Potlatch Corporation, Arkansas Pulp and Paperboard - Executive Summary
Risk Management Plan |
1. Executive Summary
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 Arkansas Pulp and Paperboard Division in McGehee, Arkansas, 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 Cypress Bend 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 Cypress Bend. 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 Cypress Bend Mill.
e risk management program at the Cypress Bend 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 Cypress Bend
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 Cypress Bend 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 Cypress Bend 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.
The safety program at the Cypress Bend 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 Corporatio
n 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 Cypress Bend 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 Cypress Bend Mill.
In the event of an accidental release, the Cypress Bend Mill controls and contains the release in a manner that will be safe for employees and will help prevent injury to the public or the environment. The mill provides response training to its employees and designates an emergency response coordinator to oversee response activities. The Cypress Bend Fire
Department is staffed with 52 employees.
1.2 Facility Information and Regulated Substances
The Arkansas Pulp and Paperboard Division of Potlatch Corporation operates an integrated bleached kraft mill that employs approximately 450 full-time workers. The mill produces approximately 750 tons per day of bleached kraft pulp and operates a coated paperboard machine. Potlatch Corporation handles three regulated substances in sufficient quantities to be covered by the RMP rule, as shown in the following list of RMP-covered processes at the Cypress Bend Mill.
Process Program Level Regulated Substance Process Quantity
Chlorine Dioxide Generation, Storage, and Transfer 3 Chlorine Dioxide 11,100 lbs
Chlorine Pulp Bleaching Unloading and Transfer 3 Chlorine 360,000 lbs
Chlorine Water Treatment 3 Chlorine 56,000 lbs
Storage and Transfer 3 Anhydrous Ammonia 70,000 lbs
1.3 Offsite Consequence Analysis
The Cypress Bend Mill performed an offsite consequence analysis to esti
mate 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. The Cypress Bend Mill does not expect a worst-case release scenario to ever occur. An alternative release scenario represents a release that (1) might occur at a facility similar to the Cypress Bend 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 Cypress Bend Mill. These requirements are:
7 one worst-case and one alternative release scenario for chlorine bleaching,
7 one alternative release scenario for chlorine water treatment,
7 one alternative release scenario for chlorine dioxide, and
7 one alternative release scenario for anhydrous ammonia.
The following information
summarizes the offsite consequence analysis performed by the Cypress Bend Mill.
1.3.1 Chlorine Bleaching 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 9.3 miles. The U. S. Census indicates that 1,000 people live within this distance from the mill. Several public receptors are located within this distance (e.g. Bunge Corporation Grain Terminal, Arkansas City Schools, Delta Schools, the Desha County Courthouse, the Mississippi River, and McCallie Public Access on the Mississippi). One environmental receptor, the Rohwer Relocation Camp Memorial, is also located within this distance.
The alternative release scenario for chlorine is the rupture of a 2" chlorine transfer line from the chlorine vaporizers to the bleach plant mixers. This scenario assumes that the release occurs outside a building and that workers require 20 minutes to detect an
d stop the leak. The maximum distance to the toxic endpoint is 3.2 miles. The U. S. Census indicates that 70 people live within this distance from the mill. Public receptors within this distance include Bunge Corporation Grain Terminal, the Mississippi River and McCallie Public Access on the Mississippi River.
1.3.2 Water Treatment Chlorine Storage and Transfer (1 ton cylinders)
No worst-case scenario is reported for one (1) ton chlorine cylinders because the effects of the chlorine located in the pulp mill for bleaching operations exceeds those of the worst-case scenario for an accidental release from a one (1) ton cylinder. The alternative release scenario for chlorine one ton cylinder is the rupture of 1 inch supply tubing on a one ton cylinder located at the river influent treatment station. This scenario assumes the cylinder is full (2000 pounds) and operators require 90 minutes to detect and stop the leak. The maximum distance to toxic endpoint is 0.5 miles. The U. S.
Census indicates that 10 persons live within this distance from the mill. The Bunge Corporation Grain Terminal and the Mississippi River are public receptors within this distance.
1.3.3 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 4" 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 180 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 1.1 miles. The U. S. Cen
sus indicates that 10 people live within this distance from the mill. The Bunge Corporation Grain Terminal and the Mississippi River are public receptors within this distance.
1.3.4 Anhydrous Ammonia Storage and Transfer
No worst-case scenario is reported for anhydrous ammonia because the effects of the chlorine worst-case scenario exceed those of the worst-case scenario for an accidental release of anhydrous ammonia. The alternative release scenario for anhydrous ammonia is the rupture of a 2" anhydrous ammonia transfer line from the storage tank to the wastewater clarifier outfall. This scenario assumes that the gas leaks from the ruptured line from the tank pressured at 150 psi, and workers require 30 minutes to detect the release and valve out the transfer line. The maximum distance to the toxic endpoint is 0.6 miles. The U. S. Census indicates that 10 people live within this distance from the mill. The Bunge Corporation Grain Terminal and the Mississippi River are publ
ic receptors within this distance.
