Westvaco Corporation, Charleston Chemical Plant - Executive Summary

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Westvaco Chemical Division owns and operates a chemical manufacturing facility in North Charleston, South Carolina which is subject to U.S. 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 (RMP) has been developed in accordance with the requirements specified under 40 CFR Part 68, Subpart G.  The RMP certifies that Westvaco, Chemical Division has instituted a Risk Management Program at the North Charleston, South Carolina facility that is in compliance with U.S. EPA ARP requirements.  
The RMP includes an Executive Summary and Data Elements following the format published by U.S. EPA.  In addition to identifying the applicable corporate policies and risk management systems, including comprehensive accident prevention and emergency response programs, this RMP document identifies the worst case release scenario and the facility's five yea 
r accidental release history.  
1.1 Control of Hazardous Materials 
Westvaco strives to conduct its business in strict conformity with all applicable laws and in a safe and responsible 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. 
This policy applies to the North Charleston, SC facility and to each location of Westvaco and its subsidiaries and to all materials which may be hazardous to health and/or the environment, whether solid, liquid or gaseous. 
It is the responsibility of the Chemical Division Manager and the Corporate Research Director to insure that each location within their respective authority is in full compliance with the provisions of this policy. 
Management at each company facility, by utilizing effective process safety management, is knowledgeable on a current basis as to ma 
terials which are present and aware of the possible risk associated 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. 
Westvaco facilities are 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.  Each facility maintains inspection records, up-to-date procedures and checklists to insure that control of hazardous materials is maintained at all times.  The procedures and checklists 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 is promptly considered.  In addition, at a minimum of every three years, each affected facility  
undergoes a comprehensive process safety management compliance review. 
The functions of environmental protection, property conservation and safety and health are coordinated at each facility 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 of detection of the presence or release of hazardous materials, the physical and health hazards of the materials, and methods for protecting themselves, co-workers, and the public.  The information provided by MSDS is reviewed with employees on a current basis. 
Each location 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.  T 
his includes forthrightly disclosing to the community, 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. 
Each Division Manager, and the Corporate Property Conservation Manager, is specifically assured in writing of compliance with the Control of Hazardous Materials Policy in his division on an annual basis.  The Corporate Property Conservation Manager provides annual written confirmation of compliance to the Chairman and the President. 
Each location 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 organization is of grea 
t 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 Kraft Division 
Westvaco Corporation operates three separate industrial operations at a site in North Charleston, South Carolina, two of which are subject to Section 112(r) of the Clean Air Act.  These two facilities are a pulp and paper mill operated by the Westvaco Kraft Division and a chemical manufacturing plant operated by the Chemical Division.  The third facility is an energy co-generation plant (COGEN South) and is not subject to this rule.   
The two subject facilities are located on adjacent properties, but 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.  A separate Risk Management Plan (RMP) is submitted for each facility, because each has an independent risk management program, but utilizes an emergency response staff and a single emergency management system.  These two facilities also 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 Kraft Division facility in the event of an accidental release.  Because it would not be necessary for the LEPC or other on-site emergency responders to coordinate intra-company emergency response, it is not appropriate to consider the Kraft Division as off-site for the RMP.   
1.3 Risk Management System 
Westvaco Chemical Division has developed a management system to implement and maintain compliance with the ARP and related chemical safety and emergency response programs.  This management s 
ystem identifies lines of responsibility for the entire program and each of its key elements. 
This management system is coordinated with the system developed by Westvaco's neighboring Kraft Division. 
The Westvaco Chemical Division facility manufactures industrial intermediates (kraft crude tall oil, modified fatty acids and polychemical products) using raw material supplied through pipeline by the neighboring Westvaco Kraft Division facility and other material supplied by truck and rail from external sources.  Chemical manufacturing processes at the facility utilize a number of chemicals, some of which are regulated under 40 CFR Part 68.  At the Chemical Division facility, only polychemicals production contains threshold amounts of a regulated substance, formaldehyde. 
