Willamette Industries Inc.- Johnsonburg mill - Executive Summary |
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Background: Willamette Industries Inc. owns and operates a Pulp and Paper mill located in Johnsonburg PA (Elk County). The mill manufactures approximately 1100 tons per day of fine specialty paper and 650 tons per day of bleached hardwood Kraft pulp. The mill has a 110 year old papermaking tradition and was purchased in 1990 by Willamette Industries. An extensive mill wide expansion and modernization project combined with a comprehensive personnel training program was immediately implemented for the aging facility to improve its operating efficiency, environmental and safety performance. This project was completed in 1994 and resulted in the installation of the latest production and environmental control technology available. As a result the mill became compliant with the EPA Cluster Rules upon start up in 1994, three ye ars before the final promulgation of these regulations. The mill is subject to OSHA CFR 1910.119 requirements - Process Safety Management (PSM) of Highly Hazardous Chemicals and is considered a "Program Three" facility under RMP. A thorough review and evaluation of the mill's manufacturing process to determine threshold quantities of regulated substances was conducted related to these regulations. As a result of this review Chlorine Dioxide (CLO2) was determined to be applicable . A PSM plan was developed and implemented as required by the January 1, 1994 deadline by the core team members and its oversight committee. A Process Hazard Analysis (PHA) was conducted on the covered process (Chlorine Dioxide) as required every five years on December 16, 1998 to revalidate. The majority of action items identified during the PHA and have been completed. Those remaining action items requiring longer lead times and extended outages will be completed by 12/31/99. A PSM compliance audit a s required every three years by 40 CFR 68.58 was conducted in 8 / 96. The next audit is scheduled in 7 / 99. 1. Accidental Release prevention and emergency response policies for the Stationary source: Chlorine Dioxide is generated at the Fiberline as the primary bleaching agent of hardwood pulp used in the paper manufacturing process. The generation of Chlorine Dioxide at the Johnsonburg Mill is a highly controlled process using a Eka Nobel SVP-HP system. This system is technologically advanced as well one of the safest available. Accidental release prevention procedures utilize the mechanical integrity section of the process safety management program. Mechanical integrity requirements for the chlorine dioxide process include documented maitenance, inspection, testing and repair procedures intended to maintain a high level of operating efficiency and safety. Additionally, regularly scheduled shutdowns of the Fiberline bleach plant and chlorine dioxide plant are used to im plement detailed equipment inspections and preventative maintenance to further minimize accidental releases. The entire chlorine dioxide generation system is under a vacuum to reduce the possibility of chlorine dioxide decomposition and includes a fully automated emergency shutdown sequence. Emergency response standard operating procedures have specifically been developed for the covered process to implement a safe shutdown. Emergency off site response notification procedures are posted in the Fiberline control room for community fire department and Haz-Mat team assistance in the event of a chlorine dioxide release. These procedures are additionally part of the mills Preventive, Preparedness and Contingency (PPC) plan. The PPC plan is intended to be an integrated facility plan designed to provide instruction during emergencies and is updated as needed to maintain accuracy. The lastest update being August of 1998. The mills emergency response procedures contained in the PPC plan i ncluding the off-site response plan has been peridiocally tested by county wide cooperative drills involving the Local Emergency Planning Commission (LEPC). The written emergency off site response plan has been approved and incorporated by the LEPC as required by section 303 of EPCRA. 2. Stationary source and regulated substance: The stationary source is the chlorine dioxide generation process where sodium chlorate and sulfuric acid solution combine in a hydrogen peroxide-based reducing agent to produce chlorine dioxide, the regulated substance handled under PSM and RMP regulations. 3. Worst case release scenario (WCS) - The worst case scenario selected was a spill from a single chlorine dioxide storage vessel (89,300 gal or 7,453 lbs CLO2) containing a 1 % by weight chlorine dioxide solution. The secondary containment in place (passive mitigation) is sufficient to contain the release. The release is calculated (DEGADISv2.1 model) as a low concentration water solution evapora tion release using the pool area and liquid factor ambient value for CLO2. A calculated release rate of 61 lbs/minute for 122 minutes has a distance to end point of 2.8 miles. Administrative controls for the WCS include written emergency shutdown and off-site reponse notification procedures and related PSM program elements. Alternative release scenario (ARS) - The alternative release senario selected was the failure of a CLO2 transfer line between the storage tank and bleach plant containing a 1 % by-weight chlorine dioxide solution. This release was also calculated as a low concentration water solution evaporation release (25 lbs CLO2 total) usinf the DEGADISv2.1 model. A calculated release rate of 57.6 lbs CLO2 / minute for 0.4 minutes has a distance to end point of 0.99 miles. Active mitigation controls include pressure monitoring of the CLO2 transfer line, automatic shut off of control valves in the event of line pressure loss and spill neutralization procedures involvi ng the capabilities of the on site effluent treatment plant. Administrative controls for the ARS include written shutdown and off site response notification procedures and PSM program related elements. 4. General accidental release prevention program and chemical specific prevention steps: Process safety management for the covered process of chorine dioxide is the primary accidential release preventation program at the Johnsonburg mill. Implementation and enforcement of the PSM program elements is intended to ensure legal compliance with both PSM and RMP requirements and the safety of mill personnel and the community. Chemical specific prevention steps include conducting regular comprehensive process hazard analyses to revalidate the process as part of the PSM program and completion of action items identified during the exercise. 5. Five year accident history: No accidents were experienced in the five year history involving chlorine dioxide that meet the criteria listed in 40 CFR 68.42 (a). 6. Emergency response program: As stated in item one the primary emergency response program for the Johnsonburg mill is contained in the PPC plan. The plan incorporates all emergency scenarios and provides guidance for response to incidents in the RMP / PSM covered process of chlorine dioxide. Additionally, off site emergency response notification procedures are posted in the Fiberline control room in the event of a chlorine dioxide release. The PPC plan is included in mandatory mill personnel training and as stated above is tested in cooperation with the Elk county LEPC. 7. Planned changes to improve safety: A planned change to be investigated for implementation as part of the 12/ 98 PHA is the installation of a water deluge system for Fiberline additive tank farm area. This system would be used as an active mitigation response to a leak from either of the two chlorine dioxide storage tanks located in the tank farm and designed to supress CLO2 vapors to minimize release potential. Additional safety improvements (action items) resulted from the 1998 revalidation of covered process PHA and are contained with anticipated completion dates within that document. |