Mead Paper Ohio Operations - Executive Summary |
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MEAD OHIO OPERATIONS - EXECUTIVE SUMMARY Mead Paper is committed to operating in a manner that is safe for employees, the public, and the environment. As part of that commitment, Mead Ohio Operations has established management systems to maximize the safety of operating processes at this facility. One component of this design is a risk management plan (RMP) that guides the safe handling, storage, and usage of regulated hazardous substances at Mead and 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 Mead Ohio. 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 Mead Ohio. The risk management program at Mead Ohio consists of three elements: 1) Hazard assessments to analyze and understand (a) the potential for offsite consequences of hypothetical accidental releases and (b) accident and incident investigations that have occurred involving substances regulated by the RMP rule (regulated substances) - see topics 1.3 and 1.5. 2) Prevention programs to help maintain and safely operate those processes containing more than a threshold quantity of a regulated substance - see topic 1.4. 3) Emergency planning for public notification and response should an accidental release of a regulated substance from covered processes ever occur - see topic 1.6. Information further describing these elements is provided in this RMPlan. Mead Ohio's risk management planning is designed to assure that the facility is maintained and operated in a safe manner. However, it is only one component of the facilities' safety program. In fact, Mead Ohio has a comprehensive safety program in place, which directs many levels of safeguards against release of hazardous substances to prevent and mitigate injuries and damage from a hazardous substance release. Accidental Release Prevention and Emergency Response Policies Mead's safety policies integrate many levels of personal, process, and environmental safety. However, this RMPlan is limited to address those elements of the safety program at Mead Ohio that are required by the RMP Rule. Mead Ohio limits the use of hazardous substances. Before using a hazardous substance at Mead, less hazardous alternatives are considered. When a hazardous substance must be used, Mead thoroughly reviews the potential for this substance to adversely affect employees, the public, and the environment and manages its processes to prevent such effects. Mead Ohio prevents releases of the hazardous substances used at the facility. Mead is committed to the safety of employees, the public, the preservation of the environment, and the prevention of accidental releases of haza rdous substances. When a hazardous substance is used at Mead Ohio, the equipment is carefully designed, built and operated to reduce the likelihood of an accidental release. In conjunction with best engineering practices, government and industry standards are closely adhered to in the design, construction, and operation of the equipment. Chemical-specific prevention steps Mead follows industry standards (e.g., Department of Transportation [DOT], National Fire Protection Association [NFPA], The Chlorine Institute, and manufacturers' guidelines) to maximize the safe handling, storage and usage of all hazardous materials. For the Chlorine Dioxide and Chlorine processes, Process Hazard Analyses (PHAs) are conducted in accordance with the requirements specified by OSHA's Process Safety Management Standard. Mead Ohio implements reasonable controls to prevent foreseeable releases of hazardous substances. If such a release should occur, Mead shall also make every attempt to limit damage s. In the event of a significant accidental release, Mead Ohio maintains a trained and certified hazardous chemical emergency response program, would evacuate employees and contact local emergency response agencies (LEPC) as necessary to control, contain, and prevent/reduce the consequences of the release. Mead Ohio and local emergency response agencies (through the Chillicothe City Fire Department) have established a process to alert the community in the event an offsite consequence exists. Mead Ohio Operations and Regulated Substances Mead Ohio is an integrated paper products company primarily involved in the manufacture of pulp and paper from both hard and softwoods. Mead Ohio handles two regulated toxic (no flammable) substances in sufficient quantities to be covered by the RMP rule. As part of the manufacturing process at this facility, Chlorine Dioxide is used as a stock bleaching agent in the Pulp Mill, and Chlorine is used as a water treatment biocide at Chilpaco. Both of these substances are inventoried at quantities above the EPA threshold limit and are regulated by the RMP rule. Both of these systems are regulated and compliance managed in accordance with OSHA's Process Safety Management Standard. As such they are designated as Program Level 3 processes for RMP rule compliance purposes. Regulated Process Program Level Substance Quantity Chlorine Dioxide Storage 3 Chlorine Dioxide 18,000 lb Water Treatment Chlorine 3 Chlorine 16,000 lb Offsite Consequence Analysis Mead Ohio has performed offsite consequence analyses to estimate the potential for an accidental release of a regulated substance to affect the public or the environment. The offsite consequence analysis consists of evaluating both worst-case release scenarios and alternative release scenar ios. Mead Ohio does not expect a worst-case release scenario to ever occur. The alternative release scenarios were selected to aid local emergency planning committee in improving the community emergency response plan. An alternative release scenario represents a release that (1) might occur at a facility like Mead and (2) would result in the greatest potential offsite consequences if the release occurred. The primary 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). When considering the release of a toxic substance, it is expected that people at the endpoint distance would experience little or