WestvacoCorporation/Chemical Division/Carbon Plant - Executive Summary
RISK MANAGEMENT PLAN PURSUANT TO 40 CFR 68(G) |
Westvaco Chemical Division
Carbon Department, Wickliffe, Kentucky
Westvaco Chemical Division owns and operates a plant that manufactures activated carbon in Wickliffe, Kentucky, which is subject to U.S. Environmental Protection Agency (EPA) regulations governing Accidental Release Prevention (ARP) Requirements: Risk Management Programs under Section 112(r) of the Clean Air Act (40 CFR Part 68). This Risk Management Plan (RMPlan) has been developed in accordance with the requirements specified under 40 CFR Part 68, Subpart G. The RMPlan certifies that Westvaco Chemical Division has instituted a Risk Management Program at the Wickliffe, Kentucky, facility that is in compliance with U.S. EPA ARP requirements.
The RMPlan includes an Executive Summary and Data Elements. This document identifies the applicable corporate policies and risk management systems, including comprehensive accident prevention and emergency response p
rograms. In addition, this RMPlan identifies a set of worst case and alternative release scenarios, the potential off-site consequences of those releases, and the facility's five year
accidental release history. This RMPlan certifies that prevention and emergency response programs are in place so as to minimize risks to workers and the potentially affected public.
1.0 WESTVACO CHEMICAL DIVISION ACCIDENTAL RELEASE AND EMERGENCY RESPONSE POLICIES
1.1 Control of Hazardous Materials
Westvaco strives to conduct its business in strict confor-mity with all applicable laws and in a safe and respon-sible manner. Westvaco has always placed the very highest priority on the safety and health of its employees and members of the communities in which it operates.
The management at the Wickliffe, Kentucky Chemical Division facility, by utilizing effective process safety management is knowledgeable on a current basis as to materials which are present and aware of the possible risk associa
ted with their handling, storage, use, discharge, spill, disposal, or release. Material Safety Data Sheets (MSDS) are maintained as required and reviewed on a current basis.
The Wickliffe, Kentucky Chemical Division facility is designed, constructed, inspected, maintained and operated in a manner so as to minimize the risk of exposure to employees and the public at large to hazardous materials and in conformity with all governmental regulations and corporate guidelines. The facility maintains inspection records and up-to-date procedures to ensure that control of hazardous materials is maintained at all times. The procedures include provisions for the periodic testing, review, and update of the emergency response programs. Changes in protective technology are monitored, and when found to be more effective, the need for change should be promptly considered. In addition, at a minimum of every three years, the facility will undergo a comprehensive process safety management compliance
The functions of environmental protection, property conservation and safety and health are to be coordinated so that the most effective and practical protection of employees, public and environment from hazardous materials is achieved and regulatory reporting requirements are met.
All employees are trained and periodically retrained in a manner appropriate to their possible exposure to materials which are considered hazardous. This includes methods for detection of the presence or release of hazardous materials, the physical and health hazards of the materials, and methods for protecting themselves and co-workers. The information provided by MSDS is reviewed with employees on a current basis.
The Wickliffe, Kentucky Chemical Division facility coordinates its safety and emergency response program with local community emergency response officials to insure safe, effective, and swift response to emergencies in the workplace. This includes forthrightly disclosing to the commu
nity, through its emergency response officials, facts regarding the hazards and risks in operating the facilities, the prevention techniques in place, and assistance in devising the most appropriate and effective protection plans for the community and the plant.
The Chemical Division Manager, and the Corporate Property Conservation Manager, are specifically assured in writing of compliance with the Control of Hazardous Materials Policy at the Wickliffe Chemical Division facility on an annual basis. The Corporate Property Conservation Manager will provide annual written confirmation of compliance to the Chairman and the President.
The Wickliffe Chemical Division facility promptly investigates, corrects, and reports in writing to the Division Manager and the Corporate Property Conservation Manager all incidents involving hazardous materials having caused, or having the potential for causing, injury or loss.
Clear understanding and careful observance of this policy throughout the organ
ization is of great importance to Westvaco, its employees, and the public. While line management has the primary responsibility for providing safe conditions and for creating a climate in which the whole organization shares in the concern for both employee and community safety and health, each member of the organization plays a key role in assuring success.
