Bowater Incorporated Coated Paper Division - Executive Summary
EXECUTIVE SUMMARY |
Bowater Coated Paper Division (Bowater) operates a pulp and paper mill in Catawba, South Carolina. The Bowater paper mill uses several chemicals in the process of manufacturing paper,
which are regulated by the Risk Management Program (RMP). The applicable chemicals include chlorine, chlorine dioxide, sulfur dioxide, and propane. These four regulated chemicals are used in four process areas of the facility. Chlorine is used in the bleach plant to brighten wood pulp from the kraft pulp mill prior to being converted into paper. Chlorine usage for pulp brightening is being phased out at the facility, and no elemental chorine will be used for this purpose after 2004. Chlorine dioxide is also currently used to brighten kraft pulp, and usage will be increased as elemental chlorine dioxide usage is phased out. Chlorine is also used in the facility filter plant as a water disinfectant. Sulfur dioxide is used by the facility to brighten wood pulp produced by the ther
mo-mechanical pulp mill prior to conversion into paper.
Accidental Release Prevention and Emergency Response Policies
The Bowater facility is operated in the safest manner possible. Bowater strives to eliminate all accidents, and has numerous programs in place at the facility to work toward this goal. In the event of an accidental release, Bowater has emergency response programs in place to minimize the release of materials and to notify and protect employees, the nearby community, and the environment.
Stationary Source and Regulated Substances
Bowater is subject to RMP requirements for the following chemicals and processes:
7 Chlorine (kraft mill bleaching)
7 Chlorine (filter plant)
7 Chlorine Dioxide (kraft mill bleaching)
7 Sulfur Dioxide (thermo-mechanical pulping)
Bowater has the capacity to store approximately 184,000 pounds of chlorine. The chlorine is stored at two locations, the Kraft Mill and the Filter plant. Approximately 1,759,740 pounds of chlorine dioxide are
stored in the Kraft Mill. Bowater also has the capacity to store approximately 367,000 pounds of sulfur dioxide. The sulfur dioxide is stored in two identical storage tanks of 16,042 gallons capacity in the Thermo-mechanical Pulping (TMP) mill.
Worst-case Release Scenario and Alternative Release Scenario
The table below outlines the outcome of the off-site consequence analysis portion of the RMP.
Release Description Distance to Toxic Endpoint Distance Determination Method
Worst-case Chlorine (bleaching) 90 ton railcar 14 miles Look-up tables
Chlorine (filter) 1 ton cylinder 1.3 miles Look-up tables
Sulfur Dioxide 15,000 gal. storage tank (172,000 lb) 15 miles Look-up tables
Chlorine Dioxide 312,419 gal. storage tank (31,283 lb) 19 miles DEGADIS
Alternate Chlorine (bleaching) 4,200 lb (70 lb/min) released 10-12-96 0.2 miles Look-up tables
Chlorine (filter) 10 lb released 3-15-94 0.1 miles Look-up tables
Sulfur Dioxide 2 inch pipe break 0.5 miles Look-up
Chlorine Dioxide 100 gal. (3.3 lb/min) released 3-13-98 0.4 miles DEGADIS
The October 1998 EPA wastewater treatment plant look-up tables are in close agreement with the site-specific DEGADIS air dispersion modeling. Therefore, the EPA look-up tables were used for all chemicals except chlorine dioxide, which was modeled using the EPA DEGADIS air dispersion model.
The facility does not have any release prevention systems which qualify as passive mitigation under EPA definitions. Therefore, no mitigation systems were accounted for in the worst-case analysis.
For the alternative analysis, actual releases of regulated each chemical were used. The only exception is for sulfur dioxide, because there have been no releases within the previous five years. The alternative release scenarios for chlorine and chlorine dioxide are based on the largest actual release within the last five years. The alternative scenarios already include devices considered active mitigation by EPA, su
ch as excess flow valves, pressure relief values, vent scrubbers, and so forth.
General Accidental Release Prevention Program and Chemical Specific Prevention Steps
The storage of chlorine, chlorine dioxide, and sulfur dioxide is also subject to the requirements of the Occupational Safety and Health Administration (OSHA) regulations for Process Safety Management (PSM). The OSHA regulations require the regulated process to undergo a process hazards analysis (PHA) and it must meet all of the other management requirements of the regulations. Bowater's has completed and implemented such a program.
