Weyerhaeuser Company - Longview Mill - Executive Summary
RISK MANAGEMENT PLAN |
1. EXECUTIVE SUMMARY
The Weyerhaeuser Company in Longview, Washington (Weyerhaeuser) is committed to operating in a manner that is safe for Weyerhaeuser workers, the public, and the environment. As part of this commitment, Weyerhaeuser has established a system to help ensure safe operation of the processes at this facility. One component of this system is a risk management program (RMP) that helps manage the risks at Weyerhaeuser 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 Weyerhaeuser. 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 We
The risk management program at Weyerhaeuser consists of three elements:
* 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 1.5.
* 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.
* An emergency response program to help respond to accidental releases of regulated substances from covered processes - see topic 1.6.
Information further describing these elements is provided in this RMPlan.
The risk management program at Weyerhaeuser is only one component of the safety program at Weyerhaeuser. Weyerhaeuser 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 hazardous substance.
Weyerhaeuser limits the use of hazardous substances. Before using a hazardous substance at Weyerhaeuser, less hazardous alternatives are considered. When a hazardous substance is used at Weyerhaeuser, Weyerhaeuser considers the potential for this substance to adversely affect Weyerhaeuser workers, the public, and the environment and takes steps to prevent any such effects.
Weyerhaeuser reduces the inventory of hazardous substances. When a hazardous substance is used at Weyerhaeuser, Weyerhaeuser limits the inventory of this substance to the lowest practical level whenever possible. Weyerhaeuser has a formal Chemical Management program in place to support the limitation and reduction of hazardous substance inventories. This program is designed to promote safe handling, storage, and use of chemicals as well as to limit the number and amount of chemicals stored on-site.
Weyerhaeuser prevents releases of the h
azardous substances used at the facility. When a hazardous substance is used at Weyerhaeuser, 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.
Weyerhaeuser limits damage from a release, if such a release occurs. Weyerhaeuser trains workers to respond to an accidental release, reducing the consequences of a release if it occurs. We have a fully staffed on-site Fire Department as well as hazardous materials technicians in the operating units. In addition, Weyerhaeuser works with the local emergency response agencies and with the local emergency planning committee (LEPC) to help minimize the potential for injuries and/or environmental damage if a release does occur.
The safety program at Weyerhaeuser consists of a number of elements, only some of which are required by the RMP rule. This RMPlan is primarily i
ntended to describe those parts of the safety program at Weyerhaeuser that are required by the RMP rule.
1.1 Accidental Release Prevention and Emergency Response Policies
Weyerhaeuser is committed to the safety of workers and the public, and the preservation of the environment, through the prevention of accidental releases of hazardous substances. We have implemented 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; and programs to evaluate hazards.
In the event of an accidental release, we work to control and contain the release in a manner that provides for the safety of workers and will help prevent injury to the public or the environment. We provide response training to Weyerhaeuser personnel, designate an emergency response coordinator to oversee response activities, and coordinate response eff
orts with the local emergency response agencies. Response activities have also been discussed with the LEPC.
In order to effectively implement these policies, Weyerhaeuser established a management system headed by the Safety Manager to oversee safety and the Risk Manager to oversee emergency response-related activities.
1.2 The Weyerhaeuser Company and Regulated Substances
Weyerhaeuser is an integrated pulp and paper mill primarily involved in the manufacture of bleached pulp and related finished paper products. As part of these manufacturing processes, Weyerhaeuser handles three regulated substances in sufficient quantities to be covered by the RMP rule. They are as follws:
* The Chemical Supply area has Chlorine, a toxic gas liquefied by pressure, with a process inventory of up to 180 tons. It is a Level 3 RMProgram.
* The Effluent Treatment area has Anhydrous Ammonia, a toxic gas liquefied by pressure, with a process inventory of up to 27 tons. It is a Level 3 RMProgram.
The Chjemical Supply area also has Anhydrous Sulfur Dioxide, a toxic gas liquefied by pressure, with a process inventory of up to 6 tons. It is a Level 3 RMProgram.
1.3 Offsite Consequence Analysis
Weyerhaeuser performed an offsite consequence analysis to estimate 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 alternative release scenarios were selected to help the local emergency planning committee improve the community emergency response plan.