1.2 Emergency Response Coordination with the Westvaco Fine Papers Division
Westvaco Corporation operates two separate industrial operations at two sites in Wickliffe, Kentucky: a pulp and paper mill operated by the Westvaco Fine Paper Division and an activated carbon plant operated by the Chemical Division. The two facilities, located on adjacent properties separated by a rail line, belong to different SIC codes and are under separate management. Each facility has greater than threshold amounts of substances regulated under 40 CFR Part 68 promulgated under Section 112(r) of the Clean Air Act. A separate Risk Management Plan (R
MPlan) is submitted for each facility, because each has an independent risk management program. However, the two facilities share information on hazardous chemicals and coordinate their emergency response plans. Thus, the Westvaco Chemical Division facility has a program in place to notify the neighboring Fine Papers Division facility in the event of an accidental release. Because it would not be necessary for the Local Emergency Planning Committee (LEPC) or other on-site emergency responders to coordinate intra-company emergency response, it is appropriate not to consider the Fine Paper Division as an off-site receptor.
1.3 Risk Management System
Westvaco Chemical Division has developed a management system to implement and maintain compliance with the Accidental Release Prevention (ARP) and related chemical safety and emergency response programs. This management system identifies lines of responsibility for the entire program and each of its key elements.
This management sys
tem is coordinated with the system developed by Westvaco's neighboring Fine Papers Division.
2.0 PROCESS AND SUBSTANCE SUBJECT TO 40 CFR PART 68
The Westvaco Carbon Plant produces activated carbon from saw dust. Activated carbon is a microcrystalline form of carbon with internal porosity and a large specific surface area. This carbon is typically used for the purification of gas and liquid streams. Activated carbon is used widely in industrial processes for the recovery and recycling of volatile organic compounds, and can also be used as a purifying filter for breathing air. All automobiles produced in the U.S. since the early 1970s and most foreign-built automobiles are equipped with an emissions control system which utilizes activated carbon to adsorb gasoline emissions. These emissions would otherwise be released to the atmosphere and contribute to the formation of ozone, a health hazard. Activated carbon is also used in the treatment of drinking water to remove toxic and
other organic material.
As with most production processes, the activated carbon production process uses several different chemicals. One of these chemicals is anhydrous ammonia, a chemical most commonly used on crops to provide nitrogen for plant growth. Anhydrous ammonia is a colorless liquid or gas which is readily detectable by its extremely pungent odor. In sufficient concentrations, anhydrous ammonia is an eye, skin, and/or inhalation irritant. For this reason, anhydrous ammonia is regulated under the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Standard at 29 CFR Part 1910.119 and the EPA risk management rule at 40 CFR Part 68.
Anhydrous ammonia is delivered to the site via tank truck and stored in a diked above-ground tank with a nominal 12,000 gallon (62,040 lb) capacity. For ammonia processes, the threshold quantity for coverage under 40 CFR Part 68 is 10,000 lb. Figure 2-1 provides the layout of the Westvaco Chemical Divisi
on facility, with the storage area for the regulated process and the on-site transport route highlighted. Once the tank truck is in the unloading area, Westvaco staff isolate the area from vehicular traffic and unlock the ammonia valves at the unloading station. A Westvaco employee provides surveillance of the entire transfer operation from a safe distance. Emergency shut-off valves can be activated remotely in the event of a spill or hose rupture.
The EPA Risk Management Regulation identifies three levels of requirements for industrial processes. Program 1 can be applied to any process which has not had a "significant" release of a regulated substance over the five year period prior to the June 1999 compliance date and for which the worst-case release does not affect "public receptors" (e.g., residences, parks and recreation areas, commercial/industrial facility, hospitals). Program 2 applies to any process that is ineligible for Program 1 and is not subject to Program 3. Prog
ram 3 applies to all processes, such as those present at the Westvaco Chemical Division facility, that are subject to the Occupational Safety and Health Administration (OSHA) Process Safety Management Standard (PSM), with which the Westvaco Chemical Division facility is in compliance. The Westvaco Accidental Release Prevention Program elements are adopted directly from the compliance program for the PSM standard, consistent with the Level 3 RMP Program requirements for this Westvaco facility under 40 CFR Part 68. Program 3 related information is included in the Data Elements section of the RMPlan.
3.0 RELEASE SCENARIOS
For the purposes of developing and maintaining adequate RMPlan's, the EPA has defined in its governing rules and guidance a series of modeling methods and assumptions which are to be utilized as administrative guides for planning purposes. In order to standardize and simplify to a practical level the many factors that can potentially occur in an accidental releas
e situation, some of these assumptions may not take into account the available preventive measures or mitigation methods that would diminish or even eliminate the implied risks that are suggested by "worst-case" analyses. For that reason, both the results for the standardized "worst-case" defined by the EPA methods and an alternative case, which is believed by Westvaco to more realistically represent situations that may possibly, but rarely, occur within the lifetime of the facility, are presented and described. The actual incident history for this facility over the last five years has been reviewed. No accident has resulted in reportable on-site injury, off-site injury, emergency response, or damage to property or the environment
However, to ensure that mitigation measures and emergency response plans are appropriate, potential release scenarios are considered. Thus, the sections of the RMPlan which discuss both the worst case and the alternative case, believed to be somewhat mor
e probable, are meant to provide the data necessary to develop and evaluate possible improvements in the overall safety provided by the programs which constitute the Westvaco ARP program.
