GILMAN PAPER COMPANY, ST, MARYS KRAFT DIVISION - Executive Summary |
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GILMAN PAPER COMPANY- ST. MARYS KRAFT DIVISION RISK MANAGEMENT PLAN EXECUTIVE SUMMARY 1. Corporate Prevention and Emergency Response Approach The Gilman Paper Company-St. Marys Kraft Division (Gilman Paper) facility is a kraft pulp and paper mill facility owned by Gilman Paper Company, located in St. Marys, Georgia. Gilman Paper's corporate philosophy requires each facility to develop and maintain accident prevention programs and an emergency response plan appropriate to the site. Each site is also responsible for regulatory compliance issues that apply to the site. Gilman Paper's environmental and safety personnel provide assistance in training for site employees and in budgeting and procurement of safety and training services. 2. Description of Stationary Source The Gilman Paper facility is located at 1000 Osborne Street, in the northeast portion of the city of St. Marys, Camdem County, Georgia. The facility produces more than 100 grades of paper including: kraft paper for conversion to usable products; envelope, book, and other fine papers; specialty papers; and bleached paperboard for consumer packaging. The Gilman Paper facility has three substances; chlorine, chlorine dioxide, and aqueous ammonia, onsite which exceeds the RMP threshold quantity for toxics of 2,500, 1,000, and 20,000 lbs, respectively. The facility also has propane, a flammable substance in excess of the RMP threshold quantity of 10,000 lbs onsite. Chlorine is stored in railcars on site with capacities of 90 tons each. Two railcars are in service at one time. Chlorine dioxide is produced onsite and stored temporarily in two above-ground tanks with a capacity of 15,500 gallons each also in close proximity to the facility's bleach plant. Aqueous ammonia (30% concentration of ammonia) is kept onsite in an aboveground storage tank with a capacity of 11,000 gallons (24,255 lbs of ammonia) located near the employee entrance to the facility at the southern plant property boundary. Propane is kept in two above ground storage tanks that have a total capacity of 67,000 pounds each. Propane is used as a fuel on site for the facility's coaters on the paper machines and is the primary fuel for the facility's forklifts. The propane storage tanks are located near the aqueous ammonia tank and is delivered by truck to the facility. 3. Description of the Worst Case and Alternative Release Scenarios 3.1 Toxics The Worst Case release scenario for chlorine is the rupture of the one of the 90-ton railcars, releasing 180,000 lbs. of chlorine gas over a ten minute period. Under worst case weather conditions, the chlorine gas could travel 25 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .0087 mg/L), using the OCA Guidance. The Alternative-Case release scenario for chlorine is an accident during the unloading of the railcar to the vaporizers. Failure of the 2-inch diameter liquid transfer hose h appens due to human error in connection of the piping to the vaporizers from the railcar. The chlorine is released from the railcar through the hose until the excess flow valve shuts off the flow from the railcar. Gilman has railcars that are equipped with excess flow valves that limits the flow rate to 15,000 lbs/hr or 250 lbs/min. At this release rate, under normal weather conditions, taking in consideration the Gilman personnel reaction to chlorine detectors going off and the excess flow valve stopping the flow within 10 minutes, the chlorine gas could travel 0.7 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than 0.0087 mg/L), using the RMP Guidance for Waste Water Treatment Plants (WWTP). The Alternative-Case release scenario for chlorine dioxide is failure of a 6-inch liquid process pipe from the storage tank to the chemical feed pumps. The chlorine dioxide is released from the pipe and pools on the gro und with no passive mitigation. It is estimated that the leak will occur for approximately 15 minutes before Gilman personnel react to the chlorine dioxide alarms and notice the flow rate is wrong for the chemical feed pumps. At a vapor release rate of 45.2 lbs/min, under normal weather conditions, taking in consideration the Gilman personnel reaction to chlorine detectors going off and stopping the pumps, the chlorine dioxide gas could travel 1.2 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than 0.0028 mg/L), using the SLAB model. The Alternative-Case release scenario for aqueous ammonia is failure of a 2-inch liquid process pipe from the storage tank to the chemical feed pumps. The aqueous ammonia is released from the pipe and pools on the ground with no passive mitigation. It is estimated that the leak will occur for approximately 15 minutes before Gilman personnel react to the flow indicator alarms in t he mixing room of the paper machine building and stop the flow from the chemical feed pump. At a vapor release rate of 11.06 lbs/min, under normal weather conditions, taking in consideration the Gilman personnel reaction to spill and stopping the pumps, the ammonia gas could travel 0.19 miles before dispersing enough to no loner pose a hazard to the public or environment (reaching a concentration less than 0.14 mg/L), using the OCA Guidance method. 