Georgia-Pacific Resins, Inc. - Executive Summary

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8.1  Executive Summary 
 
Georgia-Pacific Resins, Inc. (GPRI), a wholly owned subsidiary of Georgia-Pacific Corporation, owns and operates a synthetic resin manufacturing facility in Ukiah, CA.  The resin plant was originally constructed in 1974 and employs 24 full-time employees. 
 
GPRI is committed to operating the Ukiah, CA plant in a manner that is safe for its workers, the public, and the environment.  As part of this commitment, GPRI  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 Ukiah Plant 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 (RMP Plan) describing the Risk Management Program at the Ukiah Plant. This doc 
ument is intended to satisfy the RMP Plan requirement of the RMP rule and to provide the public with a description of the Risk Management Program at the Ukiah Plant. 
 
The Risk Management Program at the Ukiah Plant consists of the following three elements: 
 
1. a hazard assessment to help understand (a) the potential offsite consequences of hypothetical accidental releases and (b) 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 accidental releases of regulated substances from covered processes 
 
Information further describing these elements is provided in this RMP Plan. 
 
Although the Risk Management Program at the Ukiah Plant 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 Ukiah Plant.  In fact, the Ukiah Plant has a comprehensive safety program in place establishing many levels of safeguards against release of a hazardous substance, and injuries and damage from a release of a hazardous substance. 
 
GPRI limits the use of hazardous substances.  Before using a hazardous substance at the Ukiah Plant, less hazardous alternatives are considered. When a hazardous substance is used at the Ukiah Plant, GPRI considers the potential for this substance to adversely affect plant workers, the public, and the environment and takes steps to prevent any such effects. 
 
GPRI prevents releases of the hazardous substances used at the facility.  When a hazardous substance is used at the Ukiah Plant, 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 o 
peration of the equipment.  
 
GPRI limits damage from a release, if such a release occurs.  GPRI trains its workers to respond to an accidental release, reducing the consequences of a release if it occurs.  In addition, GPRI works with the local fire department and with the local emergency planning committee (LEPC) to help prevent injuries and/or environmental damage if a release does occur. 
 
The safety program at the Ukiah Plant 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 at the Ukiah Plant that are required by the RMP rule. 
 
8.1.a Accidental Release Prevention and Emergency Response Policies 
 
GPRI 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.  GPRI implements reasonable controls to prevent foreseeable releases of hazardous substances.  These contro 
ls include training programs for personnel, programs to help ensure safety in the design, installation, operation, and maintenance of processes at the Ukiah Plant, and programs to evaluate the hazards at the plant. 
 
In the event of an accidental release, the Ukiah Plant controls and contains the release in a manner that will be safe for workers and will prevent injury to the public and the environment.  GPRI provides response training to its personnel, designates an emergency response coordinator to oversee response activities, and coordinates response efforts with the local fire department.  Response activities have also been discussed with the LEPC.   
 
In order to effectively implement these policies, GPRI established a management system headed by the Safety Manager to oversee safety-related activities. 
 
 
8.1.b Regulated Substances Handled 
 
The Ukiah Plant handles two regulated substances in sufficient quantity to be covered by the federal RMP rule, as shown in the following list of  
RMP-covered processes at the plant. 
 
Regulated 
Substance                             Program Level     Process                Process Quantity*, lbs RMP Threshold, lbs* 
Formaldehyde Solution (50%)   3                      Resin Manufacture 288,000                    15,000 
Aqua Ammonia (28%)               3                      Resin Manufacture 20,030                      20,000 
 
* Process and threshold quantity are the quantities of "pure" chemical, not of the solution 
 
 
8.1.c Offsite Consequence Analysis 
 
The Ukiah Plant performed an offsite consequence analysis to estimate the potential for an accidental release of a regulated substance to affect the public or the environment.  The offsite consequence analysis evaluates a "worst-case release scenario" and an "alternative release scenario".  GPRI does not expect a worst-case release scenario to ever occur.  The alternative release scenarios were selected to help the Mendocino County LEPC improve the community emergency response plan 
.  An alternative release scenario represents a release that (1)might occur at a facility like the Ukiah Plant and (2) would result in the greatest 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 possible.  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 GPRI.  These requirements are: 
 
7 one worst-case release scenario for the class of toxic substances in Program 3 processes 
 
7 one alternative release scenario for each of the toxic substances in a Program 3 process 
 
The following information summarizes the offsite consequence analysis performed by the Ukiah Plant: 
 
8.1.c.1.  The "worst-case release scenario" for a 50% solution of formaldehyde is the release of K-2 kettle contents after filling.  A concrete diked area contains the released formaldehyde solution which evaporates and forms a vapor cloud.  The maximum distance to the toxic endpoint concentration based on modeling is 0.6 miles.  The U.S. Census indicates that 431 people live within this distance from the location of the kettle.  Several public receptors are also located within this distance including nearby residences.  No environmental receptors are lo 
cated within this distance. 
 
8.1.c.2. The "alternative case release scenario" for a 50% solution of formaldehyde is the overfilling of a formaldehyde storage tank and the spillage of 100 gallons (480 lbs of pure formaldehyde) of solution into the concrete diked area.  Modeling this scenario indicates a toxic endpoint distance of 0.02 miles.  There are no nearby residences within this distance from the plant.  There are no some public receptors within this distance.  No environmental receptors are located within this distance. 
 