The main objective of performing the offsite consequence analysis is to determine the distance at which certain effects might occur to the public because of an accidental release (called the endpoint distance). The following effects could occur at the endpoint distance. At distances less than the endpoint distance, the effects would be greater; at di
stances greater than the endpoint distance, the effects would be less.
When considering the release of a toxic substance, 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) are likely. Some people who are particularly susceptible to the substance released could be incapacitated.
The RMP rule includes specific requirements for the worst-case and alternative release scenarios that must be reported by Weyerhaeuser. These requirements are:
* One worst-case release scenario for the class of toxic substances in Program 3 processes (i.e., one scenario representing chlorine, anhydrous ammonia, or sulfur dioxide, whichever has the greatest potential impact).
* One alternative release scenario for each of the toxic substances in a Program 3 process (i.e., chlorine, anhydrous ammonia, and sulfur dioxide).
The following information summarize
s the offsite consequence analysis performed by Weyerhaeuser. Detailed information is included in Sections 2 and 3 of the RMPlan.
The worst-case release scenario for toxic substances is for chlorine. It is the failure of a 90-ton chlorine rail car in the Chemical Supply/chlorine process. Several public receptors may be affected under this scenario (e.g. schools, residences, hospital, prison/correctional facilities, public recreational areas, and major commercial, office or industrial area). There are also environmental receptors within this distance (e.g. national and state forests).
The alternative release scenario for chlorine is a leak from a chlorine loading hose. This scenario assumes that workers require 30 minutes to detect and stop the leak. Several public receptors may be affected under this scenario (e.g. schools, residences, hospital, public recreational areas, and major commercial, office or industrial areas). No environmental receptors are within this distance.
alternative release scenario for anhydrous ammonia is a leak from a ruptured anhydrous ammonia gas line. This scenario assumes that workers cannot stop the leak before the contents of the tank are released. Several public receptors may be affected under this scenario (e.g. schools, residences, public recreational areas and major commercial, office or industrial areas). No environmental receptors are within this distance.
The alternative release scenario for sulfur dioxide is a leak from a ruptured sulfur dioxide gas line. This scenario assumes that workers require 10 minutes to detect and stop the leak. Several public receptors may be affected under this scenario (e.g. schools, residences, public recreational areas, and major commercial, office or industrial areas). No environmental receptors are within this distance.
1.4 Accidental Release Prevention Program and Chemical-specific Prevention Steps
Beginning in 1992 Weyerhaeuser formalized its prevention program for the Chemi
cal Supply/Chlorine, Effluent Treatment/ Anhydrous Ammonia, and Chemical Supply/Sulfur Dioxide processes to comply with the 14 elements of the OSHA process safety management (PSM) prevention program. In 1996, the EPA RMP rule established prevention program requirements. Weyerhaeuser falls under Program 3 which has essentially the same requirements as OSHA PSM, except that the program also focuses on protection of the public and the environment.
The following sections briefly describe the elements of Weyerhaeuser's prevention program that address the EPA RMP rule prevention program requirements.
The Weyerhaeuser Program 3 prevention program consists of the following 12 elements:
1. Process Safety Information, Weyerhaeuser maintains a variety of technical documents that are used to help ensure safe operation of the Weyerhaeuser processes. These documents address (1) physical properties of hazardous substances handled at Weyerhaeuser, (2) operating parameters of the equipment at Wey
erhaeuser, and (3) design basis and configuration of the equipment at Weyerhaeuser. Weyerhaeuser ensures that this process safety information is available to all Weyerhaeuser employees, the local emergency planning committee (LEPC), and the local emergency response agencies.
Material safety data sheets (MSDS's) document the physical properties of hazardous substances handled at Weyerhaeuser, including regulated substances in covered processes. The information available for each hazardous substance typically includes:
* Toxicity information and permissible exposure limits
* Physical data (e.g., boiling point, melting point, flash point)
* Reactivity and corrosivity data
* Thermal and chemical stability data
* Hazards of mixing substances in the process
MSDS's for hazardous substances handled in each process are available on the site computer network so that the operators have ready reference to this information. In addition, MSDS's are provided to the LEPC and the local emerge
ncy response agencies for use in helping formulate emergency response plans.