3.1 Worst-Case Release for Toxic Substances
As defined by 40 CFR Part 68, a worst-case release of a gas liquefied under pressure is a 10-minute ground-level release of the entire tank contents, taking into account passive and administrative controls that limit the maximum quantity. The worst-case release scenario for the Westvaco Chemical Division facility is a gaseous release from the anhydrous ammonia storage tank dispersed under stable meteorological conditions (see section 3.1.1, below). The worst case scenario involves a quantity of 10213 gallons (52,800 lb) of ammonia, which is less than the nominal size of the tank. The ammonia storage tank is never filled to its "capacity" of 12,000 gallons. Administrative procedures and passive controls limit the quantity of ammonia in the tank. The sta
ndard operating procedure is to fill the tank to no more than approximately 85 % by volume, to allow for the volumetric expansion of ammonia. A passive control device, which consists of a liquid return line to the delivery truck, prohibits filling the tank above 85% of capacity. The quantity of ammonia to include in a worst-case release was identified by considering these administrative and passive controls.
3.1.1 Dispersion Conditions
Meteorologists have defined six "atmospheric stability classes," A through F, each representing a decreasing degree of turbulence in the atmosphere. The most turbulent condition is stability A, which is associated with light winds and very strong solar heating. Stabilities B and C are characterized by progressively weaker solar heating and stronger winds. Neutral or D stability occurs when winds are strong or when the sky is overcast. At night the earth's surface cools, causing the lower atmosphere to stabilize and become less turbulent. Stabi
lity E (moderately stable) corresponds to partly cloudy conditions with moderate winds. Stability class F (very stable) represents a very low level of turbulence due to overnight radiational cooling and weak winds. EPA requires that worst-case analyses be conducted using stability class F and 1.5 m/sec wind speed. Analysis of three years of meteorological data from the 10 m level of an instrumented tower at the Paducah, WSO Airport indicates that these dispersion conditions occur about 13% of the time.
To describe aerodynamic surface roughness for modeling purposes, EPA has established roughness categories based on land-use type. 'Urban' surface roughness indicates areas where there are many obstacles, such as industrial buildings or trees. 'Rural' indicates that there are no buildings in the immediate vicinity of a facility and that the terrain is generally flat and unobstructed. The Westvaco Carbon Plant and immediate vicinity are clearly urban in nature with areas comprised
of large structures, while the area surrounding is more rural, containing small buildings, parking lots, and open land. In order to report the most conservative 'distance to toxic endpoint' estimates, Westvaco has elected to model the worst-case and alternative release scenarios assuming 'rural' surface conditions. However, it should be noted that under actual conditions, plume dispersion would be enhanced by the 'urban' type surfaces located near the facility, and result in shorter distances to toxic endpoint.
The risk management rule dictates that pressurized gases must be assumed to be released in the vapor state, regardless of whether an actual release would be in the gaseous or liquefied form. Thus, while the dike under the anhydrous ammonia tank provides mitigation, it cannot be considered to have an effect on the worst-case release rate. Hypothetical events that could result in a release of comparable magnitude as this worst-case release include a compl
ete break of the 2" line at the bottom of the ammonia storage tank or a sudden failure of the tank, perhaps due to a major earthquake in combination with an unusually high storage pressure, due to external fire or process malfunction.
In the event of such a sudden release, however, it is likely that both gaseous and liquefied ammonia will be released simultaneously, and liquid ammonia would likely be contained in the dike. The dike would therefore substantially reduce the rate of release to the air and associated off-site migration. The dike would also isolate a liquefied ammonia release from the sewer lines to the wastewater treatment system and serve to protect any nearby workers from the volatile liquid. The possibility of a worst-case type of scenario is extremely remote and virtually prohibited, given the design of the ammonia storage system and inspection and maintenance measures that Westvaco has taken as part of its accident prevention program.
Worst-case analysis may ove
rstate the hazard associated with an ammonia release. Given that the worst case is a 10-minute release with a 10-minute averaging time, the extent of the emergency response planning zone is somewhat overes-timated because the toxic endpoint used to calculate a distance is appropriate to exposures up to an hour (see section 3.1.3).
