Moss Point Mill - Executive Summary |
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1. EXECUTIVE SUMMARY International Paper (IP) Moss Point Mill is committed to operating in a manner that is safe for IP Moss Point workers, the public, and the environment. As part of this commitment, IP Moss Point has established a system to help ensure safe operations of the processes at the mill. One component of this system is a risk management program (RMP) that helps manage the risks at Moss Point and that complies with the requirements of the Environmental Protection Agency's (EPA) 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 Moss Point. This document is intended to satisfy the RMPlan requirements of the RMP rule and to provide the public with a description of the risk management program at Moss Point. The risk management program at IP Moss Point consists of three elements: 1. Detailed hazard assessments performed to help understand the potential for both on-site and off-site consequences of hypothetical accidental releases of regulated substances 2. Prevention program established to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance 3. Emergency response program implemented to help respond to accidental releases of regulated substances from a covered process. Information further describing these elements is provided in this RMPlan. Although the risk management program at IP Moss Point helps provide assurance that the mill is maintained and operated in a safe manner, it is only one component of the safety program at IP Moss Point. In fact, IP Moss Point 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. Before using a hazardous substanc e at IP Moss Point, less hazardous alternatives are considered. When a hazardous substance is used at IP Moss Point, the mill considers the potential for this substance to adversely effect mill workers, the public, and the environment and takes steps to prevent any such effects. A thorough safety, health and environmental evaluation of all substances is performed and documented prior to the usage of any regulated chemical at IP Moss Point. When a hazardous substance is used at IP Moss Point, the equipment is carefully designed, built and operated to reduce the likelihood of an accidental release. Industry, company and government standards are closely adhered to in the design, construction, and operation of the equipment. IP Moss Point trains workers to respond to an accidental release, reducing the consequences of a release if it occurs. In addition. IP Moss Point works with the local fire department and with the local emergency planning committee (LEPC) to help ensure that inju ries and/or environmental damage will not occur if a release does occur. The safety and environmental programs at IP Moss Point consist 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 programs at IP Moss Point that are required by the RMP rule. 1.1 Accidental Release Prevention and Emergency Response Policies IP Moss Point is committed to the safety of mill employees and the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. IP Moss Point 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 at IP Moss Point; and programs to evaluate the hazards and systems in place at IP Moss Point. IP Moss Point provides response training to mill emergency responders, designates an emergency response coordinator to oversee response activities, and coordinates response efforts with the local fire department. Response activities have also been discussed with the local LEPC. In addition, IP Moss Point evacuates those non essential workers from the affected areas and performs annual evacuation drills for all employees. In order to effectively implement these policies, IP Moss Point has established a management system headed by the Environmental, Health, and Safety Manager and Emergency Response Coordinator to oversee these critical safety related activities. 1.2 IP Moss Point Mill and Regulated Substances IP Moss Point is a fully integrated pulp and paper manufacturing facility that produces bleached white paper products. Chlorine Dioxide (ClO2), which is manufactured on-site and is used as a bleaching agent for pulp, is the only substance regulated by the RMP rule that is present onsite above the EPA threshold quan tity. Process: Chlorine dioxide generation and storage Program Level: 3 Regulated Substance: Chlorine dioxide Process Quantity: 38,305 pounds (total for two tanks) The chlorine dioxide generation and storage system was built in 1989. The bleach plant at the mill operates an R8 reactor to generate chlorine dioxide aqueous solution (ClO2) for the bleaching process. The generated aqueous chlorine dioxide solution is pumped to two large outdoor tanks for storage and process and used at a maximum concentration of 1.2 percent. Each tank has a maximum storage capacity of 183,600 gallons of aqueous solution (19,200 lbs CLO2). The chlorine dioxide system is a Program 3 process for RMP rule compliance purposes. 