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:
* Operating parameters
* Block flow or simplified process flow diagrams
* Process chemistry
* Maximum intended inventories
* Safe upper and lower limits for parameters such as temperature, pressure, or flow
* Consequences of deviations from established operating limits
* Design basis and configuration of equipment
* Piping and instrument diagrams, including materials of construction
* Electrical classification
* Safety systems
* Applicable design codes and standards
* Design basis for relief and ventilation systems
When important information was not available from the design documents, it was developed through special projects or, in the case of operating parameters, during process hazard analyses of the process. M
any 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. Weyerhaeuser performs and periodically updates process hazard analyses (PHA's) of the covered processes to help identify process hazards and generate recommendations that might improve the safe operation 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. Weyerhaeuser primarily uses the hazard and operability (HAZOP) technique, supplemented with checklists, 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 uni
3. Operating Procedures. Weyerhaeuser 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 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. Operating procedures include:
* Steps for safely conducting activities.
* Applicable process safety information, such as safe operating limits and consequences of process deviations.
* Safety and health considerations, such as chemical hazards, personal protective equipment requirements, and actions to take if exposure to a hazardous substance occurs.
Weyerhaeuser 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 sh
utdown, and temporary operations. The operating procedures are used both to help in operating the Weyerhaeuser processes and as a training guide.
4. Training. Weyerhaeuser trains workers to safely and effectively perform their assigned tasks. The Weyerhaeuser 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. Oral reviews and written tests are used to verify that an employee understands the training material before the employee can resume work in the process.
The operators are consulted to evaluate the effectiveness and frequency of the training. Recommendations from the operators are reviewed, and changes to the training program are implemented as appropriate.
5. Mechanical Integrity. Weyerhaeuser maintains the mechanical integrity of process equipment to help preve
nt equipment failures that could endanger workers, the public, or the environment. The Weyerhaeuser 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 Weyerhaeuser processes. The Weyerhaeuser mechanical integrity program includes:
* Specifications for inspection and testing of process equipment.
* Specifications for replacement parts and equipment.
* Procedures for inspecting, testing, and maintaining process equipment.
* Procedures for safe work practices such as lockout/tagout, hot work, confined space entry, and line or equipment opening.
* Training of maintenance personnel.
* Documentation of maintenance activities.
6. Management of Change. The Weyerhaeuser management of change program evaluates and approves all proposed changes to chem
icals, 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. Weyerhaeuser performs a safety review of a new or modified process before the process is placed into service to help ensure that the process has been prepared to operate safely. This review confirms that:
* Construction and equipment are in accordance with design specifications.
* Adequate safety, operating, maintenance, and emergenc
y procedures are in place.
* Employee training has been completed.
For a covered process, a PHA is performed if the process is new or management of change requirements are completed if an existing process is modified.
A pre-startup review checklist is completed to document the review and to ensure that appropriate issues have been addressed.
8. Compliance Audit. Weyerhaeuser audits covered processes to be certain that the Weyerhaeuser prevention program is effectively addressing the safety issues of Weyerhaeuser operations. Weyerhaeuser 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 are implemented.
9. Incident Inv
estigation. Weyerhaeuser investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment so that similar incidents can be prevented. Weyerhaeuser 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. Weyerhaeuser developed a written employee participation program for covered processes to help ensure that the safety concerns of Weyerhaeuser workers are addressed. Weyerhaeuser encourages active participation of personnel in the prevention program activities of all processes at the facility. Employees are consulted on and informed about all aspects of the RMP rule prevention program, including PHA's and operating procedures.
Work Permits. Weyerhaeuser 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 Weyerhaeuser facility. Weyerhaeuser 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 or designee reviews the completed form before work can begin. Training in the use of the Hot Work Permit Form is included in the Weyerhaeuser safe work practices orientation.
12. Contractors. Weyerhaeuser established a program to help ensure that contractor activities at the Weyerhaeuser facility are performed in a safe manner. The program reviews the safety record of all contractors to help ensure that Weyerhaeuser only hires contractors who can safely perform the desired job tasks. Weyerhaeuser explains
to the contractor supervisors the hazards of the process on which they and their employees will work, Weyerhaeuser safe work practices, and Weyerhaeuser emergency response procedures. Weyerhaeuser requires that the contractor supervisors train each of their employees who will work at Weyerhaeuser before that worker begins work at the Weyerhaeuser site. Weyerhaeuser periodically reviews contractors' training documents and work performance to help ensure that safe practices are followed.
