Rayonier Specialty Pulp Products, Jesup Mill - Executive Summary |
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Risk Management Program Rayonier, Specialty Pulp Products, Jesup Mill June 17,1999 1.0 EXECUTIVE SUMMARY The Rayonier Jesup Pulp Mill is committed to promoting and protecting the health and safety of their employees, the environment, and the community in which they operate. As part of this commitment, the Jesup mill has established and maintained health, environmental protection, and safety systems to help ensure safe operation of their processes. One component of these systems is a Risk Management Program (RMP). This RMP 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). The RMP rule requires regulated facilities to submit a risk management plan describing their risk management program. This document provides a brief overview of the comprehensive risk management activities that the Jesup pulp mill has developed and implemented, including: 7 2.0 - A description of our facility and use of substances regulated by EPA's RMP regulation 7 3.0 - A summary of results from our assessment of the potential off-site consequences from accidental chemical releases 7 4.0 - An overview of our accidental release prevention programs 7 5.0 - A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule 7 6.0 - An overview of our emergency response program 7 7.0 - An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment 7 8.0 - The certifications that EPA's RMP rule requires us to provide 7 9.0 - The detailed registration information (called data elements) covering our risk management program 2.0 STATIONARY SOURCE AND REGULATED SUBSTANCES The Rayonier Jesup Pulp Mill is a three-mill, Kraft pulping complex involved in the manufacture of bleached dissolving, paper and fluff pulps . As part of this manufacturing process, we handle several regulated substances in sufficient quantities to be covered by the RMP rule. The RMP-covered processes at our facility are all Program Level 3 processes and are listed below: 1) Chlorine Process - Regulated substance Chlorine, 2,520,000 lb. Maximum process quantity (including rail car inventory). 2) Chlorine Dioxide Process - Regulated substance Chlorine Dioxide, 28,000 lb. Maximum process quantity. 3) Sulfur Dioxide Process - Regulated substance Sulfur Dioxide. 91,000 lb. Maximum process quantity. Chlorine and Chlorine Dioxide are used as pulp bleaching chemicals in our process. They are added directly to the pulp as dilute water solutions in carefully controlled bleach stages. Chlorine is used in two of our three mills while Chlorine Dioxide is used in all three mills. Sulfur Dioxide is added directly to the pulp as a dilute water solution and is used to control or stop chlorine reactions in pulp. It is used in all three m ills. 3.0 OFF-SITE CONSEQUENCE ANALYSIS The Rayonier Jesup Pulp Mill performed off-site consequence analyses to estimate the potential for an accidental release of a regulated substance to affect the public or the environment. These analyses consisted of evaluating both worst-case and alternative release scenarios. It is not expected that a worst-case scenario could ever occur. The alternative release scenarios represent releases that could conceivably occur and are based on process evaluation and industry experience. The main objective in performing off-site consequence analyses for accidental releases is to ensure that our mill emergency response plan and community emergency planning efforts address all reasonable accidental release contingencies. For each accidental release considered, these analyses determine the distance at which an endpoint concentration of a toxic material is reached and predict how many people would be affected within this distance. For toxic substances, this endpoint concentration (as established by the EPA) represents the concentration level of a toxic substance in air that a person can be exposed to for one hour without impairing their ability to take protective action. The RMP Rule includes specific requirements for the worst case and alternative release scenario reporting. For the Rayonier Jesup Pulp Mill, we must report one worst-case scenario covering all of our Program 3 covered processes and one alternative release scenario for each of our Program 3 covered processes. The following information summarizes the off-site consequence analyses performed by the Rayonier Jesup Pulp Mill. 3.1 Program 3 Processes - Toxic Substances Worst-Case Scenario - Chlorine Process The worst-case accidental release for toxic substances is the failure of a 90-ton (180,000 lb.) Chlorine rail car in the pulp mill Chlorine Process. No administrative, passive or active mitigation controls are considered for this release. By EPA definition for a worst-case scenario, the entire contents of the rail car would be released to the environment within 10 minutes, even though this is physically inconceivable. Under worst-case meteorological conditions, EPA look-up tables predict that the Chlorine gas from such a release would travel 14 miles before its concentration in air would reach 0.087 mg/L, the toxic endpoint concentration. 