Ponderay Newsprint Company - Executive Summary
Ponderay Newsprint Company (PNC) owns and operates a newsprint mill, at 422767 SR 20 in Pend Oreille County at Usk, Washington. Production facilities include a chip unloading and handling facility, a 610 T/D thermo-mechanical pulp mill, a 120 T/D waste paper recycling facility, and one paper machine producing approximately 700 T/D of standard newsprint. Auxiliary facilities include primary and secondary effluent treatment and a propane-fired steam boiler rated at 180,000 lbs./hour. |
PNC is committed to protecting people and the environment. As the company was formed, the leaders developed Philosophy Statements that guide business decisions. One of these is "We want to ensure a clean, safe work environment through attitudes, awareness, training, promoting safe work habits and by complying with all government regulations." Another states: "We want to operate our facility in a manner that will protect the environment." The policy is to use current best management practices to minimi
ze the possibility of an accidental release of a hazardous material. In the event of an accidental release, active mitigation would take place immediately by a trained emergency response team that is maintained on-site 24 hours/day seven days/week.
PNC has two substances that are regulated under the Risk Management Planning Standard (40 CFR 68 section 112(r)).
1) Sulfur Dioxide is delivered by railcar and is unloaded to the process. This chemical is used as a brightening agent in the pulping process. The railcar is located outside, east of the TMP mill (SE corner of the main building).
2) Propane is delivered by railcar or truck and is unloaded into the propane storage facility that consists of five 30,000-gallon tanks. The propane storage area is located approximately 450 feet East of (and situated parallel to) the main building. This propane fuels the mill's boiler.
The RMP regulations require a consequence analysis of a worst case scenario for both Sulfur Dioxide and Propan
e. A worst case scenario is if the entire content of the largest storage vessel is released to the atmosphere in 10 minutes and vaporizes immediately. The atmospheric conditions given are very calm winds, very stable conditions, and 77 degrees F. The worst case scenarios would be nearly impossible given the following:
7 A catastrophic failure of a certified pressure vessel would have to occur (a hole about 12" in diameter).
7 Sulfur dioxide is stored as a liquid under pressure. In the case of a large leak, it would pool as a liquid and vaporize over a period of time greater than 10 minutes.
7 The circle of concern does not take into account elevation changes. Sulfur Dioxide and Propane are much heavier than air and would not disperse to high areas.
7 The atmospheric conditions specified are rarely experience at this location.
The alternate release scenarios contained in this report are the "more realistic" worst case scenarios for Sulfur Dioxide and Propane.
7 For the Sulfur Dio
xide process, the failure of an unloading hose and excess flow valve was chosen as the alternate worst case. This assumes not only failure of the hose, but also failure of the excess flow valve (designed to prevent this type of situation). This release would be detected almost immediately by gas sensors in the area that would set off the mill-wide Hazardous Materials alarm. The HazMat team would respond immediately to address the situation (there is a trained Hazardous Materials Response team on-site at all times).
7 For the propane system, several possibilities were examined and it was determined that a relatively small leak in the storage area that went undetected for a significant period of time would pose the greatest hazard. Analysis of this scenario revealed that there would be no public receptors. Rigorous procedures are in place that minimizes the risk of this type of occurrence.
7 The HazMat team is also trained as an industrial fire brigade and conducts routine drills o
n responding to many types of emergency situations including Sulfur Dioxide and Propane releases. The team also participates in regularly scheduled joint training drills with local emergency response agencies.
Although there are contingency plans in place should an emergency situation arise, the prevention of releases of hazardous substances to the environment is of the utmost importance. There are many processes in place, which are designed and implemented to prevent emergency situations from occurring.
7 Area teams (made up of operators, electrical & instrumentation technicians, and mechanical maintenance technicians) actually "own" the Sulfur Dioxide and Propane systems. They have identified critical pieces of equipment in each area and maintain written preventative maintenance plans for that equipment.
7 There are detailed operating procedures and rigorous training and certification standards for all operators. This insures that personnel operating the Sulfur Dioxide and Propa
ne processes are fully qualified.
7 The Sulfur Dioxide and Propane systems are inspected daily by a qualified operator.
7 The Sulfur Dioxide and Propane systems are included in the mill safety inspection program. This process insures the entire plant is inspected every 5 weeks.
7 An internal audit process is maintained that monitors adherence to operating procedures as well as safety policies, environmental policies, and legal requirements (Process Safety Management regulations, etc.).
7 A change management system insures that any change to the Sulfur Dioxide or Propane processes is thoroughly researched and documented. Training on process changes is an important part of this system.
7 All Sulfur Dioxide lines are purged with air and the Sulfur Dioxide is neutralized in a caustic tank prior to opening any piping. This minimizes incidental releases to the environment.
7 There have been no releases of Sulfur Dioxide or Propane with an off-site consequence in history of the facility.
Ponderay Newsprint Company believes that safety of employees, neighbors, and protection of the environment is very important. Another of the Philosophy Statements reads: "We want an organization that is recognized as a good neighbor." Safety and environmental aspects are considered in all decisions. Improvement in performance is "built in" to management systems. Ponderay Newsprint continually looks for ways to improve processes to make them safer and more environmentally friendly.