1.3 Off-site Consequences Analysis IP Moss Point performed an off-site consequence analysis to estimate the potential for an accidental release of a regulated substance to affect the public or environment. The off-site consequence analysis consists of evalu ating both a worst-case release scenario and an alternative release scenario for chlorine dioxide. IP Moss Point does not expect a worst-case release scenario to ever occur. The alternative release scenario was selected for planning purposes to help the mill's emergency response planning committee improve the emergency response plan. An alternative release scenario represents a release that (1) is more creditable than the worse case release scenario and (2) would result in the potential for an off-site consequences if the release occurred. The main objective of performing the off-site consequences analysis is to determine the distance at which certain effects might occur to the public because of an accidental release (called the endpoint). The following effects could occur at the end point distance. At distances less than the endpoint distance, the effects would be greater; at distances greater than the endpoint distance, the effects would be less. When considering the release o f a toxic substance such as chlorine dioxide, most people at the endpoint distance would be able to walk away from the exposure without any long-term health consequences, although some short-term consequences (e.g., strong eye or throat irritation) could occur. The RMP rule requires that IP Moss Point report the worst-case and alternative release scenario information for its only regulated substance, chlorine dioxide. The following information summarizes the off-site consequence analysis performed for IP Moss Point by Hung-Ming (Sue) Sung, Ph.D., P.E., Senior Technical Associate for Trinity Consultants. The dense gas dispersion modeling analysis was completed in January 1999 using the DEGADIS+ software modeling program. 1.3.1 Program 3 Process Toxic Substance; Chlorine Dioxide Worst Case Release Scenario The worst-case release scenario for toxic substances is catastrophic rupture of one of the two chlorine dioxide solution storage tanks (Tank T-9A and Tank T-9B) resulting in t he evaporation and subsequent vapor cloud of the chlorine dioxide liquid solution. Both tanks have an equal capacity of 183,600 gallons and are located side by side within a common dike. The quantity of aqueous chlorine dioxide in process piping is insignificant compared to the tank capacity. Several public and environmental receptors are also located within this endpoint distance from the chlorine dioxide storage tanks (e.g.; schools, residences, hospitals, prisons/correctional facilities, recreational areas, commercial, office, and industrial areas, and officially designated wildlife sanctuaries/refuges). The details of this release scenario have been shared with the Jackson County LEPC. 1.3.2 Program 3 Process Toxic Substance; Chlorine Dioxide Alternative Release Scenario The alternative release scenario for chlorine dioxide is rupture of the chlorine dioxide solution (1.2%) main transfer line from the storage tank outside of the containment area. This scenario assumes that t he solution is released through either the ruptured transfer line or an associated failed gasket for 10 minutes before workers detect the release and isolate the line. The released chlorine dioxide solution forms a pool and the chlorine dioxide evaporates from the pool, forming a vapor cloud. Chlorine dioxide is transferred from the storage tanks via a dedicated 300 gallon transfer pump. Several potential public receptors are also located within this endpoint distance from the chlorine dioxide storage tanks (e.g.; schools and residences). No environmental receptors are within this distance. The details of this release scenario has been shared with the Jackson County LEPC. 1.4 Accidental Release Prevention Program and Chemical-specific Prevention Steps IP Moss Point has implemented a prevention program to help prevent accidental releases of hazardous substances. Beginning in 1992, IP Moss Point formalized this prevention program for Chlorine Dioxide Generation and Storage processes to comply with the 14 elements of the OSHA process safety management (PSM) prevention program. The following sections briefly describe the elements of IP Moss Point's prevention program that addresses the EPA RMP rule prevention program requirements. 1.4.1 Program 3 Prevention Program The IP Moss Point Program 3 prevention program has a strong foundation in the OSHA PSM program established at the mill since 1992. This program has been reviewed and augmented with the aspects required by the RMP rule with emphasis on offsite consequences and consist of the 14 elements of process safety management as required by OSHA 1910.119. 1.4.1.1 Process Safety Information. IP Moss Point maintains a variety of technical documents that are used to help ensure safe operations of the mill's covered processes. These documents address (1) physical properties of the hazardous substances used at IP Moss Point, (2) operating parameters of the equipment, and (3) design basis and configu ration of the equipment. IP Moss Point ensures that this process safety information is available to all affected employees. Material safety data sheets (MSDSs) document the physical properties of hazardous substances handled at IP Moss Point, including regulated substances in covered processes. MSDSs for hazardous substances handled in each process are readily available to the affected employees in order to have a ready reference to this information. In addition, a list of all hazardous material MSDSs are provided to the LEPC and the local fire department for use in helping formulate emergency response plans. These MSDSs are available to the agencies upon request. The engineering design documents include the operating parameters and the design basis and configuration of the equipment in each covered process. 