P. H. Glatfelter Co. - ECUSTA DIVISION - Executive Summary |
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The Ecusta Divisions facility at Pisgah Forest, North Carolina is part of the P. H. Glatfelter Company. It started operation at this site in 1939. It has grown to become one of the largest employers in Transylvania County. It currently employees approximately 1,200 people. It manufacturers fine printing papers from purchased wood and non-wood pulps. The latter is also produced in an on-site Pulp Mill. It has a large converting operation and twelve paper machines. The P. H. Glatfelter Companys Environmental Policy commits the Company to a continuing effort to reduce adverse environmental impacts which may be caused by its operation. In the Policys administrative direction, Paragraph D. specifically addresses emergency situations and is quoted below: "The Company will employ effective environmental protection technologies and strategies in all operating facilities as a means of both protecting the environment and also of reducing any environme ntal, health and safety risk to our employees and the communities in which we operate. Further, the Company will maintain procedures and equipment to handle environmental emergencies." This facility at Pisgah Forest has a long history of cooperating with local response agencies, in particular, the Brevard Rescue Squad, the Brevard Fire Department and, more recently, the Transylvania Local Emergency Planning Committee. This facility pledges to operate in a manner that is safe for our workers, the public, and the environment. As part of this commitment, the Ecusta facility has established a system to help insure safe operation of the processes at this facility. One component of this system is a Risk Management Program that helps manage the risks in our chlorine use areas and that comply with the requirements of EPAs 40 CFR 68 "Accidental Release Prevention Require ments: Risk Management Programs" and OSHAs 29 CFR 1910.119 "Process Safety Management of Highly Hazardous Chemicals." A. Accidental Release Prevention and Emergency Response Policies The Ecusta facility is committed to the safety of our workers and the public, and to the preservation of the environment through the prevention of accidental releases of hazardous substances. The P. H. Glatfelter Company implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of an accidental release, the P. H. Glatfelter Company controls and contains the release in a manner that will be safe for workers and will help prevent injury to the public or the environment. B. Ecusta Facility and Regulated Substances The Ecusta facility is both a non-integrated paper mill producing fine papers from purchased bleached pulp as well as an integrated paper mill for producing specialty papers from non-wood materials. The latter is beached in either a chlorine based p rocess or in a totally chlorine free (TCF) process. This facility handles only one substance regulated by RMP rule in sufficient quantities to be covered. As a result of the use of this regulated substance, the following three processes are covered by the RMP Program Regulated Process Quantity Process Level Substance (Pounds) Chlorine Tank Car 3 Chlorine 180,000 Unloading OSMR Chlorine Storage 3 Chlorine 6,750 Area Water Treatment Plant 3 Chlorine 13,650 C. Off-Site Consequence Analysis The RM P rule requires that an off-site consequence analysis be conducted for a worst-case and alternate release scenario for the toxic substance chlorine. The worst-case release scenario for chlorine is a failure of a 180,000-pound railroad tank car of chlorine at the chlorine railcar unloading area. The maximum distance to the toxic end point concentration is 21.6 miles. The residential population in this area is approximately 180,000 people and includes schools, residences, hospitals, prisons, recreation areas, and industrial areas. It would also include national or state parks, forests or monuments, wildlife sanctuaries, and federal wilderness areas. Although required by regulation, the worst case scenario is a scenario that will probably never happen. The Company has been in contact with the Chlorine Institute. According to their records, there has never been a catastrophic failure of a railcar at a user site or even at a producer's site. The alternate release scenario for chlorine is a failure of the vaporizer gasket adjacent to the chlorine tank car unloading area. This scenario assumes that 20 pounds/minute of chlorine is released through a hole for thirty minutes before workers detect the release and isolate the vaporizer. The maximum distance to the toxic end point is 0.19 mile. Several houses are located within this distance with a total population of less than 140 people. No environmental receptors are within this distance. D. Accidental Release Prevention Program and Chemical Specific Prevention Steps The RMP rule requires a Program 3 prevention program for the chlorine tank car loading area, the chlorine storage area in the Old Side Machine Room, and the Water Treatment Plant. The prevention program is summarized in Chapter 18 "Prevention Program" of Volume 2 of the Process Safety Management Manual. Full details are given in the following chapters of Volume 1 of the Process Safety Management Manual: PROCESS S AFETY MANAGEMENT Program 3 Item Chapter Title Hazard Review 3 Process Hazard Analysis Operating Procedures 4 Operating Procedures Training 5 Training Maintenance 8 Mechanical Integrity Incident Investigation 11 Incident Investigation Compliance Audit 13 Compliance With Safety Audits Management Of Change 10 Management Of Change Pre-Startup Review 7 Pre-Startup Safety Review Contractors 6 Contractors Employee Participation 1 Employee Participation Hot Work Permit 9 Hot Work Permit Industry standards are followed at the Ec usta facility to help insure the safe handling of chlorine. The chlorine vendor supplies chlorine in a U. S. Department of Transportation approved railroad tank car. This railroad tank car is then used as an on-site supply for chlorine in the process. All piping, valves, vaporizers, etc. are consistent with the Chlorine Institute standards. Workers who perform operations involving chlorine receive training emphasizing industry accepted handling procedures that are consistent with the Chlorine Institute and OSHAs guidelines. E. Five-year Accident History The Ecusta facility maintains a five-year accident history that fulfills the requirements of the RMP rule. No releases of regulated substances have occurred from any of the chlorine areas in the last five years that have resulted in consequences of interest (such as, deaths, injuries, or significant property damage on-site; or known deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off site). F. Emergency Response Programs The Ecusta facility has established a written emergency response plan that complies with the RMP rule and with other federal contingency plan regulations. The plan is described in detail in Chapter 12 of Volume 1 of the Process Safety Management Manual. This plan has been communicated to local emergency response officials through the local Emergency Planning Committee. Notifications have been made to all counties in North Carolina and South Carolina that may be affected under the worst-case modeling scenario. Regular dialogue is maintained between Ecusta and the local Emergency Planning Committee, the local fire department, and the local rescue squad. Periodically, tours of the facility with representatives from these organizations are conducted emphasizing areas in which hazardous or toxic chemicals are stored or used. G. Planned Changes To Improve Safety The Ecusta Division of P. H. Glatfelter Company constantly strives to improve the sa fety of the processes through both the Incident Investigation Program and a program to reduce chlorine usage. The following changes to improve process safety are planned or being seriously considered: 1. Replacing the biocide, chlorine dioxide, that is being used on the Old Side paper machines with a non-chlorine base material. This would substantially reduce or eliminate the Old Side Machine Room, OSMR, chlorine storage area. 2. Various alternative bleaching sequences that will reduce or eliminate the use of chlorine in the pulp mill area are being investigated. This could substantially reduce the area impacted under a worst-case scenario. |