1.4 Accidental Release Prevention Program and the Chemical-specific Prevention Steps
Since its inception in 1977, the Cypress Bend Mill has used a prevention program to help prevent accidental releases of hazardous substances. Beginning in 1992, the mill formalized this prevention program for the Chlorine Unloading and Transfer, the Chlorine Dioxide Generation, Storage, and Transfer, and the Anhydrous Ammonia 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 Cypress Bend 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 safe operation of the mill
processes. These documents address (1) physical properties of hazardous substances handled at the Cypress Bend Mill, (2) operating parameters of the equipment, and (3) design basis and configuration of the equipment in the mill. The Cypress Bend Mill ensures that this process safety information is available to all Potlatch employees and local fire and emergency response personnel.
Material safety data sheets (MSDSs) document the physical properties of hazardous substances handled at the Cypress Bend Mill, including regulated substances in RMP-covered processes. MSDSs for hazardous substances handled in each process are available to mill operators for ready reference.
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:
7 operating parameters
7 block flow or simplified process flow diagrams
7 process chemistry
7 maximum intended inventories
e upper and lower limits for parameters such as temperature, pressure or flow
7 consequences of deviation from established operating limits
7 design basis and configuration of equipment
7 piping and instrument diagrams, including materials of construction
7 electrical classification
7 safety systems
7 applicable design codes and standards
7 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 Cypress Bend Mill performs and periodically updates process hazard analyses (PHAs) of the covered processes to help identify process hazards and generate recommendations that might improve the safe operati
on 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 Cypress Bend 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. Cypress
Bend 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 Cypress Bend 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 that work closely with hazardous chemicals receive specialized training for operation and maintenance of process equipment. Demonstrations and employee observations are used to verify that an employee understands the training material before the employee can resume work in the process.
5. Mechanical Integrity. The Cypress Bend Mi
ll 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:
7 specifications for inspection and testing of process equipment
7 specifications for replacement parts and equipment
7 procedures for inspecting, testing, and maintaining process equipment
7 procedures for safe work practices such as lockout/tagout, hot work, confined space entry, and line or equipment opening
7 training of maintenance personnel
7 documentation of maintenance activities
6. Management of Change. The Potlatch management of change program evaluates and approves all p
roposed 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 Cypress Bend 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:
7 construction and equipment are in accordance with design specifications
7 adequate safety, operati
ng, maintenance, and emergency procedures are in place
7 employee training has been completed
7 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 Cypress Bend 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 ensure safe operation of the process. The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program a
9. Incident Investigation. The Cypress Bend 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 Cypress Bend Mill employees are addressed. The Cypress Bend Mill 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 preventio
n program, including PHAs, employee training, and operating procedures.
11. Hot Work Permits. The Cypress Bend 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.
12. Contractors. The Cypress Bend Mill established a program to help ensure that contractor activities at the mill are performed 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 Cypress Bend Mill trains the contract supervisors in the hazards of the pro
cess on which they and their employees will work, Cypress Bend 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 site. The Cypress Bend 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 Cypress Bend Mill.
Chlorine. Chlorine is supplied in Department of Transportation (DOT) approved 90-ton rail cars. Chlorine detectors and alarms are provided in areas containing chlorine.
Chlorine is also supplied in one ton cylinders for use in water treatment in various areas of the mill.
Chlorine Dioxide. Chlorine dioxide is produced at the Cypress Bend
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.
Anhydrous Ammonia. Anhydrous ammonia is purchased and stored on site in the wastewater treatment area of the mill. Utilities department operators make routine visual inspections of the wastewater treatment area, noting anhydrous ammonia tank levels and transfer equipment conditions.
1.6 Five-Year Accident History
The Cypress Bend Mill has had no releases during the last five years while handling either chlorine, chlorine dioxide, or anhydrous ammonia that have resulted in any offsite public or environmental effects. There have been s
ix releases that have resulted in employee or contractor first aid treatment. Four of the six incidents involved chlorine; the remaining two involved chlorine dioxide exposure. The incidents are listed below.
Incident Date Chemical Person Exposure
1/19/96 chlorine dioxide Potlatch employee inhalation
3/14/96 chlorine contractor inhalation
9/11/96 chlorine Potlatch employee inhalation
3/12/98 chlorine Potlatch employee inhalation
5/20/98 chlorine dioxide contractor inhalation
2/23/99 chlorine contractor inhalation
1.7 Emergency Response Program
The Cypress Bend 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:
7 Informing the McGehee Fire Department and the public about accidental releases that could reasonably result in offsite consequences
7 Providing proper first aid and emergency medical treatment to treat accidental human exposure to hazardous
substances at Potlatch
7 Controlling and containing accidental releases of hazardous substances, including the use of emergency response equipment
7 Inspecting and maintaining emergency response equipment
7 Reviewing and updating the emergency response plan
Potlatch Corporation operates a trained and well-equipped fire department to respond to emergencies within the Cypress Bend Mill. All mill employees are trained in evacuation procedures and the Potlatch Fire Department periodically conducts emergency response drills.
The written emergency response plan complies with other federal contingency plan regulations (e.g., 29 CFR 1910.38(a), 29 CFR 1910.120(a)) and has been communicated to the local authorities.