1.4.1.2. Process Hazard Analysis. IP Moss Point performs and periodically revalidates process hazard analyses (PHAs) of the covered processes to help identify process ha zards and generate recommendations that might improve the safe operation of the process. A team composed of personnel with engineering experience, process operating experience (including hourly employees), and a leader with process hazard analyses experience was assembled to analyze the hazards associated with the chlorine dioxide generation and storage process. IP Moss Point primarily uses the hazard and operability (HAZOP) technique, supplemented with checklists, to perform this analysis. The PHA team prepared a written report describing the results of the analysis, including a list of recommendations for management to consider. Responsibility to resolve the recommendations were assigned to unit personnel and where appropriate, changes to enhance the safety of the process were implemented. In December of 1998, IP Moss Point provided training for key personnel in PHA techniques and methodologies, including PHA revalidation process. The chlorine dioxide PHA HAZOP was revalidated in April of 1999. 1.4.1.3. Operating Procedures. IP Moss Point process 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 initial ClO2 procedures were developed by experienced operators and then reviewed by a team consisting of the following members: A) the author, B) an experienced and trained operator to ensure accuracy and validation of procedural tasks, C) a less experienced operator to ensure that the comprehension of the procedure is at a level that all employees required to perform the task can understand, and D) a process safety management facilitor to ensure all the process safety requirements were addressed in the procedure. 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. IP Moss Point personnel 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. The operating procedures are used to help in operating the IP Moss Point processes and as a training guide. The operating procedures are reviewed annually to verify and ensure procedure accuracy. 1.4.1.4. Training IP Moss Point trains workers to safely and effectively perform their assigned tasks. The IP Moss Point 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. Written tests, along with demonstrations and observations, are used to verify that an employee understands the training material before the employee can resume work in the process. The op erators are consulted annually at safety meetings to evaluate the effectiveness and frequency of the training. Recommendations from the operations are reviewed, and changes to the training program are implemented as appropriate. 1.4.1.5 Mechanical Integrity IP Moss Point 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 the IP Moss Point processes. 1.4.1.6. Management of Change The IP Moss Point mill 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 af fect 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 management of change process. 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. 1.4.1.7. Pre-startup Review IP Moss Point 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. 1.4.1.8. Compliance Audits IP Moss Point audits covered processes to be certain that the mill prevention program is effectively addressing the safety issues of the chlorine dioxide process. IP Moss Point personnel, along with International Paper corporate au ditors, both having extensive knowledge in the PSM and RMP rules and process operations, perform a detailed audit of the system at least every three years. The audit teams evaluate whether the prevention program satisfies the requirements of the RMP and PSM rules, and whether the prevention program is sufficient to help ensure safe operation of the process. The results of all audits are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented. 1.4.1.9. Incident Investigation IP Moss Point 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, including all accidents and near misses. An investigation team is assembled, and the investigation is initiated within 48 hours. IP Moss Point trains key employees on accident investi gation techniques and requires at least one trained employee on the investigation team. The results of the investigation are documented, recommendations are resolved and tracked for closure, and appropriate process enhancements are implement. 1.4.1.10. Employee Participation IP Moss Point developed a written employee participation program for covered processes to help ensure that the safety concerns of mill employees are addressed. IP Moss Point encourages active participation of personnel in the prevention program activities of all processes at the mill. Employees are consulted on and informed about all aspects of the RMP rule prevention program, including PHAs, operating procedures, training frequencies, and accident investigations. 