3.2 Flammables The Worst Case release scenario for propane is the failure of the largest storage tank when filled to the greatest amount which would release 67,000 lbs. of propane. It is assumed that the entire contents are released as vapor which finds an ignition source, 10% of the released quantity is assumed to participate in the resulting explosion. The distance to the endpoint of 1 psi for the worst case analysis is 0.30 miles using the OCA Guidance. The Alternative-Case release scenario for propane is a failure of the 2-inch process pipe due to corrosion near the propane storage tank. The contents of the process pipe is released, however the excess flow valve closes to prevent flow from the tank and only the contents of the pipe is spilled. The resulting unconfined vapor cloud travels to the lower flammability limit. The distance to the endpoint for the lower flammability limit for the alternative-case scenario is less than 0.10 miles (528 feet). This release has the possibility of extending beyond the facility boundary since the storage tank is next to the property boundary's fence line. 4. Prevention Program This facility exceeds the chlorine and chlorine dioxide threshold quantities in those two process for the OSHA Process Safety Management (PSM) Standard, 1910.119, and is therefore subject to the PSM requirements. The facility also exceeds the flammables threshold quantity for its propane system and the toxics threshold quantity for aqueous ammonia and is therefore subject to the RMP requireme nts. For RMP compliance purposes, this places the Gilman Paper facility's chlorine and chlorine dioxide processes in the Program 3 level and the aqueous ammonia and propane processes in Program 2 level. Gilman Paper will use its PSM program as the required Program 3 Prevention Program for chlorine and chlorine dioxide. The facility will address the required Program 2 Prevention Program for the aqueous ammonia and propane processes by expanding its PSM program for the applicable seven elements. The Gilman Paper facility has a program in place to comply with the OSHA Process Safety Management Standard, 29 CFR 1910.119. The PSM Program was audited in 1998 for the chlorine and chlorine dioxide processes. The PSM Program includes a preventative maintenance plan which requires all covered process equipment to be periodically inspected and serviced. This will ensure that the equipment remains in good operating condition and will minimize the probability of accidents due to faulty equip ment. In developing the PSM Program, Gilman Paper also developed written operating procedures for both processes. These procedures cover all phases of operation and include information on safety devices. These procedures will be used to train all operators and mechanics who work on the covered processes to ensure consistency of operation and minimize human error. Existing safe work practices such as Lockout/Tagout and Hot Work Permit, were reviewed and updated to ensure that all non-routine work can be performed safely. Other components of the prevention program include collection and review of all equipment information, the development of updated Piping & Instrumentation Diagrams (P&IDs), and the correction of any equipment design deficiencies found. These actions will ensure that the equipment meets all the Chlorine Institute industry standards and that accurate equipment information will be available when needed. Other PSM procedures, including Management of Change, Pre-Star tup Safety Review, Compliance Audits, and Incident Investigation are also part of the program to ensure continued safe operation and prompt correction of deficiencies. The PSM Program receives full support of plant management and involvement of employees at all levels. 5. Accident History The Gilman facility has had no accidental releases of chlorine dioxide, aqueous ammonia, or propane in the past five years. However, Gilman has had approximately thirteen reportable accidental releases of chlorine in the past five years. Of those releases, no offsite injuries, deaths, or property damage have occurred as a result of the releases. Five of the accidents resulted in workers having chemical inhalation injuries, but all were treated onsite and none had long lasting injuries. One person went to his personal physician and had some lost work time. Most if not all the releases have occurred from scrubber bypasses due to equipment failure or regular maintenance on the bleach plant scrub ber. A backup scrubber has been planned to be installed in early 2000 to ensure these releases do not occur again due to equipment failure. 6. Emergency Response Program The Gilman facility has an Emergency Response Program in place. The program complies with 29 CFR 1910.38. The site also has some internal emergency response capability and is developing a program to comply with paragraph (q) of 29 CFR 1910.120. The current plan has been coordinated with the St. Marys Fire Department. Notification is made locally by dialing 911 or 729-3911, and by notifying Georgia State Warning Point or the Emergerncy Operartions Center (EOC) at (800) 241-4113. |