8.1.c.3. The "alternative case release scenario" for a 28% solution of ammonia is the overfilling of an ammonia storage tank and the spillage of 100 gallons (209 lbs of pure ammonia) of solution into the concrete diked area.  Modeling this scenario indicates a toxic endpoint distance of 0.15 miles.  There are no nearby residences within this distance from the plant.  There are some public receptors within this distance.  No environmental receptors are located 
within this distance. 
 
8.1.d  Administrative Controls - Administrative controls to limit the determination for each reported scenario exist to restrict the amount of regulated chemical released to a minimum, if a release were to occur and preferably to not have a release occur.  The administrative control is inherent in operational procedures for the regulated chemical system and the training provided to the regulated chemical operators.   
 
8.1.e  Mitigation Measures 
 
8.1.e.1  Passive mitigation: 
i.  The formaldehyde storage tanks are situated within a concrete, secondary containment structure which has the capacity to contain 100% of the volume of the contents of a storage tank, should it release its contents. 
 
ii. The aqua ammonia storage tank is situated within a concrete, secondary containment structure which has the capacity to contain 100% of the volume of the contents of the storage tank, should it release its contents. 
 
 
8.1.e.2  Active mitigation: 
 
i. The formal 
dehyde tanks have differential pressure cells with level readouts and high level alarms to prevent overfilling.  The plant maintains a standard operating procedure for these tanks which requires the operator to manually verify the level of solution in the tanks before it is filled with additional raw material.  In this way, the tank should not be overfilled. 
 
ii. The aqua ammonia storage tank has a differential pressure cell with a level readout to prevent overfilling.  The plant maintains a standard operating procedure for this tank which requires the operator to manually verify the level of solution in the tank before it is filled with additional raw material.  In this way, the tank should not be overfilled. 
 
8.1.f  General Accidental Release Prevention Program - Since 1982, the Ukiah Plant has used a prevention program to help prevent accidental releases of hazardous substances.  Beginning in 1992, the plant formalized this prevention program for the resin manufacturing process  
to comply with the 14 elements of the OSHA process safety management (PSM) prevention program. 
 
8.1.g Chemical-Specific Prevention Steps 
 
8.1.g.1 Formaldehyde Solution - Industry standards are followed at the plant to help ensure safe handling of formaldehyde.  All of the formaldehyde stored in the plant's storage tanks is delivered to the plant by offsite vendors.  The formaldehyde vendor supplies formaldehyde solution via a DOT-approved tank truck and follows  DOT standards when filling the formaldehyde storage tank.  Workers who perform operations involving formaldehyde receive training emphasizing safe handling procedures for formaldehyde.  The storage tanks are surrounded by a concrete dike which is large enough to contain 100% of the volume of a tank should its entire contents be spilled. 
 
8.1.g.2 Aqueous Ammonia - Industry standards are followed at the plant to help ensure safe handling of aqueous ammonia.  The ammonia vendor supplies aqueous ammonia via a DOT-approved tan 
k truck and follows DOT standards when filling the aqueous ammonia storage tank.  Workers who perform operations involving ammonia receive training emphasizing safe handling procedures for ammonia developed by the plant.  The storage tank is surrounded by a concrete dike which is large enough to contain 100% of the volume of the tank should its entire contents be spilled. 
 8.1.h Five-Year Accident History 
 
The Ukiah Plant has completed a five year accident history that indicates no off-site releases of regulated substances. 
 
             Year  Number of Reported Accidents  Substance Released  Consequences 
             1994      0                                               None                          No Offsite Impacts 
             1995      0                                               None                          No Offsite Impacts 
             1996      0                                               None                          No Offsite Impacts 
             1997  
    0                                               None                          No Offsite Impacts 
             1998      0                                               None                          No Offsite Impacts 
 
8.1.i Emergency Response Program-the Ukiah Plant has established a written emergency response program to help safely respond to accidental releases of hazardous substances. The emergency response plan includes procedures for the following: 
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 the plant 
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 
 
The Ukiah Plant maintains an e 
mergency response team trained in these emergency response procedures.  All plant personnel are trained in evacuation procedures.  The plant periodically conducts emergency response drills, including 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), 29 CFR 1910.120(a)) and has communicated to local emergency response officials through the local fire department.  The plant maintains a regular dialogue with the local fire chief, and the plant provides appropriate information to the fire chief. 
 
A copy of the plant's Emergency Response Plan is contained in Appendix D.  
 
 
8.1.j Planned Changes to Improve Safety  
 
The Ukiah Plant constantly strives to improve the safety of the processes at the facility through both the incident investigation program and a program soliciting safety suggestions from the workers. The following changes to improve p 
rocess safety are planned or have recently been completed. 
 
7 Revalidation of PHAs will continue. 
7 Operator training to increase with the use of Computer Based Training (CBT) interactive modules for theory on current systems.  Recertification of operating personnel will  use the CBT training and hands on demonstrated ability checklists. 
7 Permit auditing will increase on all types of work permits. 
 
7 Combined exercises will be performed for emergency response with the local responding agencies as appropriate. 
7 Safety and Health training will be supplemented by some "hands on" exercises. 
7 Pre-Startup Safety Reviews will be performed on any major shut down prior to restarting the process. 
7 Labeling of all equipment and piping will continue. 
7 Variation Reduction program will continue for identification of "best practice" for implementation on the processes.
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