local emergency planning and response organizations. Response activities have also been discussed with the LEPC. 1.2 Inland Eastex and Regulated Substances Inland Eastex is an integrated pulp and paperboard mill primarily involved in the manufacture of bleached paperboard products. As part of this manufacturing process, Inland Eastex handles several regulated substances in sufficient quantities to be covered by the RMP rule, as shown in the following list of RMP-covered processes. Process Program Level Regulated Substance Process Quantity Monox-L Generation 3 Chlorine 180,000 lb. Water Treatment/Chlorine 3 Chlorine 180,000 lb. Chlorine Dioxide Generation 3 Chlorine Dioxide 7,844 lb. and Storage 1.3 Offsite Consequence Analysis Inland Eastex performed an offsite consequence analysis to estimate the potential for an accidental release of a regulated substance to affect the public of the environment. The offsite consequence analysis consists of evaluating both worst-case release scenarios and alternative release scenarios. Inland Eastex does not expect a worst-case release scenario to ever occur. The alternative release scenarios were selected to help the local emergency planning committee i mprove the community emergency response plan. An alternative release scenario represents a release that: (1) might occur at a facility like Inland Eastex (2) would result in a conservative estimate of potential offsite consequences if the release occurred 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, 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 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 Inland Eastex. These requirements are: 7 one worst-case release scenario for the class of toxic substances in Program 3 processes (i.e., one scenario representing both chlorine and chlorine dioxide) 7 one alternative release scenario for each of the toxic substances in a Program 3 process (i.e., chlorine and chlorine dioxide) The following information summarizes the offsite consequence analysis performed by Inland Eastex. 1.3.1 Program 3 Processes - Toxic Substances The worst-case release for toxic substances is rupture of a tank car of 90-tons of chlorine, which evaporates and forms a vapor cloud. The maximum distance to the toxic endpoint concentration is greater than 25 miles. The U.S. Census indicates that 242,313 people live within the 25-mile radius from the storage vessel. This 25-mile radius cont ains public receptors of all types defined by the EPA in the RMP regulation. The receptors include schools, hospitals, industrial developments, and residential developments. The primary environmental receptors within the 25 mile radius per USGS maps are Big Thicket National Preserve, E.O. Siecke State Forest, and Sabine Island State Wildlife Management Area. The alternative release scenario for chlorine is the rupture of a 1" liquid unloading line from a 90-ton tank car. This scenario assumes active mitigation from tank car's built-in excess flow valve, which restricts the release to one that is instantaneous in nature. It is also assumed that this release requires approximately 30 minutes for workers to discover and isolate the ruptured hose. The maximum distance to the toxic endpoint is 2.1 miles. As many as 2,221 people offsite (U.S. Census data indicates approximately 1,406 local residents) could be impacted within this 2.1-mile radius. Several public receptors are also loc ated within this distance (e.g., the local school, the Pinefield subdivision, the Inland Eastex park baseball field, and several small businesses). No environmental receptors are within this distance. The alternative release scenario for chlorine dioxide is shearing off a one-inch sample line on the discharge of a chlorine dioxide solution (1wt%) pump that transfers solution to/from the chlorine dioxide absorber to storage. This scenario assumes that the solution is released through the hole for the 60 minutes before workers detect the release and isolate the line. The released chlorine dioxide solution forms a pool and the chlorine dioxide evaporates from the pool, forming a vapor cloud. The maximum distance to the toxic endpoint is 1.1 miles. As many as 1,626 people offsite (U.S. Census data indicates approximately 811 local residents) could be impacted within this 1.1-mile radius. Several public receptors are also located within this distance (e.g., the local school, part of the Pinefield subdivision, the Inland Eastex park baseball field, and several small businesses). No environmental receptors are within this distance. 1.4 Accidental Release Prevention Program and Chemical - Specific Prevention Steps Since its inception in 1953, Inland Eastex has used a prevention program to help prevent accidental releases of hazardous substances. Beginning in 1992, Inland Eastex formalized this prevention program for the Water Treatment/Chlorine and Chlorine Dioxide Generation and Storage processes to comply with the 13 elements of the OSHA process safety management (PSM) prevention program. In 1996, the EPA RMP rule established prevention program requirements: Program 3 - 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 Inland Eastex's prevention program that address the EPA RMP rule prevention program requirements. 