In addition to the required prevention program elements, Weyerhaeuser has implemented safety features specific to the hazardous substances used at Weyerhaeuser. The following paragraphs describe some of these safety features.
Anhydrous ammonia. Industry standards are followed at Weyerhaeuser to help ensure safe handling of anhydrous ammonia. The ammonia vendor supplies anhydrous ammonia via a Department of Transportation (DOT)-approved tank truck and follows DOT standards when loading the anhydrou
s ammonia storage tank. The storage tank design and construction are consistent with American National Standards Institute (ANSI) standards. Workers who perform operations involving ammonia receive training emphasizing safe handling procedures for ammonia developed by Weyerhaeuser.
Chlorine. Chlorine is used following standard industry equipment and procedures. The chlorine vendor supplies chlorine via a Department of Transportation (DOT)-approved rail car. Weyerhaeuser employees follow DOT standards when transferring to the chlorine storage tanks. There are control system interlocks which isolate the storage tanks from the unloading process in the case sensors detect chlorine in the unloading area. In addition, chlorine detectors and alarms are located in the process areas and around the perimeter of the manufacturing area to warn of leaks. Workers who perform operations involving chlorine receive training emphasizing safe handling procedures for chlorine developed by Weyerhaeu
Sulfur Dioxide. Industry standards are followed at Weyerhaeuser to help ensure safe handling of sulfur dioxide. The sulfur dioxide vendor supplies sulfur dioxide via a Department of Transportation (DOT)-approved tank truck and follows DOT standards when loading the sulfur dioxide storage tank. The storage tank design and construction are consistent with American National Standards Institute (ANSI) standards. Workers who perform operations involving sulfur dioxide receive training emphasizing safe handling procedures for sulfur dioxide developed by Weyerhaeuser.
1.5 Five-Year Accident History
Weyerhaeuser has completed a five-year accident history that indicates safe on-going operations at Weyerhaeuser. There have not been any releases at the facility that resulted in injury or property damage, as described in the RMP regulation.
1.6 Emergency Response Programs
Weyerhaeuser has established a written emergency response program to help safely respond to accidental releases
of hazardous substances. The emergency response plan includes procedures for:
* Informing the local emergency response agencies and the public about accidental releases that could reasonably result in offsite consequences.
* Providing proper first aid and emergency medical treatment to treat accidental human exposure to hazardous substances at Weyerhaeuser.
* 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.
Weyerhaeuser trains some employees to the Hazardous Technician level to use these emergency response procedures for on-site response. All Weyerhaeuser personnel are trained in evacuation procedures. Weyerhaeuser periodically conducts emergency response drills, including annual drills coordinated with the local emergency response agencies.
The written emergency response plan complies with o
ther 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 emergency response agencies. Weyerhaeuser maintains a regular dialogue with the local emergency response agencies, and Weyerhaeuser provides appropriate information to these agencies.
1.7 Planned Changes to Improve Safety
Weyerhaeuser constantly strives to improve the safety to the processes at Weyerhaeuser through both the incident investigation program and by soliciting safety suggestions from the workers. The following changes to improve process safety are planned or have recently been completed.
* Weyerhaeuser replaced two chlorine vaporizers with one smaller unit designed to Chlorine Institute standards and routed the safety valve on the new unit to a scrubbing system - these changes reduce the likelihood of a chlorine release caused by degraded equipment or process upsets
is planning to minimize chlorine inventory. The three 60 ton tanks will be filled from 90-ton rail cars supplied by an external vendor as required.
* Weyerhaeuser is planning on routing the output from the perimeter chlorine sensors in the Chemical Supply process to the Communication Center so they can be monitored 24 hours a day independent of the operations. Additionally, the internal area chlorine sensors are routed to the department control room. These sensors provide early detection of chlorine releases, thus minimizing potential consequences.
* Weyerhaeuser worked with the sulfur dioxide vendor to replace the sulfur dioxide storage tank - replacing the old tank will reduce the likelihood of a sulfur dioxide release caused by degraded equipment