Willamette Industries, Inc., Albany Paper Mill - Executive Summary |
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Per the requirements of Section 112(r) of the Clean Air Act Amendments of 1990 as codified in Title 40 of the Code of Federal Regulations (CFR) Part 68, this Risk Management Program (RMP) plan is submitted to the United States Environmental Protection Agency (U.S. EPA) in a timely manner for the Willamette Industries, Inc., (Willamette) pulp and paper mill (SIC 2611, NAICS 322121) in Albany, Oregon. 1. STATIONARY SOURCE & REGULATED SUBSTANCES HANDLED Willamette owns and operates a pulp and paper mill located in Albany, Oregon, which is an existing major stationary source per the requirements of Title V of the 1990 Clean Air Act Amendments of 1990. The mill handles anhydrous ammonia, which is considered hazardous by the U.S. EPA. Anhydrous ammonia is used in the pulp mill's cogeneration plant as part of the Selective Catalytic Reduction (SCR) system that reduces emissions of nitrogen oxides (NOx) from the cogeneration plant turbine. The maximum quantity of ammonia that can be stor ed or handled at this facility is 76,440 pounds. 2. ACCIDENTAL RELEASE PREVENTION POLICY Willamette has a Process Safety Management (PSM) Plan under OSHA requirements for the prevention of accidental releases of ammonia from the ammonia process. The plan covers employee participation, process safety information, process hazard analyses, management of change procedures, pre-startup safety review procedures, operating procedures, hot work permits, employee training program, incident investigation procedures, mechanical integrity, emergency planning and response, contractor safety, and compliance audits. 3. WORST-CASE & ALTERNATIVE RELEASE SCENARIOS A worst case and alternative release scenario are required for each substance. These scenarios are documented below. 3.1 WORST CASE RELEASE FOR AMMONIA Failure of the ammonia storage tank when filled to capacity would release 76,440 pounds of ammonia. Based on the requirements of the RMP rule, it is assumed that the entire content s of the tank are released as a vapor over a 10-minute period. Dispersion modeling was performed using the DEGADIS dispersion model; modeling results showed a distance to the toxic endpoint of 140 mg/m3 to be 1.60 miles (2.58 km). 3.2 ALTERNATIVE RELEASE FOR AMMONIA The alternative release scenario for the ammonia process is based on a clean break in a 2-inch loading line during unloading of ammonia. Based on an engineering estimate, the release rate from the ammonia tank is 4,404 lbs/min for a duration of 2.5 minutes. The alternative release was modeled using the INPUFF dispersion model; modeling results showed a distance to the toxic endpoint of 140 mg/m3 to be 0.89 miles (1.43 km). 4. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM & CHEMICAL-SPECIFIC PREVENTION STEPS The mill complies with EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations. 5. FIVE YEAR ACCIDENT HISTORY A minor release of ammonia occurred at the mill on August 28- 29, 1999 as a result of a leaking valve fitting on a vent line. The downwind ammonia sensors detected slightly elevated ammonia concentrations and triggered an alarm as designed. No injuries, damaged property, off-site evacuations, or environmental damage took place as a result of the release. Therefore, the release is not reportable under the RMP rule. Willamette conducted a formal investigation of this incident to identify and correct the root cause of the event. 6. EMERGENCY RESPONSE PROGRAM Willamette maintains a written integrated emergency response plan to safely respond to accidental releases of hazardous substances at the mill. The plan identifies personnel roles, lines of notification, and evacuation procedures for handling various emergencies that may take place at the mill. The plan also provides contact information for other responders/agencies, and emergency training procedures for personnel at the mill. The emergency response procedures are coordinated with the Albany Fire Department. 7. RMP MANAGEMENT SYSTEM A management system has been established to identify responsibility for the development, implementation, and maintenance of the Risk Management Program. The RMP is required to be updated every three years, or any time a covered process undergoes a physical or administrative modification. The following personnel are responsible for the development, implementation, and maintenance of the plan: John Goldsberry, Safety Specialist: overall responsibility of overseeing RMP, management of change, incident investigations, Emergency Response Plan, coordination of compliance audits, track regulations Jack Carter, Environmental Engineer: coordination of Process Hazard Analysis (PHA) group, pre-startup safety procedures, track regulations Cam Crawford, Training Coordinator: oversee and develop training program, track training of employees, contractor training program Jim Pruett, Power and Recovery For eman: oversee process operation, develop operating procedures for process, on-the-job training and testing Gary Hodges: Process Safety Information (PSI) documentation Vaughn Pieschl: coordinate with local responders; coordinate plant's emergency response team (ERT) Dan Barrett, Ken Moseley: develop and implement maintenance schedule 8. PLANNED CHANGES TO IMPROVE SAFETY Willamette continues to improve safety conditions at the facility by implementing changes to the process safety management program that were identified during the October 1, 1998, audit. These changes are expected to be complete by August 1, 1999. Additionally, Willamette is working toward long-term safety improvements by replacing gaseous chlorine use in the water treatment area with sodium hypochlorite. This change was complete by April 30, 1999. |