1.4.1 Program 3 Pre vention Program The Inland Eastex Program 3 prevention program, which applies to the Monox-L Generation, Water Treatment/Chlorine and the Chlorine Dioxide Generation and Storage processes, consists of the following 12 elements: a. Process Safety Information. Inland Eastex maintains a variety of technical documents that are used to help ensure safe operations of the Inland Eastex processes. These documents address: (1) physical properties of hazardous substances handled at Inland Eastex (2) operating parameters of the equipment at Inland Eastex (3) design basis and configuration of the equipment at Inland Eastex. Inland Eastex ensures that this process safety information is available to all employees, the local emergency planning committee (LEPC), and the fire department. Material safety data sheets (MSDSs) document the physical properties of hazardous substances handled at Inland Eastex, including regulated substances in covered processes. The information available for each haza rdous substance typically includes: 7 toxicity information and permissible exposure limits 7 physical data (e.g., boiling point, melting point, flash point) 7 reactivity and corrosivity data 7 thermal and chemical stability data 7 hazards of mixing substances in the process MSDSs for hazardous substances handled in each process are available in the process control room so that the operators have ready reference to this information. In addition, MSDSs are provided to the LEPC and the fire department for the 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: 7 operating parameters 7 block flow or simplified process flow diagrams 7 process chemistry 7 maximum intended inventories 7 safe upper and lower limits for parameters such as temperature, pressure, or flow 7 consequences of deviations fro m established operating limits 7 design basis and configuration of equipment 7 piping and instrument diagrams, including materials of construction 7 electrical classification 7 safety systems 7 applicable design codes and standards 7 design basis for relief and ventilation systems When important information was not available for the design documents, it was developed through special projects or, in the case of operating parameters, during process hazard analysis of the process. 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 (3) to help maintain the equipment. b. Process Hazard Analysis. Inland Eastex 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 hazards of the process. Inland Eastex 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 unit personnel and, when appropriate, changes to enhance the safety of the process are implemented. c. Operating Procedures. Inland Eastex 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: (1) are used to train employees (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets Operati ng procedures include: 7 steps for safely conducting activities 7 applicable process safety information, such as safe operating limits and consequences of process deviations 7 safety and health considerations, such as chemical hazards, personal protective equipment requirements, and actions to take if exposure to a hazardous substance occurs Inland Eastex personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operations, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations. The operating procedures are used both to help in operating the Inland Eastex processes and as a training guide. d. Training. Inland Eastex trains workers to safely and effectively perform their assigned tasks. Inland Eastex 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 (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 training material before the employee can resume work in the process. The operators are consulted annually at safety meetings to evaluate the effectiveness and frequency of the training. Recommendations from the operators are reviewed, and changes to the training program are implemented as appropriate. e. Mechanical Integrity. Inland Eastex maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public, or the environment. The Inland Eastex mechanical integrity program includes: (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 r equired for service in Inland Eastex process The Inland Eastex mechanical integrity program includes: 7 specifications for inspection and testing of process equipment 7 specifications for replacement parts and equipment 7 procedures for inspecting, testing, and maintaining process equipment 7 procedures for safe work practices such as lockout/tagout, hot work, confined space entry, and line or equipment opening 7 training of maintenance personnel 7 documentation of maintenance activities f. Management of Change. The Inland Eastex 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. Changes that are determined to be a replacement in kind (e.g., replacing a valve with an identical valve) are allowed without completing a full management of change program. All other changes must be confirmed through the full management o f 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. g. Pre-startup Review. Inland Eastex 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: 7 construction and equipment are in accordance with design specifications 7 adequate safety, operating, maintenance, and emergency procedures are in place 7 employee training has been completed 7 for a covered process, a PHA has been performed if the process is new or management of change 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. h. Complian ce Audit. Inland Eastex audits covered processes to be certain that the prevention program is effectively addressing the safety issues of operations. Inland Eastex assembles an audit team that includes personnel knowledgeable in 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 enhancements to the prevention program are implemented. i. Incident Investigation. Inland Eastex 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. Inland Eastex 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. j. Employee Participation. Inland Eastex developed a written employee participation program for covered processes to help ensure that the safety concerns of Inland Eastex workers are addressed. Inland Eastex encourages 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 the RMP rule prevention program, including PHAs and operating procedures. k. Hot Work Permits. Inland Eastex 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 Inland Eastex facility. Inland Eastex 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 who are to perform hot work are required to fill out the Hot Work Permit Form. The Operating Supervisor/Constru ction Coordinator/Team Leader