16,700 people could be impacted by this release based on this endpoint distance and US Census data. Public receptors impacted include schools, correction facilities, residences, hospitals, recreation areas and Industrial areas. No environmental receptors are within this distance. Alternative Release Scenario - Chlorine Process The Alternative release scenario for the Chlorine Process is a hose rupture during the unloading of a Chlorine rail car. The release is mitigated by the rail car excess flow valve, which limits liquefied/pressurized Chlorine flow to 250 lb./min. No passive mitigation controls were con sidered for this release. This scenario assumes that workers require 30 minutes to detect and stop the release. A total of 7500 lb. of Chlorine is released. EPA look-up tables predict that the Chlorine gas from such a release would travel 0.3 miles before its concentration in air would reach 0.087 mg/L, the toxic endpoint concentration. Public receptors are limited to residences and industrial areas. 11 people could be impacted by this release based on this endpoint distance and US Census data. No environmental receptors are within this distance. Alternative Release Scenario - Chlorine Dioxide Process The Alternative release scenario for the Chlorine Dioxide Process is a flange gasket failure in one of the lines entering or leaving the Chlorine Dioxide storage tanks. A dike area contains the released Chlorine Dioxide solution, which evaporates and forms a vapor cloud. This scenario assumes that workers require 180 minutes to detect and stop the leak. A total of 3570 lb. of Chlorine Dioxide is released. EPA look-up tables predict that the Chlorine Dioxide gas from such a release would travel 0.5 miles before its concentration in air would reach 0.028 mg/L, the toxic endpoint concentration. Public receptors are limited to residences and industrial areas. 25 people could be impacted by this release based on this endpoint distance and US Census data. No environmental receptors are within this distance. Alternative Release Scenario - Sulfur Dioxide Process The Alternative release scenario for the Sulfur Dioxide Process is a hose rupture during the unloading of a Sulfur Dioxide tank truck. The tank truck excess flow valve and a back flow regulator valve in the feed lines to the concentrated Sulfur Dioxide storage tank mitigate the release. These safety systems limit liquefied/pressurized Sulfur Dioxide flow to 250 lb./min. No passive mitigation controls were considered for this release. This scenario assumes that workers require 30 minutes to detect and valve off th e leak. . A total of 7500 lb. of Sulfur Dioxide is released. EPA look-up tables predict that the Sulfur Dioxide gas from such a release would travel 0.3 miles before its concentration in air would reach 0.0878 mg/L, the toxic endpoint concentration. Public receptors are limited to residences and industrial areas. 11 people could be impacted by this release based on this endpoint distance and US Census data. No environmental receptors are within this distance. 4.0 ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS In 1994, the Rayonier Jesup Pulp Mill formalized their accidental release prevention program for eight chemical systems or processes. This program complied with the 14 elements of the OSHA Process Safety Management (PSM) prevention program. In 1996, the EPA RMP rule established that for Program Level 3 processes, OSHA's PSM prevention program could be used to satisfy RMP prevention requirements provided that it was updated to reflect accidental rele ases with potential off-site impact. This update was accomplished for our three RMP covered processes during recent Process Hazard Analysis revalidations. The following is a brief description of the key elements of our OSHA PSM prevention program. PROCESS SAFETY INFORMATION. A variety of technical documents are maintained and used to help ensure safe operation of the Jesup mill processes. Material safety data sheets (MSDS) document the physical properties of hazardous substances handled at the Jesup mill. Engineering design documents include the operating parameters and the design basis and configuration for the equipment in each covered process. The Jesup mill ensures that this process safety information is available to all mill employees. PROCESS HAZARD ANALYSIS. The Jesup mill performs and periodically updates process hazard analyses (PHA's) for each covered process. A team composed of personnel with engineering and process operating experience and a leader with process hazard an alyses experience is assembled to perform these PHA's. PHA teams at the Jesup mill use the hazard and operability (HAZOP) technique, supplemented by checklists, to perform the hazard analyses. A written summary report that contains recommendations for mill management review is prepared by the team. Mill