Willamette Industries, Inc., Marlboro Mill - Executive Summary
Executive Summary |
RMP program for Willamette Industries, Inc.
Marlboro Paper Mill, Marlboro County, S.C.
1.0 Facility Background
Willamette Industries, Inc. owns and operates a fully integrated pulp and paper mill located in Marlboro County along the Great Pee Dee River about five miles west of Bennettsville, SC. The location of the mill is in a rural, agricultural setting with a low population density in the vicinity of the mill. The topography of the surrounding countryside is generally flat. The largest nearby town or city is Bennettsville, SC located five miles east of the mill. Bennettsville has a population of about 10,000.
The mill employs both technically advanced processes as well as a non-traditional, highly educated, non-union work system. In most ways, the mill is considered to be state of the art. The mill produces grades of hardwood and softwood market pulps as well as various grades of printing, copier, and writing papers.
2.0 Accidental Release Preventi
on and Emergency Response Policies
Willamette is committed to the safety of Willamette employees and the general public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. Willamette implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of an accidental release, Willamette controls and contains, to the extent possible, the release in a manner that will be safe for employees and will help prevent injury to the public or the environment. In addition, Willamette will investigate incidents soon after they occur to determine the root cause(s) for the incident and develop plans to ensure that the incident does not occur again.
3.0 RMP Applicability
Willamette Industries' "Marlboro" pulp and paper mill incorporates four processes which contain or use chemicals to a stored volume that causes those processes to be covered under the RMP program, 40 cfr 68 (and OSHA's PSM program
as well). The four processes include a Lurgi R-6 process which manufactures chlorine dioxide (ClO2), a Sterling R-10 process which also manufactures ClO2, a chlorine (Cl2) railcar unloading and distribution system, and a raw water Cl2 treatment process. The Lurgi R-6, Sterling R-10, and Cl2 railcar unloading systems all support the bleaching operations of the pulp mill, while the raw water treatment process serves to disinfect incoming river water from the Great Pee Dee River. The following table serves to summarize the covered processes in use at Willamette's Marlboro Paper Mill.
Process Program Level Regulated Substance Process Qty RMP TQ
Lurgi R-10 3 Chlorine Dioxide 4,970 lbs. 1,000 lbs.
Sterling R-10 3 Chlorine Dioxide 11,684 lbs. 1,000 lbs.
3 Chlorine 180,000 lbs. 2,500 lbs.
Raw Water 3 Chlorine 16,000 lbs. 2,500 lbs.
4.0 Overview of Covered Processes and Off-Site Consequence Analyses
This section exams the four RMP covered processes and provides details on each specific process, a review of worst case release scenarios for each and a review of more probable alternate release scenarios for each. The off site impact areas have been determined by using the EPA approved DEGADIS dense gas air dispersion model.
4.1.1 Lurgi ClO2 Process
The mill employs a Lurgi ClO2 process to manufacture part of the ClO2 required for bleaching pulp in the Bleach Plant. The Lurgi process uses three subsystems to accomplish the task of ClO2 manufacture. The three process are the chlorate electrolysis process, HCl synthesis, and ClO2 generat
ion. The product of the three processes is ClO2, although none of the three processes in itself contains ClO2 over the threshold quantity listed in RMP regulations. ClO2 is stored in two large storage tanks which results in this process being included in RMP. It is important and significant to note, however, that in addition to the storage tanks, the entire Lurgi process is covered in the process hazard analysis (PHA). Willamette did not differentiate between the process and the storage tanks with regard to ClO2. This position is a very conservative position with respect to RMP applicability. In addition, the entire Lurgi process is included in all aspects of the mill's RMP/PSM prevention program. The solution manufactured by the Lurgi process contains 0.085% pure ClO2.
4.1.2 Lurgi R-6 Worst Case Scenario
The worst case Lurgi incident is the rupture of one 70,000 gallon ClO2 storage tank. In this case the liquid ClO2 would pool then vaporize creating a toxic gas cloud. T
he gas cloud is modeled to travel to a location 4.66 miles before reaching the EPA defined concentration endpoint. In this event and depending upon wind direction and speed, the town of Bennettsville could be impacted. Otherwise, impact upon the general public would be minimal since the population density around the mill is very low.
4.1.3 Lurgi R-6 Alternate Release Scenario
The most probable incident that creates the alternate release scenario is the liquid spill and vaporization of ClO2 from a pipe leak or rupture. In this case, the full pipe contents in 1000 ft of 6" pipe would leak out of the pipe. This scenario would create a release of about 104 lbs. of toxic gas and would effect an area up to 1.93 miles from the mill. In this case, the impact upon the general public would be minimal since there are very few persons who live this close to the mill. No cities, towns, or other public receptors would be impacted.