reviews the completed form and work area then signs form before work can begin. Training in the use of the Hot Work Permit Form is included in the Inland Eastex safe work practices orientation. l. Contractors. Inland Eastex established a program to help ensure that the contractor activities at the Inland Eastex facility are performed in a safe manner. The program reviews the safety record of all contractors to help ensure that Inland Eastex only hires contractors who can safely perform the desired job tasks. Inland Eastex explains to the contract supervisors the hazards of the process on which they and their employees will work, Inland Eastex safe work practices, and Inland Eastex emergency response procedures. Inland Eastex requires that the contractor supervisors train each of their employees who will work at Inland Eastex before that worker begins work at the Inland Eastex site. Inland Eastex periodically reviews contractors' training documents a nd work performance to help ensure that safe practices are followed. 1.4.2 Chemical-specific Prevention Steps In addition to the required prevention programs elements, Inland Eastex has implemented safety features specific to the hazardous substances used at Inland Eastex. The following paragraphs describe some of these safety features. Chlorine. Chlorine is supplied in DOT-approved 90-ton rail tank cars, 1-ton cylinders, and 150-lb cylinders. Chlorine is used for water treatment and for preparation of a bleaching chemical, Monox-L. For water treatment, chlorine gas is fed through a short length of piping to an eductor, where it is absorbed into process water for use in the water treatment unit. The length of piping containing chlorine is kept to a minimum to reduce the likelihood of a release. If a release occurs downstream of the regulator at the cylinder, the regulator will close and only the quantity in the piping will be released. This quantity is small because of the short pipe in length and the vacuum conditions inside the piping. Chlorine detectors and alarms are provided in most areas containing chlorine. For Monox-L preparations, liquid chlorine is vaporized to chlorine gas prior to reacting with other chemicals. Operators via remote TV cameras constantly monitor rail tank car unloading. Chlorine detectors and alarms provide an immediate warning of any release. Chlorine Dioxide. Chlorine dioxide is produced at the Inland Eastex facility 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 it is mixed with chilled water and a 1 wt% chlorine dioxide solution is generated. Storing this substance as a solution helps to reduce the consequences of a release. 1.5 Five-Year Accident History Inland Eastex has completed a five-year accident history that has shown an improvement ove r the past year. The number of accidental releases declined from a peak of 18 in 1997 to 10 in 1998 and show continuous decline in 1999. The most significant incident in the past five years was on May 22, 1997. Release was due to a broken electrical wire to a caustic makeup valve, which caused a loss of caustic to a scrubber resulting in a release of 7-9 pounds of chlorine. Incident resulted in 7 OSHA's and 1 first aid. An accident investigation team was assembled in accordance with the investigation protocol. The team recommended and implemented several improvements to eliminate the potential of this in the future. Since 1994, there have been 7 OSHA's and 23 first aid cases involving both contractors and inland employees due to inhalation or skin contact with either chlorine or chlorine dioxide. The records for releases for the 5-year period prior to June 1999 show a total of 46. There is no record of offsite consequences in the past 5-years. 1.6 Emergency Response Program s Inland Eastex has established a written emergency response program to help safely respond to accidental releases of hazardous substances. The emergency response plan includes procedures for: 7 informing the local fire department and the public about accidental releases that could reasonably result in offsite consequences 7 providing proper first aid and emergency medical treatment to treat accidental human exposure to hazardous substances at Inland Eastex 7 controlling and containing accidental releases of hazardous substances, including the use of emergency response equipment 7 inspecting and maintaining emergency response equipment 7 reviewing and updating the emergency response plan Inland Eastex maintains an emergency response team trained in these emergency response procedures. All Inland Eastex personnel are trained in evacuation procedures. Inland Eastex 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 (e.g., the OSHA regulations 29 CFR 1910.38(a), 29CFR 1910.120(a)) and has been communicated to local emergency response officials through the local fire department. Inland Eastex maintains a regular dialogue with the local emergency planning and response organizations. 1.7 Planned Changes to Improve Safety Inland Eastex constantly strives to improve safety in all areas including covered processes. Improvements in incident investigations and employee involvement with processes such as our behavior process (Hero: Hazards Eliminated through Routine Observations) and continued aggression in our Standing Safety Committee. The PSM Program will continue to improve due to full time coordinator and continual evaluation by a team of diversified talent. 7 Inland Eastex reviewed the chlorine handling system, increased the inspection frequency for chlorine equipment, added TV cameras and chlorine detectors for remote observations, and took steps to decrease the traffic near chlorine equipment - these changes reduce the likelihood of a chlorine release caused by degraded equipment or external impact 7 A new chlorine dioxide generating facility, currently under construction will eliminate the chlorine requirements for generating Monox-L, which will also eliminate the use of chlorine as part of that generation. |