no exposure, with no long-term health consequences. However, the potential for some short-term consequences (e.g., strong eye irritation, or throat irritation), while not likely, does exist. Some people who are particularly susceptible to th e substance released could be incapacitated. The RMP rule includes specific requirements for the worst-case and alternative release scenarios that must be reported by Mead Ohio. These requirements are: - 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) - 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 Mead. Program 3 Processes - Toxic Substances The worst-case release scenario for the two toxic chemicals on site would be a rupture at the bottom of the 224,000 gallon Chlorine Dioxide storage tank full of solution (1 wt%), resulting in a Chlorine Dioxide/Chlorine vapor cloud release. This scenario assumes that all safety devices fail. Also, no administrative controls or passive mitigation were considered for this r elease scenario. The maximum distance to the toxic endpoint (0.0028 mg/l @ 25 degrees C ) calculated using DEGADIS vapor release modeling is 13 miles. Public and environmental receptors are located within the endpoint distance from the Chlorine Dioxide storage tank. The U.S. Census indicates that 70,000 people live within this distance from the storage tank; several public receptors are also located within this distance (e.g., shops, schools, churches, residences, hospitals, parks, etc.) A more likely alternate release scenario for Chlorine Dioxide could occur during start-up, if the Chlorine Dioxide Heater drain valve was inadvertantly left open following a process maintenance shutdown. This model conservatively allows twenty minutes once vapors are detected by local gas monitors and activate alarms, for operations personnel to locate and assess the problem, suit up and close the valve. However, in all likelihood a situation of this type would result in a more timely remote shutdo wn of the process (and the leak flow). Again, the released chlorine dioxide solution would form an evaporative pool with Chlorine Dioxide and Chlorine released as a vapor cloud. The ALOHA modeled distance to the 0.0028 mg/l toxic endpoint is one mile. The U.S. Census indicates that 1700 people live within this distance. Several public receptors are also located within this distance (e.g., part of a residential subdivision, the Mead park and ball fields). There are no environmental receptors within this distance. The alternative release scenario for Chlorine is that a 5/16" gas valve on a full 1-ton chlorine cylinder is left partially open (or leaks through) a 0.10 inch diameter opening, allowing Chlorine gas to escape to the atmosphere. This scenario assumes that it would require as much as 30 minutes after Chlorine gas monitors in the area detect the leak, for emergency response personnel to suit up, enter the area, and shut the valve or plug the leak. Using ALOHA modeling, un der normal cylinder pressure (initially) and then in ambient equilibrium, 762 pounds of Chlorine would be released. The modeled distance to a 0.0087 mg/l toxic endpoint is 0.44 miles or approximately 775 yards. The U.S. Census indicates that 170 people live within this distance from the chlorine cylinder location; several public receptors are also located within this distance (e.g., several residences, Tiffin elementary school). There are no environmental receptors within this distance. Accidental Release Prevention Program and Chemical-specific Prevention Steps Mead maintains a number of programs to help prevent accidental releases and ensure safe operation. The accident prevention programs in place at Mead Ohio include: Program 3 Prevention Program. Since 1963, Mead Ohio has used a prevention program to help prevent accidental releases of hazardous substances. Beginning in 1992, Mead formalized this prevention program for the Water Treatment/Chlorine and Chlorine Dioxide Gener ation and Storage processes to comply with the 14 elements of the OSHA process safety management (PSM) prevention program. In 1996, in accordance with the EPA RMP rule, two Program 3 proccesses were identified. RMP requirements for these systems are 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 Mead's prevention program that address the RMP rule prevention program and ERP requirements. Mead Ohio's Prevention Program for the RMP Program 3 Water Treatment/Chlorine and the Chlorine Dioxide Generation and Storage processes consists of the following 12 elements: Process Safety Information Mead Ohio maintains a variety of technical documents (e.g., MSDSs, PSM Process Safety information manuals, etc.) that support the safe operation of its processes. For each regulated process, these documents address (1) physical properties of hazardous substances handled at Mea d, (2) operating parameters of the equipment at Mead, and (3) the technical and design bases, and configuration of the equipment. Mead ensures that this process safety information is available to all Mead employees, the local emergency planning committee (LEPC), and the Chillicothe Fire Department. 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 analysis of the process. Operating parameters are included in the standard operating procedures to enhance the safe operation of the process. These documents are used in (1) employee training, (2) performing process hazard analyses, and (3) the monitoring and maintainence of equipment. Material safety data sheets (MSDS) document the physical properties of hazardous substances handled at Mead, including regulated substances in covered processes. MSDS's for hazardous substances handled in each process are availa ble 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 use in developing emergency response plans. Process Hazard Analysis. In accordance with the Process Safety Management Standard, and to help identify process hazards and generate recommendations that might improve the safe operation of the process, Mead conducts and recertifies process hazard analyses (PHA) of the regulated processes. PHA review teams composed of personnel with process-specific design, operating, and maintainence experience and a leader with process hazard analysis experience are assembled to analyze the hazards of each regulated process. Mead primarily uses a combination of the hazard and operability (HAZOP) methodology in conjunction with What if?