The polychemicals process area includes a number of reactors that produce a variety of products. Formaldehyde is present in the form of an aqueous solution and 
stored at ambient temperature in tanks in the polychemicals process area. Formaldehyde is delivered to the site via tank truck in the form of a 37% solution and stored in an above ground tank with a 30,000 gallon (270,000 lb) capacity.  The tank is surrounded by a 30 ft x 30 ft dike that provides passive mitigation  by limiting the surface area of a spill. 
The EPA Risk Management Regulation identifies three levels of requirements defined as "programs".  EPA recognizes that some regulated processes would not pose an off-site hazard in the event of an accidental release.  Such processes are classified as Program 1.  Program 1 is applicable to any process for which it can be demonstrated that the public would not be adversely affected by a release. Thus, to qualify for Program 1, a facility with a regulated toxic chemical needs to meet two criteria.   
1) no release over the most recent 5-year period has resulted in off-site injury or environmental damage; and  
2) dispersion modeling d 
emonstrates that a worst-case release (as defined by the regulation) will not result in concentrations at public receptors that exceed the toxic endpoint. 
Westvaco has determined that the polychemicals production process that uses formaldehyde qualifies for Program 1.  Program 2 and 3 are applicable to processes that do not qualify for Program 1.  Program 3 applies to processes that are subject to Occupational Safety and Health Administration (OSHA) Process Safety Management Standard (PSM) or listed among nine North American Industrial Classification System (NAICS) codes.  Otherwise, a process would be subject to Program 2.  If a change were to occur such that the polychemicals process no longer met the Program 1 criteria, it would be subject to Program 3.  This is because that process belongs to a listed NAICS code (325199, industrial organics) and is subject to PSM. 
The Risk Management Plan requirements for Program 1 processes are as follows: 
* Registration 
* Accident history 
* Ha 
zard assessment for the worst-case release 
* Coordinate emergency response procedures with local emergency planning and response organizations 
* Certification 
The Hazard Assessment under the ARP program consists of two parts; 1) a review of the five-year accident history involving regulated substances in the covered process and 2) a modeling evaluation of the impact associated with an accidental release.  Because there have been no accidental releases during the most recent five-year period that had an off-site impact and modeling of a worst-case release shows that off-site concentrations of formaldehyde would not exceed the endpoint concentration , the Westvaco Chemical Division is subject to Program 1 ARP requirements. 
3.1 Five-Year Accident History 
In conjunction with the current ARP 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 of 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 of any chemical listed as requiring reports to regulatory authorities is involved.  If so, the appropriate authorities are promptly notified.  
During the past 5 years there has been no accident involving formaldehyde 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 off-site damage to property or the environment.  Thus, the Westvaco Chemical Division facility meets the Program 1 accident history criteria.   
3.2 Worst-Case Release for Toxic Substances 
The worst-case release scenario for the Westvaco Chemical Division facility, as defined by 40 CFR Part 68, is an instantaneous spill of the entire contents of the 30,000 gallon capacity 
formaldehyde storage tank.  The spill area, and thus the rate of evaporation, is limited by a 900 square foot dike which provides passive mitigation.  The formaldehyde is stored at a temperature of 125 deg. F.  The first step in the evaluation is to estimate the evaporation rate of formaldehyde from the solution to the air.  This was computed using estimation methods provided in Appendix B of the  EPA RMP Off-Site Consequence Analysis Guidance (OCAG, May 24, 1996).  The calculation used the vapor pressure of formaldehyde at a 37% concentration  and 125 degree F temperature.   Because active mitigation is not allowed for the worst-case release assessment, it is assumed that the emission continues unabated.  [In reality, Westvaco staff would respond to limit the duration and magnitude of the airborne release.]  U.S. EPA's Off-site Consequence Analysis Guidance recommends that for emissions lasting more than 10 minutes, modeled concentrations should be averaged over a 1-hour period when  
computing the endpoint distance. 
The toxic endpoint established for formaldehyde  by the EPA (10 ppm, 0.012 mg/liter) is based on the Emergency Response Planning Guideline, Level 2 (ERPG-2).  This is defined by the American Industrial Hygiene Association as "the maximum airborne concentration 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."  
