Blandin Paper Company - Executive Summary

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Blandin Paper Company (BPC) is committed to operating in a manner that is safe for BPC  
workers, the public, and the environment.  As part of this commitment, BPC has established a  
system to help ensure safe operation of the processes at this facility.  One component of this  
system is a risk management program (RMP) that helps manage the risks at BPC and that  
complies with the requirements of the Environmental Protection Agency (EPA) regulation 40  
CFR part 68, Accidental Release Prevention Requirements:  Risk Management Programs (the  
RMP rule).  One of the requirements of the RMP rule is to submit a risk management plan  
(RMPlan) describing the risk management program at BPC.  This document is intended to  
satisfy the RMPlan requirement of the RMP rule ('68.150 through '68.185) and to provide the  
public with a description of the risk management program at BPC. 
1.1    Accidental Release Prevention and Emergency Response Policies 
BPC is committed to the safet 
y of BPC workers and the public, and to the preservation of the  
environment, through the prevention of accidental releases of hazardous substances.  BPC will  
implement reasonable controls to contain releases in a manner that will be safe for workers and  
will help prevent injury to the public or the environment. 
1.2    The Stationary Source and Regulated Substances 
BPC is a paper mill with bleaching operations.  The facility handles one substance in a  
sufficient quantity to be regulated by the RMP rule covered.  The regulated substance is sulfur  
dioxide gas.  Liquefied compressed sulfur dioxide gas is stored for use as a pH adjuster in the  
pulp process. 
The storage delivery system contains up to 160,000 pounds of sulfur dioxide. 
1.3 Offsite Consequence Analyses 
The RMP rule requires BPC to perform an offsite consequence analysis for the following  
One worst-case release scenario for sulfur dioxide delivery system. 
One alternative release scenario for sulfur dioxide 
delivery system. 
The worst-case release scenario for sulfur dioxide gas is failure of the 16,000-gallon sulfur  
dioxide (SO2) storage tank, which is used in the pulp production process.  Administrative  
controls limit the quantity of sulfur dioxide in the tank to 13,900 gallons or 160,000 pounds.   
A cement dike would contain the released (SO2), which would boil if the ambient air  
temperature were above 14 0F, forming a dense gas cloud.  The maximum distance to the toxic  
endpoint concentration is 13 miles.  The City of Grand Rapids and surrounding communities  
within southern Itasca County could be effected by a worst-case release of SO2.  The estimated  
population within a 13-mile radius of the storage tank is 20800 people.  
The alternative release scenario for sulfur dioxide gas is rupture of a 1-inch diameter liquid  
line from the SO2 storage tank.  This scenario assumes that the sulfur dioxide is released  
through the ruptured pipe for 60 minutes before workers are able to iso 
late the line.  The  
released SO2 would rapidly boil if ambient air temperatures were above 14 0F, forming a dense  
gas cloud.  The maximum distance to the toxic endpoint is 0.8 miles.  The downtown district  
of the City of Grand Rapids is located within this radius.  The estimated residential population  
within a 0.8-mile radius of the storage tank is 2260 persons.   
1.4    Accidental Release Prevention Program and Chemical-specific  
Prevention Steps 
The RMP rule requires a Program 3 prevention program for the sulfur dioxide system.  The  
following paragraphs describe the prevention program elements at BPC that apply to this  
Safety information.  BPC maintains a variety of technical documents that are used to help  
ensure safe operation of the BPC processes.  Material safety data sheets (MSDSs) document  
the physical properties of hazardous substances handled at BPC, including regulated substances  
in covered processes.  The engineering design documents include the operatin 
g parameters, the  
design basis and configuration of the equipment in each covered process, and references to  
applicable codes and standards. 
Hazard review.  BPC performs and periodically updates hazard reviews of the covered  
processes to help identify and control process hazards.  Checklists are used to guide the hazard  
review.  These checklists include items to help ensure that BPC operates and maintains the  
equipment in a manner consistent with the applicable design specifications, codes, standards,  
and regulations. 
Operating procedures.  BPC develops and maintains operating procedures to define how tasks  
related to process operations should be performed.  The operating procedures are used to (1)  
train employees and contractors and (2) serve as reference guides for appropriate actions to  
take during both normal operations and process upsets. 
