Potlatch Corp. Idaho Pulp and Paperboard Division - Executive Summary
Risk Management Plan |
1. Executive Summary
The Potlatch Corporation is committed to operating in a manner that is safe for Potlatch employees, the public, and the environment. As part of this commitment, the Idaho Pulp and Paperboard Division in Lewiston, Idaho, has established a system to help ensure safe operation of the processes at its facility. One component of this system is a risk management program (RMP) that helps manage the risks at the Lewiston Mill 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 (RMPlan) describing the risk management program at Potlatch's Idaho Pulp and Paperboard Division. 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
the Lewiston Mill.
The risk management program at the Lewiston Mill consists of 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) - see topics 1.3 and 1.6
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 1.7
Information further describing these elements is provided in this RMPlan.
Although the risk management program at the Potlatch Corporation 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 mill. In fact
, the Lewiston Mill 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.
The Lewiston Mill prevents releases of the hazardous substances used at the facility. When a hazardous substance is used at the mill, 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.
The Lewiston Mill limits damage from a release, if such a release occurs. Potlatch Corporation trains workers to respond to an accidental release, reducing the consequences of a release if it occurs. In addition, the mill's fire department works with the City of Lewiston fire department and with the Lewiston-Nez Perce County Office of Emergency Management to help ensure that injuries and environmental damage will be minim
ized if a release does occur.
The safety program at the Lewiston Mill 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 Potlatch Corporation that are required by the RMP rule.
1.1 Accidental Release Prevention and Emergency Response Policies
Potlatch Corporation 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. The Lewiston Mill 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, installation, operation, and maintenance of processes in the mill; and programs to evaluate the hazards at the Lewiston Mill.
In the event of an accidental release, the Lewiston Mill controls and contains the release in a manner that wil
l be safe for employees and will help prevent injury to the public or the environment. The mill provides response training to its employees, designates an emergency response coordinator to oversee response activities, and coordinates response efforts with the local fire departments. The Potlatch Fire Department is staffed with 19 certified firemen and is manned 24 hours per day. Potlatch has formed a mutual aid agreement with the City of Lewiston, Port of Wilma Fire Department, City of Clarkston, Asotin County Fire Protection District No.1, City of Asotin, and Washington State University. Response activities have also been discussed with the Lewiston-Nez Perce County Office of Emergency Management.
In order to effectively implement these policies, the Lewiston Mill established a management system headed by the Environmental Manager to oversee RMP-related activities.
1.2 Facility Information and Regulated Substances
The Idaho Pulp and Paperboard Division of Potlatch Corporation
operates an integrated bleached kraft mill that employs approximately 950 full-time workers. The mill produces approximately 1,450 tons per day of bleached kraft pulp and operates two coated paperboard machines. The mill also supplies bleached kraft pulp to Potlatch's Consumer Products Division, which manufactures tissue and towel products. As part of this manufacturing process, Potlatch Corporation handles several regulated substances in sufficient quantities to be covered by the RMP rule, as shown in the following list of RMP-covered processes at the Lewiston Mill.
Process: Chlorine Unloading and Transfer
Program Level: 3
Regulated Substance: Chlorine
Process Quantity: 1,080,000 lb
Process: Chlorine Dioxide Generation, Storage, and Transfer
Program Level: 3
Regulated Substance: Chlorine Dioxide
Process Quantity: 36,000 lb
1.3 Offsite Consequence Analysis
Potlatch Corporation 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 consists of evaluating both worst-case release scenarios and alternative release scenarios. Potlatch Corporation does not expect a worst-case release scenario to ever occur. The alternative release scenarios were selected to help the Lewiston-Nez Perce County Office of Emergency Management improve the community emergency response plan. An alternative release scenario represents a release that (1) might occur at a facility like the Lewiston Mill and (2) would result in the greatest potential offsite consequences if the release occurred.
The RMP rule includes specific requirements for the worst-case and alternative release scenarios that must be reported by the Lewiston Mill. These requirements are:
* one worst-case and one alternative release scenario for chlorine, and
* one alternative release scenario for chlorine dioxide.
The following information summarizes the offsite conseque
nce analysis performed by the Lewiston Mill.
1.3.1 Chlorine Unloading and Transfer
The worst case release scenario for toxic substances is the rupture of a 90-ton chlorine rail car. The maximum distance to the toxic endpoint concentration is 7.7 miles. The U. S. Census indicates that 43,000 people live within this distance from the mill. Several public receptors are located within this distance (e.g., the Snake River, part of the Nez Perce Reservation, the City of Lewiston, and part of the City of Clarkston). Environmental receptors such as Hells Gate State Park and Nez Perce National Historical Park are also located within this distance.