management assigns responsibility for resolution of each recommendation. Where appropriate, changes to improve the safety of the process are implemented. PHA's are performed on each covered process at least once every five years. OPERATING PROCEDURES. Jesup mill process engineers, project engineers, operators and supervisors work together to develop and maintain operating procedures for all covered processes. These procedures describe how operations should be safely performed under conditions of process start-up, normal operations, normal shutdown and emergency shutdown. Operating procedures are used both as operating guidelines and training tools. They are reviewed by Jesup mill man agement on an annual basis. TRAINING. Jesup mill training focuses on general process descriptions, a reviews of the properties and hazards of the process chemicals and detailed process operating procedures and safe work practices. This is accomplished using computer based training (CBT) for all covered processes. CBT modules have been developed for each covered process and include skills testing and testing record keeping. CBT is augmented with classroom and on-the--job training. Refresher training is conducted at least once every three years. MECHANICAL INTEGRITY. The Jesup mill employs a mechanical integrity program to help prevent equipment failures that could endanger workers, the public or the environment. The program applies to all covered processes and includes equipment inspection and testing specifications, replacement parts and equipment specifications, procedures for inspection, testing and maintaining equipment, training of maintenance personnel, and documentation o f maintenance activities. MANZGEMENT OF CHANGE. The Jesup mill management of change procedure requires evaluation and approval of all changes to chemicals, equipment, and procedures for covered processes. These procedures help ensure that the change does not impact the safe operation of the process. Central to this process is the updating of process information relating to the change and communication of the change to employees involved in the covered process. PRE-STARTUP REVIEW. The Jesup mill performs a pre-startup safety review on new covered processes and covered processes undergoing significant modification. A pre-startup review team completes a checklist to document the review and to ensure that identified safety issues have been addressed. COMPLIANCE AUDITS. Process safety compliance audits are an integral part of the Jesup mill prevention program. Audits are performed by an audit team knowledgeable in the process and process safety management. The audit team evaluates wheth er the prevention program satisfies the requirements of the RMP rule and is sufficient to help ensure the safe operation of the process. Audit results are documented, recommendations resolved and appropriate improvements to the prevention program are implemented. The Jesup mill audits the prevention program using both internal and external audits at least once every three years. INCIDENT INVESTIGATION. The Jesup mill investigates all incidents that result in or could potentially result in injury to mill personnel or the public or could harm the environment. A mill team performs this investigation and documents recommendations aimed at preventing similar incidents from occurring in the future. All recommendations are resolved and appropriate corrective actions are implemented. EMPLOYEE PARTICIPATION. Employee participation is a key element of the Jesup mill prevention program. This participation ensures that employee concerns relative to the safety of the covered processes are full y addressed. Employees participate in PHA's, incident investigations, procedures development and compliance audits HOT WORK PERMIT. The Jesup mill has developed hot work procedures to control spark or flame-producing activities that could result in fires or explosions in the mill covered processes. These procedures and the development of a hot work permit system comply with OSHA's 29 CFR 1910.252(a). Training on hot work permitting is conducted annually. CONTRACTORS. Contractor safety is included in the Jesup mill prevention program. The Jesup mill reviews the safety records of all contractors to help ensure that they can safely perform the desired job tasks. As with mill employees, contractors are informed of the hazards of the processes they will work on, the Jesup mill emergency response procedures and the mill safe work practices. Contractors are required to provide the Jesup mill with training records and work performance is periodically reviewed to ensure that safe work p ractices are being followed. These prevention program elements work together to prevent accidental chemical releases. Our company and our employees are committed to the high standard that these management systems set for the way we do business. As part of our ongoing prevention efforts, we have implemented several chemical-specific safety improvements. In the Sulfur Dioxide and Chlorine systems, air padding was replaced by Nitrogen padding in our chemical feed systems. This prevented process equipment corrosion arising from moisture entrainment in the air system. Part of the Chlorine system that services one of our three pulp mills has recently been decommissioned. This reduces our exposure to accidental releases of Chlorine. 