Training.  BPC trains personnel in the operating procedures to help ensure safe and effective  
performance of their assigned tasks.  
A training documentation file is maintained to help ensure  
that refresher training is provided, as necessary. 
Maintenance.  BPC properly maintains the process equipment.  The BPC maintenance  
program includes (1) procedures to safely guide workers in their maintenance tasks, (2) worker  
training in the maintenance procedures, and (3) an inspection and testing program to help  
identify equipment deterioration and damage before equipment failure occurs. 
Compliance audits.  This document is the first report for the BPC Risk Management  
Program.  Future compliance audits will be conducted at three year intervals in accordance  
with Part 68.79 of the Risk Management Program Rule.   
Incident investigations.  BPC investigates all incidents that could reasonably have resulted in  
a serious injury to personnel, the public, or the environment.  BPC trains employees to identify  
and report any incident requiring investigation.  An investigation team is assembled, and the  
investigation is i 
nitiated within 48 hours of the incident.  The results of the investigation are  
documented, recommendations are made, and appropriate process enhancements are  
Chemical-specific prevention steps  sulfur dioxide.  Industry standards are followed at BPC  
to ensure safe handling of SO2.  The SO2 vendor supplies SO2 via a Department of  
Transportation (DOT)-approved tank truck and follows DOT standards and BPC Operating  
Procedures when loading the SO2 storage tank.  The storage tank design and construction are  
consistent with American National Standards Institute (ANSI) standards.  Workers who  
perform operations involving SO2 receive training emphasizing safe handling procedures for  
SO2 developed by BPC.   
1.5    Five-Year Accident History 
BPC maintains a five-year accident history that fulfills the requirements of the RMP rule  
('68.42).  This history indicates a good record of accidental release prevention over the past  
five years.  Two minor releases of SO2 have occ 
urred from BPC in the last five years that have  
resulted in consequences of interest. 
On February 9, 1996 a 1/8-inch line between the SO2 tank fill line and a signal transmitter  
was removed for maintenance purposes allowing the release of approximately 10-pounds of  
SO2.  A BPC employee was treated for respiratory distress at Itasca Medical Center and  
released that same day.  No other consequences of interest, either on-site or off-site, were  
generated by this incident.   
On November 18, 1997 a malfunctioning pH probe led to the release of an undetermined  
amount of SO2 into a bleach tank.  Two BPC workers, working in the area at the time,  
were exposed to SO2 levels of 17 parts per million or higher.  The workers were sent to the  
Itasca Medical Center for evaluation and released that same day. No other consequences of  
interest, either on-site or off-site, were generated by this incident. 
1.6    Emergency Response Programs 
BPC has established a written emergency response plan t 
hat complies with the RMP rule and  
with other federal contingency plan regulations.  This plan has been communicated to local  
emergency response officials through the local fire department.  Regular dialogue is maintained  
between BPC and the local fire chief.  BPC periodically conducts emergency response drills,  
including annual exercises. 
1.7    Planned Changes to Improve Safety 
BPC constantly strives to improve the safety of the processes at BPC through both the incident  
investigation program and a program soliciting safety suggestions from the workers.  The  
following changes to improve process safety have been implemented as a result of the February  
9, 1996 SO2 release:   
BPC has provided a second means of escape from the sulfur dioxide storage tank area.  A  
second stairway to the south of the tank has been installed. 
A check valve has been installed in the fill line and ball valves have been added to the  
pressure switches. 
Walkways have been installed over the storage ta 
nk to allow workers to close the hand  
valves prior to working on the rupture disc mechanisms. 
Hand valves on the storage tank are shut before work is performed on the rupture disc or  
alarm transmitters. 
A sign has been installed on the SO2 storage system which requires that the PGW shift  
coordinator be notified prior to any work being performed on the SO2 system.  The sign  
also directs workers performing maintenance on the rupture disc to shut the hand valve on  
the tank before working on the disc or the transmitter.  The sign directs all individuals  
working on the system to assume that the worst-case scenario is in order.   
The following changes to improve process safety have been implemented as a result of the  
November 18, 1997 SO2 release:   
The high output alarm setting for the SO2 valve was reduced, and is checked on a regular  
A SO2 sensor for the pulp storage tank facility has been installed.
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