/Checklist techniques to review and report the analyses. Recommendations and action items resulting from the analysis are documented and tracked to comp letion. Responsibility to resolve action items are assigned to unit personnel and, where appropriate changes to enhance the safety of the process are implemented. Operating Procedures. Mead process safety personnel, engineers, operators, and supervisors work together to develop and maintain operating procedures to define how tasks related to regulated process operations should be safely performed. The operating procedures (1) are used to train employees and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets. Operating procedures include: Training. Mead Ohio provides basic chemical specific HAZCOM training for all employees. Mead trains employees to safely and effectively perform their assigned tasks. For current hazardous process operations personnel, Mead training programs include both initial and refresher training that cover; (1) general overview of the process (2) the properties and hazards of the substances in th e process, and (3) a detailed review of the process operating procedures and safe work practices. Both oral reviews and written tests are used to verify that an employee understands the appropriate level of training prior to working in, on or around a regulated process. Mechanical Integrity. Mead maintains the mechanical integrity of regulated process equipment to help prevent equipment failures that could endanger workers, the public or the environment. The mead mechanical integrity program includes (1) an inspection and testing program to help identify equipment deterioration and damage before the equipment fails and (2) a quality assurance program to help ensure that new and replacement equipment meet the design standards required for each specific process service. Management of Change. The Mead management of change program evaluates and approves all proposed not-in-kind changes to regulated process chemicals, equipment, and procedures to help ensure that the change does not negatively affect safe operations. For regulated processes, all not-in-kind, non-emergency changes must have prior review and qualified approval before the change can be implemented. This is to prevent inadvertent consequences of a process change, and to ensure any potential hazards created by the change are proactively recognized and addressed, affected process safety information and procedures are updated, and affected employees are notified of the changes. Pre-startup Review. Mead 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: - Construction and equipment are in accordance with design specifications; - Adequate safety, operating, maintenance, and emergency procedures are in place; and - Employee training has been completed. Compliance Audit. Mead audits regulated processes to be certain that the Mead prevention program is effectiv ely addressing the safety issues of its operations. Mead maintains a cross-corporate audit team that includes only personnel knowledgeable in PSM, the RMP rule and in the regulated processes. This team evaluates whether the prevention program satisfies the requirements of the PSM and RMP standards as well as Corporate health, safety and environmental policies; and whether or not the prevention program is sufficient to help ensure safe operation of the process. The findings and recommendations of these audits are documented. The audit recommendations are the basis for the development and implementation of resolvable action items. Incident Investigation. Mead Ohio investigates all incidents that could reasonably have resulted in a serious consequence to personnel, the public, or the environment so that similar accidents can be prevented. Mead trains employees to identify and report any incident requiring investigation. A qualified investigation team will initiate an investigation within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved, and appropriate process enhancements are implemented. Employee Participation. Mead has a written employee participation program for covered processes to help ensure that the safety concerns of Mead workers are addressed. Mead 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. Safe Work Practices. Compliance with documented standard safe work practices, including hot work safety, confined space entry, and zero energy potential policies, are required operating and maintenance procedures. Hot Work Permits. Mead has an established hot work management system to control spark and flame-producing activities that could result in fires or explosions in covered processes at the Mead facility. In accordance with OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a), Mead implemented a Hot Work Permit Process. Personnel preparing to perform hot work are required to conduct a pre-work inspection of the area and complete a Hot Work Permit Form. A Mead Area Supervisor (in the work area), must review and approve the completed form before the hot work can begin. Training in the use of the Hot Work Permit Form is included in the Mead safe work practices orientation. Contractors. Mead has a management system in place help ensure that contractor activities at the Mead facility are performed in a safe manner. The program reviews the safety record of all contractors to help ensure that Mead hires only those contractors who can safely perform the desired job tasks. Mead instructs contract supervisors as to the hazards of the process on which they and their employees will work,all Mead safe work practices, and Mead emergency response procedures. Mead requires that the contractor supervisors train each of their employees, who will work at Mead before that worker