1.4.1.11. Hot Work Permit IP Moss Point established a hot work permit program to control spark and/or flame producing activities that could result in fires or explosions at the mill. The hot work permit program involves the entire mill including the covered processes as well. IP Moss Point reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a) and created a Hot Work Permit Form to comply with the requirements. Personnel who are to perform hot work permits are required to fill out the Hot Work Permit Form. The shift supervisor or lead person reviews the completed form before work can begin. Training in the use of the Hot Work Permit Form is included in the mill's annual OSHA block training classes. 1.4.1.12. Contractors IP Moss Point established a program to help ensure that contractor activities in the mill are performed in a safe manner and consistent with the requirements as established by International Paper. The program reviews the safety record of all contractors to help ensure that IP Moss Point hires contractors who can safely perform the desired job tasks. IP Moss Point reviews to the contract supervisor the hazards of the process on which the contractor employees willl work, the m ill safe work practices required to be followed by the contractors, and mill emergency procedures. Contractors are pre-qualified for work at the mill and are required to submit a detailed site specific safety and health plan prior to beginning work activities. IP Moss Point requires that contractors working at the mill be provided a contractor safety orientation before starting work at the site. If the work involves a covered process, specific PSM overview training is required. IP Moss Point periodically reviews contractor's training documents and audits work performances to help ensure that safe practices are followed. 1.4.2 Chemical-specific prevention steps In addition to the required prevention program elements, the IP Moss Point has implemented safety features specific to the hazardous substances used at the mill. The following describe some of these safety features for chlorine dioxide. Chlorine Dioxide is produced at the IP Moss Point 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 (R-8 plant) and piped to an absorber column, where a 1.2% (max.) chlorine dioxide solution is generated. Storing this substance as a solution helps to reduce the consequences of a release. A containment area around the storage tanks helps reduce the consequences of a release. The dike area is piped to the mill's waste water treatment facility and all spills in the diked area would be immediately treated in the waste water system. In addition, chlorine dioxide detection sensors are strategically located in the storage tank and process area to provide an immediate warning in the event of a release. 1.5 Five Year Accident History IP Moss Point mill has completed a five-year accident history and has not experienced any releases that had off site consequences. The mill has experienced two incidents on site that required medical treatment due to minor exposure to chlorine dioxide. In both cases the employees returned back to work immediately following medical treatment. 1.6 Emergency Response Programs IP Moss Point has established a written emergency response program to help respond to accidental releases of hazardous substances. The emergency response plan includes procedures for: - informing the local fire department about accidental releases that could reasonably result in off-site consequences - providing proper first aid and emergency medical treatment to treat accidental employee exposure to hazardous substances at IP Moss Point - 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. IP Moss Point maintains an emergency response team trained in these emergency response procedures. All IP Moss Point personnel are trained in e vacuation procedures. IP Moss Point periodically conducts emergency response drills, including annual evacuation drills with mill employees. The written emergency response plan complies with other federal contingency plan regulations (e.g., the OSHA regulations 29 CFR 1910.38(a), 29 CFR 1910. 120(a)) and has been communicated to local emergency response officials through the local fire department and LEPC. IP Moss Point maintains a regular dialogue with the local fire department and provides appropriate information as well. 1.7 Planned changes to Improve Safety IP Moss Point constantly strives to improve the safety of the processes at the mill through both the incident investigation program and a program soliciting safety suggestions from the workers. The following changes to improve process safety for the chlorine dioxide system have been completed: - Upgraded the chlorine dioxide generator process from R-3 to R-8 process to minimize the formation of byproduct chlorine - Elim inated use of the regulated chemical elemental chlorine in bleaching process with chlorine dioxide - Upgraded the ClO2 atmospheric monitoring system - Implemented a checklist for basic care maintenance and operations - Developed an employee driven safe behavior process to observe and monitor safety activities - Perform OSHA physical compliance audits to identify and correct physical deficiencies - Reduced methanol concentration from 100% to 80% to reduce equipment corrosion - Currently in the process of upgrading the mill's sitewide emergency evacuation alarm system |