3.1.3 Modeling Method
Worst-case dispersion modeling to determine the distance to toxic endpoint was conducted using the U.S. EPA's RMP*COMP (Version 1.06) software. RMP*COMP implements the consequence analysis calculations set forth in the EPA's Off-site Consequence Analysis Guidance (OCAG). Only passive mitigation (e.g., dikes, enclosures) and administrative controls may be accounted for in the evaluation. As seen in Figure 3-1, the resulting emergency response planning zone is defined by a circle centered at the ammonia storage area with a radius equal to the distance to toxic endpoint of 4.4 miles (23230 ft.). Beyond this distance, a release of am
monia would not be expected to pose a significant hazard to the public.
The toxic endpoint chosen by the EPA for ammonia is 200 parts per million (ppm). This level is the Emergency Response Planning Guideline, Level 2 (ERPG-2), which was developed by the American Industrial Hygiene As-sociation. An ERPG-2 is "the maximum airborne con-centration below which it is believed that nearly all individuals could be exposed for up to 1 hr without experiencing or developing irreversible or other serious health effects, or symptoms which could impair an individual's ability to take protective action."
Within the emergency planning zone for ammonia, the outdoor concentration at a stationary receptor, averaged over 10 minutes, could exceed 200 ppm. Because this exposure level assumes a stationary receptor, it does not account for evasive or protective action. Actions that could reduce or eliminate exposure to ammonia include avoiding the plume transport path, relocating beyond the plannin
g zone, or seeking shelter in a building.
3.1.4 Public and Environmental Receptors
The worst-case planning zone encompasses a resident population of approximately 2,200, based on the 1990 Federal Census, and estimated by applying EPA's LANDVIEW III program. Public receptors were identified using 1:24,000 scale U.S.G.S maps, which were supplemented with a local map of the Wickliffe area (DeLorme Street Atlas USA, Version 5). The potential worst-case planning zone includes residential housing, public recreation areas and commercial areas. There are no schools, hospitals, or prisons within the worst-case endpoint distance. The Peal Land Wildlife Management Area, which is located to the northwest of the Wickliffe facility, is the only environmental receptor identified.
Since the resulting planning zone predicted for the worst-case toxic release potentially affects public receptors, the regulated process at the Westvaco Chemical Division facility is subject to Program 3 requirements.
3.2 Alternative Release for Anhydrous Ammonia
The alternative release examined for anhydrous ammonia corresponds to a hose rupture or coupling failure occurring during transfer from a tanker truck. Liquefied ammonia from the leak could potentially spill into a generally unconfined area outside of the dike. The ammonia release rate has been estimated to be equal to the normal transfer rate of 150 gallons/min (774 lb/min). According to the EPA OCAG, this corresponds to a hose rupture of approximately 0.6 inches in diameter. Release of liquefied gas to the air was conservatively assumed to be at the same rate as the spill because the portion that does not initially flash to a gas upon release would rapidly spread out into a shallow pool until the spill rate equaled the evaporation rate. The spill is assumed to continue for 10 minutes before the truck operator or Westvaco personnel is able to activate the remote emergency shut-off valve.
A complete break of the unloading hose
was also examined as a possible alternative release scenario. A break of this type would result in a large pressure change in the ammonia delivery hose and a greater initial ammonia release rate. An emergency check valve located on the tanker truck is designed to sense the change in pressure due to this type of break and immediately shut down the flow of ammonia. The resulting ammonia spill would be limited to the amount of ammonia contained in the hose. Because the resulting distance to toxic endpoint is expected to be much smaller than the endpoint for the alternative release scenario discussed above, this release is not reported in the RMPlan.
3.2.1 Dispersion Conditions
EPA suggests that alternative release scenarios be analyzed using typical meteorological conditions of D stability, and a wind speed of 3 m/sec. Stability Class D represents conditions of neutral stability, or moderate atmospheric turbulence. A temperature of 77 0 F and relative humidity of 50 percent were al
so used in accordance with the OCAG. Climatological data for Paducah, KY indicate that these conditions are typical. Figure 3-2 depicts the wind rose based on three years of data (1989-91) from the Paducah, WSO Airport. This indicates that the predominant direction of transport is toward the north.
Alternative releases are intended to represent releases that generally have a greater likelihood than the worst-case release and that occur during typical rather than worst-case meteorological conditions. Unlike the worst-case release, alternative releases can account for both passive and active mitigation systems. In accordance with EPA Guidance, the alternative release does not necessarily represent the type of release that the PSM hazard analysis and/or accident history indicate is the most likely to occur, but rather a release that is somewhat more likely than the worst-case release and that generally still has the potential to affect off-site receptors.
