Red River Mill - Executive Summary
1.0 RED RIVER MILL Risk Management Plan: Executive Summary |
2645 LDEQ Facility ID Number
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
The Red River Mill has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of facility's processes. The Willamette Industries, Inc. (Willamette) policy is to implement reasonable controls to prevent foreseeable releases of substances. However, if a release does occur, trained personnel will respond to, control, and contain the release.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED
Willamette owns and operates the Red River Mill located in Campti, Natchitoches Parish, Louisiana. The Red River Mill is an integrated pulp and paper mill that utilizes the standard Kraft process for the manufacture of unbleached pulp from wood chips and recycl
ed corrugated containers into linerboard.
The Red River Mill was evaluated to determine if any regulated flammable or toxic substances exceeded the threshold quantity. Based on process knowledge, Willamette identified the regulated substances and quantities kept on site. These are the quantities maintained in process vessels and piping at normal operating conditions and does not necessarily represent maximum capacities of the equipment.
The only listed substance, which is stored above threshold quantity at the Red River Mill, is chlorine, which is classified as toxic. Propane, a regulated flammable substance is also stored on site. However, administration controls are in place to limit the propane storage quantity below threshold. Based on worst-case analysis the distance to the endpoint exceeds the distance to public receptors. In addition, the Red River Mill is subject to OSHA PSM. Therefore, the Red River Mill is classified as a Program 3 process under the ARP Program.
-SITE CONSEQUENCE ANALYSIS RESULTS
Toxic Substances - Worst-Case Scenario
The end point for each toxic substance in the ARP regulations is listed in Appendix A to 40 CFR 68 (Table of Toxic Endpoints). Toxic endpoints are based on the Emergency Response Planning Guideline Level 2 (ERPG-2) developed by the American Industrial Hygiene Association. The ERPG-2 represents the maximum airborne concentration below which EPA judged that nearly all individuals could be exposed for up to an hour without experiencing or developing irreversible or other serious human health effects or symptoms. The endpoint for chlorine is listed as 0.0087 milligrams per liter which is equivalent to 3.1 parts per million (ppm).
For worst-case scenarios, according to the "RMP Offsite Consequence Analysis (OCA) Guidance" document, you need only consider the largest amount in the vessel, regardless of interconnections with pipes and other vessels. Therefore, the worst-case is a single chlorine cylinder resultin
g in a total capacity of 2,000 lbs. Using the lookup tables and equations, the distance to endpoint for the worst-case release of chlorine (2,000 lbs) at the Red River Mill was calculated to be 3.0 miles.
Toxic Substances - Alternative-Case Scenario
One single alternative release scenario for each toxic substance is required under the ARP program. A hypothetical, but likely to occur, release scenario has been identified for chlorine as follows. A 1-inch header line on a 2,000-pound cylinder is sheared off, allowing the chlorine to be released. An iterative approach was used to determine an average release rate of 9.9 pounds per minute. The distance to endpoint calculated from the lookup tables and equations is 0.15 miles.
The Red River Mill does not have any flammable substances held above the threshold quantity. Therefore, analyses of worst-case or alternative release scenarios for flammable substances are not required.
GENERAL ACCIDENT RELEASE PREVEN
The following is a summary of the accident prevention program in place at the Red River Mill. Because the processes at the mill that are regulated by the Environmental Protection Agency's (EPA's) risk management program (RMP) regulations are also subject to the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.
Active employee participation and involvement in the development and implementation of the Red River Mill's PSM program is an important step toward achieving the objective to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. Employee involvement will help to ensure that all perspectives regarding PSM are considered, and that the best ideas are implemented. Open communications are enco
uraged between supervisors and employees regarding all safety and health issues.
The Red River Mill strongly promotes employee involvement in safety issues through existing programs. These programs include Central Safety Teams (which are made up of a cross section of employees and supervision), regularly scheduled safety meetings, Hazard Communication, "near-miss" reporting, and special training programs (emergency response training, first aid, etc.).
The Red River Mill actively seeks employee involvement in the development and conduct of all accident prevention activities through the appropriate existing safety programs. Accident and release prevention is discussed at the regularly scheduled safety meetings and/or during special training sessions if necessary. Employees are encouraged to discuss accident prevention with their supervisors if they have questions, comments, or suggestions.
Process Safety Information
Complete and accurate written process safety information (PSI)
concerning process chemicals, process technology, and process equipment is essential to effective PSM and RMP programs and to completing and maintaining a process hazard analysis (PHA). The PSI will be useful to the operators; the team performing the PHA; those in charge of training; contractors; those conducting pre-startup safety reviews; and those in charge of updating the emergency preparedness plans. Process safety information is readily available to all employees.