The elements required for a Program 3 Prevention Program as required in 40 CFR Part 68,
Subpart C are included in Bowater's Process Safety Management Plan required by 29 CFR 1910.119. The elements include:
o Process Safety Information
o Process Hazard Analysis
o Operating Procedures
o Mechanical Integrity
o Management of Change
o Pre-Startup Review
o Compliance Audits
o Employee Participation
o Hot Work Permits
Process Safety Information
Bowater has gathered and will maintain up-to-date safety information related each chemical. The current process safety information for each chemical is maintained in the PSM program manual for the process. The manual contains a Material Safety Data Sheet (MSDS) for each chemical containing information pertaining to its hazards, piping and instrument diagrams (P&ID's), list of critical equipment items, and equipment specifications.
Process Hazard Analysis
Bowater assembled a team of individuals with expertise in engineering and process operations to perform the process hazard analyses required by OSHA standard 1910.119 and 40 CFR 68. The Hazard and Operability (HAZOP) Method was used for the process hazard analyses. The objective of each process hazard analysis is to identify, evaluate, and control hazards that may result in the catastrophic release of the hazardous chemica
l. Each process was divided into several sections for the analysis. All of the recorded incidents and near misses that have occurred during the life of the process were reviewed for the analysis. The OSHA standard requires that a process hazard analysis update be performed at least every five years.
Bowater will maintain up-to-date operating procedures for each process. The current operating procedures are maintained in the PSM program manual. Bowater refers to these procedures as Competency Based Learning (CBL) manuals. Bowater will continue to review and update these procedures as process changes take place in each process.
Bowater maintains documentation of training programs for the chlorine processes at Kraft Mill in the PSM Program manual. The operating procedures are maintained within the training manuals for each part of the process. As stated above, Bowater refers to these training programs as CBL manuals. There are two different typ
es of training programs at Bowater. Some of the programs are written for self-study or classroom training, while other programs require on-site training sessions. These on-site training sessions are generally used to teach employees operating procedures of certain equipment. Employees are taught these skills by observing the performance of the operation. The employee will then have to perform the same operation correctly to pass the course. The self-study or classroom training programs include self-check tests throughout the manuals. Competency tests are also provided in these training manuals. Employees pass the course when they complete the test with 100% accuracy. The manuals for these programs often include prerequisites, summaries of the purpose, performance objectives, enabling objectives, and directions for use of the training guide.
All new employees are provided with initial training of the processes and refresher training is provided every three years. The training
sessions are provided in a classroom setting or at the site of the processes. As described above, written competency tests or performance evaluations are used to evaluate the employees. Bowater will continue to review and update the training programs as process changes take place in each process.
Bowater has established and implemented written procedures in an effort to maintain the ongoing mechanical integrity of the process equipment used in each covered process. An inspection and testing program has been established for all critical equipment. Critical equipment is any equipment that is in direct contact with the process chemical or by its failure or improper operation, could cause a catastrophic release of the process chemical. Examples of critical equipment are pressure and storage tanks, pumps, piping systems, relief and vent devices, emergency shutdown systems, and controls that include monitoring devices, sensors, alarms, and interlocks.
nt of Change
All changes to the process are thoroughly evaluated in order to assess their potential impact upon the safety and health of employees and to determine what modifications to operating procedures may be necessary. Bowater has established written procedures to manage these changes to processes. There are two standard forms that are completed to document management's approval of the changes.
Pre-Startup Safety Review
If Bowater should establish a new facility or modify an existing facility which triggers a change in process safety information, Bowater will perform a pre-startup safety review. The operating department head is responsible for ensuring that the pre-startup safety review is conducted prior to the introduction of chemicals to the system if a process change has occurred. Bowater has a pre-startup review checksheet, which must be completed during the pre-startup safety review if a change in process information is required. Bowater will continue to conduct the
se pre-startup safety reviews in the future, documenting any changes in the PSM manual on the pre-startup safety review checksheet.
Bowater's process safety management system is evaluated at least every three years to determine its effectiveness and to identify potential weaknesses. Bowater will continue to conduct compliance audits at least every three years or have them conducted by an outside contractor.