begins work at the facility. Mead periodically reviews contractor's training documents and audits work performance to help ensure safe practices are followed. Chemical-specific Prevention Steps In addition to the required prevention program elements, Mead Ohio has implemented safety features specific to regulated hazardous substance used atthe facility. The following paragraphs describe some of these safety features. Chlorine Dioxide - To avoid the necessity of transporting large quantities of a hazardous material, Mead Ohio produces Chlorine Dioxide at the facility and stores it as a dilute aqueous solution. Chlorine Dioxide is generated on-site using the R8 process in the Chlorine Dioxide generator and piped to an absorber column, where a 1wt% Chlorine Dioxide solution is generated. A diked area around the storage tank further reduces the consequences of a rel ease. Chlorine - Supplied in 1-ton DOT-approved cylinders, Chlorine gas is pulled by vacuum through a regulator directly attached to the cylinder. The vacuum regulator at the cylinder acts as an immediate safety shut-off valve in the event vacuum is lost anywhere downstream of the cylinder. From the regulator, tubing and a piping manifold carry gas to multiple vacuum eductor/mixer stations. At the chlorinator stations, Chlorine is absorbed into process water for use as a dilute liquid oxidizing biocide solution at various pulp stock chests and paper machine locations. If a leak downstream of the cylinder, large enough to break the system vacuum, should occur at any point in the lines feeding the multiple eductors, the regulator valve at the cylinder is designed to automatically shut off all gas flow. Only the quantity of gas between the vacuum regulator and the leak will be released (0.4 pounds maximum). The quantity of gas remaining in the system between the leak and the chlorinat ors will be evacuted to the process. The Chilpaco Chlorine storage/feed facilty is equipped with Chlorine detectors and alarms. All personnel who work in the area maintain the technical training and qualifications required on the system. The cylinders, valves, regulators, carbon steel piping and polyethylene tubing are visiually inspected at least every four hours as part of the day-lab technician's routine round. The tubing lengths from the cylinders to the manifold are replaced on a preventive maintenance routine schedule (even if their condition is still operable). Five-Year Accident History There has been only one accidental release in the past five years that resulted in two recordable toxic vapor exposure injuries. This incident occurred on May 19,1997,when Pulp Mill maintenance personnel responded to a bleach plant flange leaking dilute Chlorine Dioxide solution, without proper respiratory protection. No serious injuries resulted. The recordable status of the injuries was i nvoked when, as a precautionary measure, the two maintenance employees were taken to the plant hospital and received follow-up observation for minor respiratory irritation. The release caused no other significant onsite or offsite effects. An incident investigation team was assembled and the team followed the incident investigation protocol. The team suggested several improvements (including re-training of the affected employees) to the Chlorine Dioxide Respiratory Protection Program that were evaluated and, where appropriate, implemented. Emergency Response Programs Mead coordinates emergency response procedures with the local fire department. Mead employees will respond to minor events that do not have the potential for significant effects (e.g., small fires or small leaks). In the event of a larger fire or release, workers evacuate the area and contact the local fire department. Mead Ohio's personnel and procedures are prepared to coordinate the activities of the facility, an d maintain an emergency response team trained in emergency response procedures. Mead periodically conducts emergency response drills, including annual drills coordinated with the local fire department, the first-response emergency team, the Corporate Crisis Management Team, and local emergency response agencies. Mead employees will respond to minor events that do not have the potential for significant effects (e.g., small fires or small leaks). In the event of a larger fire or release, employees will be evacuated from the area, the Mead Emergency Response Team will be responsible for initial response and assessment, and contact with the Chillicothe City Fire Department as necessary. All Mead Ohio personnel are trained in evacuation procedures. Mead has established a written emergency response program to help safely respond to accidental releases of hazardous substances. The emergency response plan 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 Mead; - Controlling and containing accidental releases of hazardous substances, including the use of emergency response equipment; - Inspecting and maintaining emergency response equipment; and - Reviewing and updating the emergency response plan. The written emergency response plan complies with other federal contingency plan regulations (e.g., the emergency response officials through the local fire department). Mead provides appropriate information to, and regularly communicates with the Local Emergency Planning Committee and Chillictothe and Ross County fire chiefs. Planned Changes to Improve Safety Mead constantly strives to improve the safety of these regulated processes. Through the PSM PHA and Audit programs, incident investigation action items, and on-going employee participatio n in all safety programs, the planning and implementation of changes to reduce risk and improve safety is a continuous process. Mead recently reviewed (PHA conducted 10/98) the Chlorine handling system, upgraded all handling and operating procedures, increased the inspection frequency for chlorine equipment, and took steps to decrease the traffic near chlorine equipment. These changes reduce the likelihood of a Chlorine release cause by degraded equipment or external impact. |