For the worst-case, the ARP regulation prescribes that the release occurs during light wind, stable conditions  (atmospheric stability F and 1.5 m/sec wind speed).  Analysis of meteorological data from the National Weather Service at Charleston indicates that these dispersion conditions, which can occur at night under clear skies, are present about nine percent of the time (or about 2 hours per day, on average).  Another important piece of informat 
ion needed for modeling is the type of topography in the area.  Because of the large number of structures, tanks and buildings at the chemical plant, adjacent paper mill and vicinity, the area is characterized by  an "urban" dispersion environment.  
Emissions of formaldehyde, released from the diked area,  become mixed with the air passing over the dike and transported downwind.  Because formaldehyde has a density nearly identical to that of air, it mixes readily with the air and disperses passively. Dispersion modeling of the worst-case release was performed with the U.S. EPA SCREEN3 model. This model was selected because it can simulate all of the features of the worst-case formaldehyde release: area source, continuous emissions, passive dispersion, urban dispersion environment and 1-hour averaging time.   
The resulting endpoint distance from the formaldehyde storage tank is 0.10 mile (530 ft).  Beyond this distance, according to the criterion established by the regulation, the wor 
st-case formaldehyde release would not pose a significant health hazard.  The nearest Westvaco facility fenceline is located about 900 ft to the south of the formaldehyde storage tank.  As such, concentrations exceeding the endpoint concentration are isolated within the confines of the Westvaco North Charleston facility and such that no public or environmental  receptors would be affected by a worst case release.  This meets the worst-case modeling criteria for Program 1.   
3.3 Program 1 Applicability 
Since the modeled endpoint distance predicted for the "worst-case" toxic release does not affect public receptors and no accidental release involving formaldehyde has occurred over the past 5 years that has impacted off-site public or environmental receptors, the formaldehyde system in the polychemicals process area at the Westvaco Chemical Division facility is subject to Program 1 Accidental Release Prevention Requirements under CFR Part 68.   
Because the p 
olychemicals process is subject to Program 1, no accident prevention program is required under 40 CFR Part 68.  However, the process is subject to the Occupational Safety and Health Administration (OSHA) Process Safety Management Standard (PSM) with which the Westvaco Chemical Division facility is in compliance. This program minimizes the potential for accidental releases and helps Westvaco maintain a safe facility.  Westvaco has in-place specific operational programs to address PSM Prevention Program requirements.  These include: 
* Preventive Maintenance Program 
* Tank Integrity Program 
* Regular Process Hazards Analysis (HAZOP Studies) and 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 Testing Program 
Consistent with Program 1 requirements, Westvaco coordinates emergency response with the lo 
cal emergency planning and response agencies, including the North Charleston police and fire departments.  
A formal emergency response program is not required under Program 1 provisions of 40 CFR Part 68.  Nonetheless, Westvaco maintains an emergency response program that contains the elements in terms of plans, procedures, equipment, and training required to deal with chemical emergencies. The Westvaco Chemicals emergency response plan is contained in the Integrated Contingency Plan (ICP). This plan, which is coordinated with the Westvaco Kraft Division Emergency Response Plan, identifies the protocols and procedures utilized in an abnormal release or spill event when there is concern that it may lead to an emergency condition.  These plans define the criteria for identifying, classifying, and notifying appropriate emergency response staff of potential emergency events.  This ensures that those with more significant possible consequences receive immediate priority for appropriate eme 
rgency response.  If an abnormal event indicates the potential for the release of a chemical and quantity that may lead to an emergency condition, the site emergency response team is notified and the most appropriate mode of response is determined by the Site Emergency Coordinator, with support from available emergency response and technical advisory staff.   
Training of responsible staff from both the Charleston Chemical Plant and the Kraft Division Emergency Response Team is designed to ensure that reliable communication and coordination occur in any emergency situation.  The Charleston Chemical Plant has a continuous safety improvement program which includes prompt investigation and reporting of all spill- or release-related events, even when there is no immediate threat of off-site exposure.   
Westvaco Chemical Division, under the EPA Accidental Release Prevention program, as well as its PSM and SARA Title III Community Right-to-Know Act  
compliance programs has organized its management system to effectively address hazards and potential risks. These programs are documented so that needed information about the safe handling of 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.
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