Bowater investigates all incidents which result or may result in a catastrophic release of chlorine. Bowater has established a procedure to thoroughly investigate and analyze each incident. Following each incident, a team of Bowater employees will investigate the incident and make recommendations to help prevent the same type of incident in the future. The investigation team prepares a report following the incident investigation and then Bowater promptly addresses the report's findings.
Bowater is dedicate
d to employee participation in the development and implementation of this Risk Management Program and the Process Safety Management Plan. Outside of these two plans, Bowater project leaders and other management are always willing to listen to the concerns of the employees, especially when it comes to process safety. Management will not hesitate to make process changes if they feel it will make a safer work environment for the employees. Safety is a high priority at Bowater. The development of the entire PSM plan involved many Bowater employees from several different departments. Including employees from several different departments and levels for the development of the PSM enabled Bowater to consider all aspects of the processes and their safety. Encouraging employee participation has and will continue to enhance the safety of Bowater's work environment.
Bowater will provide to all employees access to the process hazard analyses and to all other information developed as part o
f this Risk Management Program, as required by 40 CFR 68.83(c). The Risk Management Program and the Process Safety Management Program, including the process hazard analysis, will be available to employees. The location and a description of each plan will be discussed in the training programs for the employees.
Hot Work Permits
Bowater requires hot work permits for all hotwork operations performed at the Catawba facility. All hotwork permits are maintained on file at the facility until completion of the hotwork operations.
Bowater has procedures established for the selection process of a contractor. There are several elements in these procedures which each contractor must provide including documentation that the contractor has received training regarding the process safety procedures as required by OSHA. The contractor must also include documentation that the training topics were understood. Bowater monitors the safety performance of all contractors on an ongoing
Chemical-specific Prevention Steps
Chlorine - Kraft Mill
Bowater has several process controls in use to help prevent the occurrence of major hazards including the following: relief valves, excess flow valves, check valves, rupture disks, alarms and procedures. There are no known mitigation systems used for chlorine storage in Kraft Mill. There are several detection monitors located in this process area for chlorine, low flow, pressure, and temperature.
Chlorine - Filter Plant
Bowater has several process controls in use to help prevent the occurrence of major hazards including the following: relief valves, check valves, rupture disks, alarms and procedures. There are no known mitigation systems used for chlorine storage in the Filter Plant. There are several detection monitors located in this process area for low and high temperatures.
Bowater has several process controls in use to help prevent the occurrence of major hazards including the followin
g: vents, relief valves, excess flow valves, check valves, rupture disks, automatic shutoffs, manual shutoffs, alarms and procedures. Dikes are used as mitigation systems for the sulfur dioxide stored in the TMP mill. There are several detection monitors located in this process area for sulfur dioxide and other process parameters.
Bowater has several process controls in use to help prevent the occurrence of major hazards including the following: vents, relief valves, check valves, scrubbers, interlocks, alarms and procedures, and purge system. There are no known mitigation systems used for chlorine dioxide storage in Kraft Mill. There are several detection monitors located in this process area for different process parameters.
Five-Year Accident History
A five-year accident history must be completed for each covered process and included in the Risk Management Program. Bowater reviewed its history for any record or memory of any accidental releases involving
regulated chemicals and processes in the last five years. These releases are summarized below. If an accidental release should occur in the future, this section of the Risk Management Program will be updated and Bowater will maintain a record of the accident for at least five years.
Chlorine - Filter Plant
Bowater had records of three small chlorine releases occurring in the Filter Plant in 1994. One release did cause one reportable injury; therefore, this is a reportable release according to the 112(R) regulations.
The reportable release for the Filter Plant occurred on March 15, 1994. One of the wastewater treatment operators found a chlorine leak in the chlorinator room. A full investigation was performed the following day and it was determined that the failure of a PVC line caused the leak. Following the incident, it was recommended that sections of the PVC pipe should be replaced with stainless steel pipe. Based on the results of the investigation, equipment was improve
d to help prevent similar incidents in the future. The operator who found the leak had inhaled chlorine gas and had to be taken to First Aid. Bowater reported this incident as a Doctor Case, according to OSHA requirements. The release did not impact any other employees on-site or any off-site receptors.
Chlorine - Kraft Mill
The Kraft Mill has had four reportable releases according to the reporting requirements of the 112(R) regulations.
