Blandin Paper Company - Executive Summary |
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1.0 EXECUTIVE SUMMARY 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 scenarios: 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 system. 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 implemented. 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 basis. A SO2 sensor for the pulp storage tank facility has been installed. |