International Paper--Ticonderoga Mill - Executive Summary |
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RISK MANAGEMENT PLAN International Paper, Ticonderoga Mill 1. EXECUTIVE SUMMARY International Paper (IP), Ticonderoga mill is committed to operating in a manner that is safe for IP employees, the public, and the environment. As part of this commitment, IP 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 IP and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR '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 IP. This document is intended to satisfy the RMPlan requirement of the RMP rule ('68.150 through '68.185) and to provide the public with a description of the risk management program at International Paper, Ticonderoga mill. 1.1 Accidental Release Prevention and Emergency Response Policies IP is committed to the safety of its employees and the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. IP implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of an accidental release, IP controls and contains the release in a manner that will be safe for workers and will help prevent injury to the public or the environment. 1.2 International Paper and Regulated Substances International Paper, Ticonderoga Mill is a pulp and paper facility with bleaching operations. The facility handles three substances regulated by the RMP rule in sufficient quantities to be covered by the rule: Process Program Level Regulated Substance Proce ss Quantity Pulp Bleaching 3 Chlorine Dioxide (Less than 1%) 11,000 lbs Water Treatment 3 Chlorine 22,000 lbs Effluent Treatment 1 Aqueous Ammonia (30%) 23,000 lbs 1.3 Offsite Consequence Analysis The RMP rule includes specific requirements for the worst-case and alternative release scenarios that must be reported by IP, Ticonderoga mill. These requirements are: -one worst-case release scenario for each Program 1 process (i.e., the effluent treatment/aqueous ammonia process); -one worst-case release scenario for the class of toxic substances in Program 2 and Program 3 processes (i.e., one scenario representing both chlorine and chlorine dioxide); and -one alternative release scenario for each of the toxic substances in a Program 2 or Program 3 process (i.e., chlorine and chlorine di oxide). The following information summarizes the offsite consequence analysis performed by IP, Ticonderoga mill. 1.3.1 Program 1 Processes--Effluent Treatment/Aqueous Ammonia The worst-case release scenario for toxic substances is failure of the 12,000-gallon aqueous ammonia (30 wt%) storage tank in the effluent treatment/aqueous ammonia process. Administrative controls limit the quantity of aqueous ammonia in the tank to 10,800 gallons. A concrete dike around the tank limits the exposed surface area of a pool and thus reduces the evaporation rate. No public or environmental receptors are located within the endpoint distance from the hypothetical release site. 1.3.2 Program 2 and Program 3 Processes--Toxic Substances The worst-case release scenario for toxic substances is failure of a 1-ton chlorine cylinder in the water treatment/chlorine process. This scenario assumes that the entire contents of the cylinder will be released in 10 minutes. This scenario could have off-site impacts. Affected public receptors could include residences, recreational areas, and a small landing strip. The Adirondack Park is a potentially affected environmental receptor. The alternative release scenario for chlorine is shearing off a valve on a 1-ton chlorine cylinder in the water treatment/chlorine process. This scenario assumes that workers require 30 minutes to detect and plug the leak; the entire contents of the cylinder will be released in less than 30 minutes. This scenario could have off-site impacts. Affected public receptors could include residences, recreational areas, and a small landing strip. The Adirondack Park is a potentially affected environmental receptor. The alternative release scenario for chlorine dioxide is a leak in an 8-inch process line that carries 1 wt% chlorine dioxide solution from the generator to the storage tanks. This scenario assumes that the solution is released through the hole for 15 minutes before chlorine detectors alert wor kers that there has been a release and the release is stopped. The process line is located outdoors but within the diked area surrounding the chlorine dioxide tanks. The diked area contains the released chlorine dioxide and limits the exposed surface area of the pool, thus reducing the evaporation rate. No public or environmental receptors are located within the endpoint distance from the hypothetical release site. 1.4 Accidental Release Prevention Program and Chemical-Specific Prevention Steps The RMP rule requires a Program 3 Prevention Program for the pulp bleaching/chlorine dioxide process and water treatment/chlorine process. The following paragraphs describe the prevention program elements at IP that apply to these processes. Safety information. IP maintains a variety of technical documents that are used to help ensure safe operation of the IP processes. Material safety data sheets (MSDSs) document the physical properties of hazardous substances handled at IP, inclu ding regulated substances in covered processes. Hazard review. IP performs and periodically updates hazard reviews of the covered processes to help identify and control process hazards. Checklists are used to guide the hazard review. These checklists include items to help ensure that IP operates and maintains the equipment in a manner consistent with the applicable design specifications, codes, standards, and regulations. Operating procedures. IP develops and maintains operating procedures to define how tasks related to process operations should be performed. The operating procedures are used to (1) train employees and contractors and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets. Training. IP trains personnel in the operating procedures to help ensure safe and effective performance of their assigned tasks. A training documentation file is maintained to help ensure that refresher training is provided, as neces sary. Maintenance. IP properly maintains the process equipment. The IP maintenance program includes (1) procedures to safely guide workers in their maintenance tasks, (2) worker training in the maintenance procedures, and (3) an inspection and testing program to help identify equipment deterioration and damage before the equipment fails. Management of change. The IP 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. Pre-startup review. IP 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; and for a covered process, a process hazard analysis 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. Compliance Audit. IP audits covered processes to be certain that the IP prevention program is effectively addressing the safety issues of IP operations. IP assembles an aud it 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 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. Incident Investigation. IP 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. IP 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. Employee Participation. IP Ticonderoga Mill developed a w ritten employee participation program for covered processes to help ensure that the safety concerns of IP workers are addressed. IP 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. Hot Work Permits. IP 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 IP facility. IP 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 IP safe work practices orientation. Contractors. IP established a program to help ensure that contractor activities at the IP facility are performed in a safe manner. The program reviews the safety records of all contractors to help ensure that IP only hires contractors who can safely perform the desired job tasks. IP explains to the contract supervisors the hazards of the process on which they and their employees will work, IP safe work practices, and IP emergency response procedures. IP requires that the contractor supervisors train each of their employees who will work at IP before that worker begins work at the IP site. IP periodically reviews contractors' training documents and work performance to help ensure that safe practices are followed. Chemical Specific Prevention Steps-Chlorine. Chlorine is supplied in DOT-approved 1-ton cylinders. Chlorine 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 reduc e 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. The quantity is small because of the short pipe length and the vacuum conditions inside the piping. Chlorine detectors and alarms are provided in most areas containing chlorine. Chemical Specific Prevention Steps-Chlorine Dioxide. Chlorine dioxide is produced at the IP facility and stored as dilute aqueous solution. Chlorine dioxide is produced in the chlorine dioxide generators and piped to an absorber column, where a 1 wt% chlorine dioxide solution is generated. Storing this substance as a solution helps to reduce the consequences of a release. A diked area around the storage tank further reduces the consequences of a release. 1.5 Five-Year Accident History IP Ticonderoga Mill has completed a five-year accident history that indicates continued improvement in safe operations at IP. There has been one accidental release of chlorine dioxide from the pulp bleaching process that resulted in two worker injuries. No releases from the water treatment/chlorine process or effluent treatment/aqueous ammonia process have occurred in the last 5 years that have resulted in deaths, injuries, or significant property damage on site, or known deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage offsite. 1.6 Emergency Response Programs IP has established a written emergency response plan that complies with the RMP rule and with other federal contingency plan regulations. This plan has been communicated to local emergency response officials through the local fire department. Regular dialogue is maintained between IP and the local fire chief, and IP provides appropriate information to the fire chief. IP periodically conducts emergency response drills, including annual drills coordinated with the local fire department. |