The alternative release scenario for chlorine is the rupture of a 2" chlorine transfer line to the bleach plant mixers. This scenario assumes that the release occurs outside a building and that workers require 20 minutes to detect and stop the leak. The maximum distance to the toxic endpoint is 2.3 miles. The U. S. Census indicates that 9,0
00 people live within this distance from the mill. Several Lewiston neighborhoods are located within this distance. There are environmental receptors within this distance.
1.3.2 Chlorine Dioxide Generation, Storage, and Transfer
No worst-case scenario is reported for chlorine dioxide because the effects of the chlorine worst-case scenario exceed those of the worst-case scenario for an accidental release of chlorine dioxide. The alternative release scenario for chlorine dioxide is the rupture of a 3" chlorine dioxide solution (1 wt%) transfer line from the storage tank to a bleach plant mixer. This scenario assumes that the solution is pumped through a severed line at 230 gallons per minute, and workers require 20 minutes to detect the release and stop the transfer pumps. 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 0.90 mile. The U. S. Census indicate
s that 1,800 people live within this distance from the mill. There are environmental receptors within this distance.
1.4 Accidental Release Prevention Program and the Chemical-specific Prevention Steps
Since its inception in 1951, the Lewiston Mill has used a prevention program to help prevent accidental releases of hazardous substances. Beginning in 1992, the mill formalized this prevention program for both the Chlorine Unloading and Transfer and the Chlorine Dioxide Generation, Storage, and Transfer processes to comply with the 14 elements of the OSHA process safety management (PSM) prevention program. In 1996, the EPA RMP rule established similar requirements for Program 3 processes. The following sections briefly describe the elements of the Lewiston Mill's Program 3 prevention program that address the EPA RMP rule prevention program requirements.
1. Process Safety Information. Potlatch Corporation maintains a variety of technical documents that are used to help ensure saf
e operation of the mill processes. These documents address (1) physical properties of hazardous substances handled at the Lewiston Mill, (2) operating parameters of the equipment, and (3) design basis and configuration of the equipment in the mill. The Lewiston Mill ensures that this process safety information is available to all Potlatch employees, the Lewiston-Nez Perce County Office of Emergency Management, and the Lewiston Fire Department.
Material safety data sheets (MSDSs) document the physical properties of hazardous substances handled at the Lewiston Mill, including regulated substances in RMP-covered processes. MSDSs for hazardous substances handled in each process are available to mill operators for ready reference. In addition, MSDSs are provided to the Lewiston-Nez Perce County Office of Emergency Management and the Lewiston Fire Department for 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:
* operating parameters
* block flow or simplified process flow diagrams
* process chemistry
* maximum intended inventories
* safe upper and lower limits for parameters such as temperature, pressure or flow
* consequences of deviation from established operating limits
* design basis and configuration of equipment
* piping and instrument diagrams, including materials of construction
* electrical classification
* safety systems
* applicable design codes and standards
* design basis for relief and ventilation systems
When important information was not available from the design documents, it was developed through special projects. 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, and (3) to help maintain the equipment.
2. Process Hazard Analysis. The Lewiston Mill performs and periodically updates process hazard analyses (PHAs) of the covered processes to help identify process hazards and generate recommendations that might improved 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. The Lewiston Mill primarily uses the hazard and operability (HAZOP) technique 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 mill personnel and, when appropriate, changes to enhance the safety of the process are implemented.
3. Operating Procedures. Potlatch Corporation 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, and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets. Lewiston Mill employees 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.
4. Training. Potlatch Corporation trains workers to safely and effectively perform their assigned tasks. The Lewiston Mill 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, and (3) a detailed review of the process operating procedures and safe work practices. Employees who work closely with hazardous materials receive specialized training. Demonstrations and employee observa
tions are used to verify that an employee understands the training material before the employee can resume work in the process.
5. Mechanical Integrity. The Lewiston Mill maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public, or the environment. The 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 service in mill processes. The mechanical integrity program includes:
* specifications for inspection and testing of process equipment
* specifications for replacement parts and equipment
* procedures for inspecting, testing, and maintaining process equipment
* procedures for safe work practices such as lockout/tagout, hot work, confined space entry, and line or equipment opening
ining of maintenance personnel
* documentation of maintenance activities
6. Management of Change. The Potlatch 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. Process 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 of 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.