The most recent reportable release in the Kraft Mill occurred on November 27, 1996 at 2:00 p.m. The chlorine sensor near the vaporizers detected a chlorine leak. During the investigation, one operator inhaled chlorine gas from a leak in the evacuation header before he could see the leak. The operators then found the leak at the railcar in service and proceeded to manually valve that car out of service. Two operators were sent to the hospital for observation and were released the same day. There were no other known injuries from this in
cident, and the release did not impact any off-site receptors.
Another reportable release of chlorine occurred in the Kraft Mill on October 12, 1996. On the evening of this day, a chemical operator was "valving" a full chlorine railcar into the system. The operator accidentally charged the system header with liquid chlorine while the header evacuation line was open. This action resulted in liquid chlorine being vented to the evacuation line scrubber. Chlorine that could not be absorbed by the scrubber system was released into the air. Additional chlorine was released when a circulating pump on the scrubbing system tank failed. One employee was injured during this incident with a sprained ankle and chlorine inhalation. It is believed that there were no off-site receptors impacted by this release.
Another reportable release of chlorine occurred in the Kraft Mill on June 12, 1995. A Utility employee was exposed to chlorine fumes causing shortness of breath. The incident occurr
ed when the employee was preparing to connect a chlorine car to the mill transfer lines. The employee had a respirator with him; however, he was not wearing it when opening the chlorine line. Chlorine gas was released from the line as he loosened the plug on the end of the line. The employee quickly escaped, put on his respirator, and returned to tighten the line to control the leak. This employee was the only person who inhaled chlorine gas as a result of this release. In addition, the release did not impact any off-site receptors. The committee who investigated the incident recommended that the operating procedures be reviewed with all unloading personnel. It was also recommended that personnel should wear a respirator when opening a chlorine line.
One other reportable release has occurred in the Kraft Mill in the last five years. This release occurred on April 27, 1995. Two employees were exposed to chlorine during the incident and required first aid care. The incident occ
urred while two employees were valving out and disconnecting an empty chlorine rail car. The release occurred when one employee began disconnecting the flexible hose connection at the empty railcar dome. This employee was not wearing his respirator at this time. He knocked loose the connection and then liquid chlorine sprayed into his face causing eye irritation and shortness of breath. The employee helping to disconnect the railcar put on a full-face respirator and tightened the fitting to stop the release.
Bowater reviewed its history for any record or memory of any accidental releases involving sulfur dioxide in the last five years. No records were found and no one could recall any accidental sulfur dioxide releases in the past five years. Subsequently, Bowater has no record or knowledge of any instances in the past five years that may have caused on-site deaths, injuries, or significant property damage. In addition, there were no records or knowledge of any
releases which caused known offsite deaths, injuries, property damage, environmental damage, evacuations, or sheltering in place.
Bowater had one record of a reportable release of chlorine dioxide occurring in the Kraft Mill in 1998. This release had one reportable injury of an employee on-site; therefore, it must be reported as required by the 112(R) regulations. There were no off-site impacts resulting from this release.
Emergency Response Program
The Bowater facility has an existing emergency response plan for each regulated chemical. The existing plant emergency response plans were reviewed for compatibility with Part 68 requirements. Each plan includes the appropriate mechanisms to notify emergency responders when there is a need for a response, as required by 40 CFR 68.90(b)(3).
Each plan includes all of the required elements described in 40 CFR 68.95(a)(1). These elements include procedures for informing the public and local emergency response agenci
es about accidental releases, documentation of proper first-aid measures to treat exposures, and emergency response procedures including use of emergency equipment and training for the employees. These written plans have also been developed in coordination with the community emergency response plan.
Planned Changes to Improve Safety
Bowater constantly works to improve safety. After an accidental release has occurred, an incident report is written following an investigation. This report includes a complete description of the incident and its cause, date of incident, estimate of quantity released, and recommendations for preventing the same type of incident in the future. Each process at the facility is also periodically reviewed for safety even if no accidental releases have occurred. At this time, no safety issues have been identified which require changes to the facility.
Bowater does have other planned changes at the facility will result in removal of chlorine at the kraf
t mill bleach plant. After elemental chlorine is no longer used in bleaching, 90-ton railcars of chlorine will no longer be received.