The Red River Mill keeps a variety of technical documents that are used to help maintain safe operation of the process. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information.
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs).
The mill also maintains numerous te
chnical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised.
Process Hazard Analysis (PHA)
The Red River Mill has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.
The Red River Mill primarily uses the failure mode and effect analysis technique to perform these evaluations. The analyses are conducted using a team o
f people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures when they believe such measures are necessary.
The PHA team findings are forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options in response to PHA team findings are tracked until they are completed. The final resolution of each finding is documented and retained.
To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the mill periodi
cally updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained.
The Red River Mill maintains written procedures that address various modes of process operations, such as; (1) startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures provide guidance for experienced operators and also provide the basis for training new operators. Operating procedures are periodically reviewed and annually certified as current and accurate. The review and certification process involves both operators and technical staff.
intent of the operating procedures is to provide workable, useful, and clearly written instructions for conducting operating activities. To have effective operating procedures, the task and procedures directly and indirectly related to the covered process must be appropriate, clear, consistent, and most importantly, communicated to employees. Operating procedures are specific instructions or details on what steps are taken or followed in caring out the stated procedures. The specific instructions include the applicable safety precautions and appropriate information on safety implications.
In addition to training on operating procedures, the Red River Mill has a comprehensive training program for all employees involved in operating the process. New employees receive basic training in mill operations. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable leve
l. This refresher training is conducted at least every 3 years. All of this training is documented for each operator including the means used to verify that the operator understood the training.
The Red River Mill uses contractors during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the mill has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have appropriate knowledge and skills, (3) are aware of the hazards of their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site specific safety rules, and (6) inform mill personnel of any hazards that they find during their work. This is accomplished by providing contractors with an orientation session that covers (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prio
r to beginning their work. In addition, the Red River Mill evaluates contractor safety programs and performance during the selection of a contractor. Mill personnel periodically monitor contract performance to ensure that contractors are fulfilling their safety obligations.
Pre-startup Safety Review (PSSR)
The Red River Mill conducts a PSSR on any new facility or facility modification that requires a change in process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with design specification and that all-supporting systems are operationally ready. The PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.
The Red River Mill has well established practices and procedures for maintaining process equipment. The basic aspects of this program include (1) training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting equipment deficiencies, when identified, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process.
Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner.
Another integral part of mechanical integrity program is quality assurance. The Red River Mill incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials
and spare parts are used when repairs are made.
Safe Work Practices
The Red River Mill has long standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous substances before process piping and equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely.
Management of Change
The Red River Mill has a comprehensive system to manage changes to all covered processes. This system requires that changes to items
such as process equipment, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change.
The Red River Mill promptly investigates all incidents that resulted in or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to gather the facts, determine the root cause, and develop corrective actions to prevent the reoccurrence of the i
ncident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to the business management team for resolution.
To help ensure that the accident prevention program is functioning properly, the Red River Mill periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to Red River Mill management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained.
CHEMICAL SPECIFIC PREVENTION STEPS
The processes at the Red River Mill have hazards that must be man
aged to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility.
Universal Prevention Activities
The accident prevention program summarized previously is applied to all RMP-covered processes at the Red River Mill. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors.
Specialized Safety Features
The Red River Mill has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in the covered processes:
1. Chlorine detectors with alarms
1. Valves to permit isolation of the process (manual or automated)
2. Redundant equipment and instrumentation (e.g., backup firewate
1. Fire extinguishers and extinguishing systems
2. Personnel trained in emergency procedures
3. Personal protective equipment (e.g., chemical protective clothing, self-contained breathing apparatus)
FIVE YEAR ACCIDENT HISTORY
The Red River Mill has an excellent record of accident prevention. Over the past 5 years there have been no accidental releases.
EMERGENCY PROCEDURE INFORMATION
The Red River Mill maintains a written emergency procedure, which is in place to protect worker and public safety as well as the environment. The procedures are for the possibility of a safety or health hazard if a hazardous substance is accidentally released. The procedures address notification of local emergency response agencies if a release occurs, and post incident cleanup and decontamination requirements. Employees receive training in emergency procedures. The emergency procedure is updated when necessary based on modifications made to the Red River Mill. The e
mergency procedure changes are administered through the Management of Change (MOC) process, which includes informing and/or training affected personnel in the changes.
The overall emergency procedure program for the Red River Mill is coordinated with the Natchitoches Parish, Louisiana, Local Emergency Planning Committee (LEPC). The Red River Mill has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. The Red River Mill conducts periodic emergency drills and provides periodic refresher training to mill personnel regarding the hazards of regulated substances in the plant.