7. Pre-startup Review. The Lewiston Mill 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
* employee training has been completed
* 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.
8. Compliance Audit. The Lewiston Mill audits covered processes to be certain that the prevention program is effectively addressing the safety issues of Potlatch operations. The mill assembles an audit team that includes personnel knowledgeable in the RMP rule and in the process, and this team evaluates whether the prevention program satisfies the requirements of the RMP rule and whether the prevention program is sufficient to help ens
ure 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. The Lewiston Mill 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. The mill 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.
10. Employee Participation. Potlatch Corporation developed a written employee participation program for covered processes to help ensure that the safety concerns of Lewiston mill employees are addressed. The Lewiston Mill encourages active participation of personnel in t
he 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, employee training, and operating procedures.
11. Hot Work Permits. The Lewiston Mill 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 mill. Potlatch Corporation 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 Shift Supervisor reviews the completed form before work can begin. Training in the use of the Hot Work Permit Form is included in the Lewiston Mill's safe work practices orientation.
12. Contractors. The Lewiston Mill established a program to help ensure that contractor activities at the mill are perf
ormed in a safe manner. The program reviews the safety record of all contractors to help ensure that Potlatch only hires contractors who can safely perform the desired job tasks. The Lewiston Mill trains the contract supervisors in the hazards of the process on which they and their employees will work, Lewiston Mill safe work practices, and mill emergency response procedures. The mill requires that the contractor supervisors train each of their employees who will work at the mill before that worker begins work at the Lewiston Mill site. The Lewiston Mill periodically reviews contractors' training documents and work performance to help ensure that safe work practices are followed.
1.5 Chemical-specific Prevention Steps
In addition to the required prevention program elements, the Potlatch Corporation has implemented safety features specific to the hazardous substances used at the Lewiston Mill.
Chlorine. Chlorine is supplied in Department of Transportation (DOT) approved 90-to
n rail cars. Chlorine is unloaded in an enclosed building which vents to a caustic scrubber to reduce the likelihood of a release. Chlorine detectors and alarms are provided in areas containing chlorine.
Chlorine Dioxide. Chlorine dioxide is produced at the Lewiston Mill 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 a 1 weight percent chlorine dioxide solution is generated. Storing this substance as a solution helps to reduce the consequences of a release. A curbed area around the storage tanks further reduces the consequences of a release.
1.6 Five-Year Accident History
The Lewiston Mill is proud of its excellent safety record with respect to the generation, storage and use of chlorine and chlorine dioxide. No releases of chlorine dioxide occurred from the Lewiston Mill in the last five years that resulted in
deaths, injuries or significant property damage on site, or known deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off-site.
The Lewiston Mill's five year accident history includes one release of chlorine that occurred on September 25, 1998 that resulted in an OSHA Recordable Incident for one contracted employee working at the mill site. The employee was treated for chlorine inhalation which resulted in no lasting physical impairment. As a result of this incident, Lockout procedures were changed and reviewed with employees.
1.7 Emergency Response Program
The Lewiston Mill 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 Lewiston Fire Department and the public about accidental releases that could reasonably result in offsite consequences
* Providing proper first aid and emergency medical tre
atment to treat accidental human exposure to hazardous substances at Potlatch
* Controlling and containing 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
Potlatch Corporation operates a trained and well-equipped fire department to respond to emergencies within the Lewiston Mill. All mill employees are trained in evacuation procedures. The Potlatch Fire Department periodically conducts emergency response drills and has a mutual aid agreement with the city of Lewiston, Port of Wilma Fire Departments, City of Clarkston, Asotin County fire Protection District No. 1, City of Asotin, and Washington State University. Response activities have also been discussed with the Lewiston-Nez Perce County Office of Emergency Management.
The written emergency response plan complies with other federal contingency plan regulations (e.g., 29 C
FR 1910.38(a), 29 CFR 1910.120(a)) and has been communicated to the Lewiston-Nez Perce County Office of Emergency Management and the Lewiston Fire Department. The Potlatch Fire Chief maintains a regular dialogue with the local municipal fire departments and emergency planning agencies.
1.8 Planned Changes to Improve Safety
The Potlatch Corporation constantly strives to improve the safety of the processes at the Lewiston Mill through both the incident investigation program and a program soliciting safety suggestions from mill employees. The following changes to improve process safety are planned or have recently been completed.
* The Lewiston Mill plans to upgrade its employee training program for chlorine and chlorine dioxide processes. More frequent refresher training will be provided to employees on the written operating and maintenance procedures for these processes.