5.0 FIVE-YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occur at our facility. Under the RMP rule, significant releases include those that have occurred over the last five years and resulted in deaths, injuries, o r significant property damage on-site or deaths, injuries, evacuations, sheltering-in-place, property damage or environmental damage off-site. We have had two significant releases of Chlorine and one release of Chlorine Dioxide in the past five years; the largest was 492 pounds of Chlorine released over a thirty-minute period. There were no off site impacts from these releases but injuries to mill employees did occur. For each of these accidental releases, formal incident investigations were conducted. Root causes were identified and corrective actions taken to prevent similar releases from occurring in the future. The Chlorine Dioxide release was relatively small and occurred at the time of our RMP filing. Corrective actions for this incident were identified and are currently being implemented. No significant releases occurred over the last five years in our Sulfur Dioxide Process. 6.0 EMERGENCY RESPONSE PROGRAM The Jesup mill has a written emergency response plan for the facility to aid in safely responding to accidental releases of hazardous chemicals. This emergency response plan includes: 7 Procedures for how employees will respond to emergency situations. 7 Procedures for specific departmental emergency and evacuation plans 7 Procedures covering evacuation routes and safe places of refuge. 7 A description and explanation of the emergency alarm system. 7 Procedures for activation of the emergency response team. 7 A description of the incident command system. 7 Training of employees in their responsibilities during an emergency. 7 Procedures for providing proper first aid and emergency medical treatment to treat accidental human exposure to hazardous substances. 7 Procedures for controlling and containing accidental releases of hazardous substances, including the use of emergency response equipment. 7 Procedures for informing County emergency response officials of releases which could reasonably result in off-site consequences. 7 Procedures for informing the public when necessary. 7 Procedures for inspecting and maintaining emergency response equipment. 7 Procedures for reviewing and updating the emergency response plan. The Rayonier Jesup Mill maintains a twenty-four hour emergency response team trained in these emergency response procedures. All mill personnel are trained in evacuation procedures. Rayonier periodically conducts emergency response drills. The written emergency response plan has been communicated to the local emergency response officials. 7.0 PLANNED CHANGES TO IMPROVE SAFETY The Jesup Mill constantly strives to improve the safety of our workers and the safety of our processes. There are many systems in place to achieve this goal. Currently, the entire mill is undergoing extensive training in "Behavior Based Safety" to improve overall safety performance. This program is entitled SPEAR and is underway with a steering committee guiding the effort. The SPEAR concept is based on changing worker safety behavior by individually conducting observations and providing feedback to other employees as they perform their duties. Incident investigations are also performed to improve safety. These investigations are conducted whenever an incident has the potential to affect the safety of workers. Major efforts to improve our safety are also underway with Jesup's new SkillsNow computer based training program. Technologies are currently being evaluated that will substantially reduce our current usage and storage inventories of Chlorine. We expect to see these reductions over the next three to five years. A new computer-based operating procedure/training system has been developed for the Chlorine, Chlorine Dioxide and Sulfur Dioxide systems which will facilitate procedure changes and will provide operators easier access to process information. Since 1995, the Jesup Annual Environmental, Safety and Health Continuous Improvement Plan has provided a focus for safety improvement. Mill-wide goals are establi shed each year and each mill department is charged with developing an improvement plan that contributes to each element of the mill plan. A recently reorganized Central Safety and Health Committee continues to provide the Jesup Mill with tangible safety improvements primarily based on active participation and suggestions from employees. 8.0 CERTIFICATION Refer to the Form included with the RMP submittal. 9.0 DATA ELEMENTS Refer to Section 1 Registration Information. |