2.3 Modeling Method
Alternative dispersion modeling to determine the distance to toxic endpoint was conducted using the U.S. EPA's RMP*COMP (Version 1.06) software. As discussed in Section 3.1.1, the modeling was performed using the conservative assumption of a rural surface roughness. The resulting planning zone is defined by a circle centered at the ammonia storage area with a radius equal to the distance to toxic endpoint of 0.50 miles (2640 ft.). Figure 3-3 shows the circle that encompasses the alternative-release planning zone.
3.2.4 Public Receptors
The residential population within a circular area of this radius centered at the point of release is estimated to be approximately 30 persons. No environmental receptors would be affected.
4.0 ACCIDENT PREVENTION
The process subject to the Risk Management Regulation is also subject to the OSHA PSM Standard with which the Westvaco Chemical Division facility is in compliance. PSM governs the same process and regulated subs
tance at the site that is subject to 40 CFR Part 68. As such, because Westvaco Chemical Division has complied with PSM, it is also in compliance with the Prevention Program requirements of 40 CFR Part 68. Westvaco has in-place specific operational programs to address PSM/RMP Prevention Program requirements. Descriptions of the following programs reside on-site at the Carbon Plant.
Preventive Maintenance Program
Tank Integrity Program
Regular Process Hazards Analysis (HAZOP Studies)
Pre-Startup Safety Checks for Changes as Part of Management of Change Program
Incident Review, Diagnosis and Correction (to Prevent Recurrence)
Written Operating Procedures
Operator Training and Qualification Program
5.0 FIVE-YEAR ACCIDENT HISTORY
In conjunction with the current ARP and PSM programs in place at the Westvaco Chemical facilities, there is a standard management practice that requires immediate internal reporting of unusual events, including those in which any abnormal emission o
f regulated chemicals is observed or suspected. The incident information is reviewed by supervisory staff and a determination is made as to whether a reportable quantity on any chemical listed as requiring reports to regulatory authorities is involved. If so, the appropriate authorities are promptly notified.
Since the facility has been in operation (June 1997), there has been no accident involving any RMP regulated substance that qualifies for reporting under 40 CFR Part 68. This means that no accident has resulted in reportable on-site injury, off-site injury, off-site evacuation or sheltering in place, or damage to property or the environment.
6.0 EMERGENCY RESPONSE PROGRAM
It is the policy of the Westvaco Chemical Division Carbon Department to place the highest priority on employee safety and health, and on protection of the community for all plant-induced environmental conditions. Emergency response plans have been developed to provide protection by providing prompt ac
tion to control an emergency, minimize the amount of released material, and lessen or eliminate the hazards to employees and the community. Proper planning and an organized approach will reduce the effects of emergency events. Prompt internal and external communications, emergency equipment and trained personnel are the key ingredients of this plan. Westvaco policy provides for external communications with local and county-wide response agencies.
The Westvaco Chemical and Fine Paper Divisions in Wickliffe, Kentucky have in place plans to protect both operational integrity, the safety of its workers, and the safety of the surrounding community. The provisions of the Emergency Preparedness Plan for the Carbon Plant address chemical releases as well as a wide range of natural and man-made event, including fire, explosion, utility failures, earthquakes and extreme meteorological events. Procedures are in place to classify events to expedite effective emergency shutdown.
ffe Carbon Plant utilizes early detection monitors to notify plant personnel of possible ammonia releases. This, coupled with a fully trained Hazardous Materials Response Team ( employees on all shifts trained to the technician level), ensure that emergency situations regarding ammonia are handled quickly and professionally. Emergency response is coordinated by the Shift Supervisors who are trained Incident Commanders. If outside response agencies are needed, they are notified via the Ballard County dispatcher. Provisions for making this notification are located in the plant's Emergency Response Procedures.
7.0 PLANNED CHANGES TO IMPROVE SAFETY
Westvaco Chemical Division, under the recent RMP program, as well as its existing PSM and earlier Superfund Amendments and Reauthorization Act (SARA) Title III Community Right-to-Know Act compliance programs, has organized its manageme-nt system to effectively address all hazards and potential risks. Both the advanced planning aspect
s of process design, operating procedures, emergency prepared-ness, and the operational elements of system maintenance, safe operating practices and ongoing personnel training are necessary to support a continual improvement in facility safety. These programs are all documented so that needed information about the safe handling of all chemicals present at the facility is continuously available to employees, and can be readily interpreted by emergency response team staff and the Site Emergency Coordinator when questions arise from public safety officials on potential risks to the community. All of these features of the RMP and the integrated risk management program at this site lead to operations that are safe today, but will be even safer tomorrow.