4.2.1 Sterling R-10 ClO2 Process
The Sterling process pro
duces ClO2 liquid from a closed recirculating reactor. In this case, sodium chlorate and sulfuric acid are added together in a closed dynamic reactor to produce ClO2 gas. Methanol is also added to the reactor to serve as a catalyst. ClO2 gas is drawn off the top of the reactor and routed to a chilled water absorption column where the chilled water strips the ClO2 out of the gas stream to form liquid ClO2, which is 0.01% pure ClO2. This process was installed in 1998 and was subjected to pre-start up safety reviews as well as a pre-start up PHA. Like the Lurgi ClO2 process, ClO2 is a product of the system and is stored in two 140,000 gallon tanks. The entire Sterling process, though, was subjected to the safety reviews and PHA and is currently subjected to all facets of RMP/PSM programs.
4.2.2 Sterling R-10 Worst Case Release Scenario
Like the Lurgi process, the worst case release scenario fro the Sterling R-10 process would be the rupture of one of the ClO2 storage tanks. In t
his case, a 140,000 gallon tank would rutprue spilling its entire contents. In this case, the liquid would pool then vaporize resulting in a toxic gas cloud. The gas cloud would impact an area within 6.09 miles from the mill. Within this boundary and depending upon wind direction, the gas cloud could impact the City of Bennettsville. Bennettsvile would be the only municipality impacted. Public receptors in Bennettsville include Marlboro County High School as well as middle and elementary schools, Marlboro Park Hospital, nursing homes, and all Marlboro County governmental agencies.
4.2.3 Sterling R-10 Alternate Release Scenario
The most probable alternate release scenario for the Sterling process is a pipe leak where the entire contents of a 1000 ft, 6" pipe are leaked to the ground. In this case, 123 lbs. of toxic gas would be formed from the vaporizing pool. This gas cloud would impact an area up to 2.05 miles from the mill. In this case, the impact upon the general publ
ic would be minimal since the population density within 2 miles of the mill is very small. No cities or towns would be affected by this release scenario.
4.3.1 Chlorine (Cl2) Railcar unloading and Distribution System
The Marlboro Mill receives chlorine in 90 ton railcars for use in the process. Elemental chlorine is used as a make up chemical in the Lurgi ClO2 process and as a bleaching agent in the mill's pulp bleaching operations. While the use of chlorine is anticipated to significantly decrease due to process changes, the receipt of 90 ton chorine railcars is not expected to end. This system includes 90 ton railcars, two steam vaporizers, and associated distribution piping. This system is covered under both RMP and PSM.
4.3.2 Chlorine Railcar Worst Case Release Scenario
The worst case release scenario for the railcar unloading and distribution system is a catastrophic failure of a 90 ton railcar. This release scenario is also the worst case scenario for the entire mill.
In this event, the entire contents is assumed to vaporize and form a toxic gas cloud. The total maximum released quantity would be 180,000 lbs. and would impact an area from the mill up to 9.20 miles. Again, depending upon wind direction and speed, this event could impact the city of Bennettsville as well as the Towns of Cheraw and Society Hill. Public receptors identified in Bennettsville were previously listed in section 4.2.2. Public receptors in Cheraw include Chesterfield County Hospital as well as Cheraw High School and the numerous elementary and middle schools, various nursing homes, and the municipal government offices of Cheraw. The Town of Cheraw is located about 8.5 miles WNW of the mill. In Society Hill, the public receptors would include an elementary school and municipal offices. Society Hill is located about 8 miles SW of the mill.
4.3.3 Chlorine Railcar Alternate Release Scenario
The alternate release scenario for the railcar unloading and distribution s
ystem is a transfer hose break which would result in a release of 7,500 lbs. of chlorine toxic gas. In this event, the gas cloud could impact an area up to 1.99 miles from the mill. Like most of the release scenarios, the impact to the general public would be minimal due to the low population density in the vicinity of the mill.
4.4.1 Chlorine Raw Water Treatment
Raw River Water is pumped from the Great Pee Dee River through a treatment system for use as process water in the mill. Part of the treatment system includes disinfection of the river water through the use of gaseous chlorine. In this system, eight one-ton chlorine cylinders are used to provide chlorine for disinfection. The eight cylinders are divided into two groups of four such that at least four cylinders are connected together and are on-line at any time. The eight one-ton cylinders are housed in their own building which provides shelter from weather elements.
4.4.2 Chlorine Raw Water Treatment Worst Case Rele
The worst case release scenario associated with this system would be the complete failure of a one ton chlorine cylinder. In this case, 2,000 lbs. of chlorine gas would be released and could impact an area up to 1.93 miles from the mill. Like most other scenarios, the impact upon the general public would be minimal due to the low population density present.
4.4.3 Chlorine Raw Water Treatment Alternate Release Scenario
The alternate release scenario would be the rupture of transfer tubing and would result in the release of 2,000 lbs. of chlorine gas. This scenario is the release of all the contents of one one-ton cylinder, but in a longer period of time than the worst case release scenario. This release could impact an area up to 1.43 miles from the mill, but the impact to the general public would be minimal due to the low population density present.
5.0 General Accidental Release Prevention Program
Willamette's Marlboro Mill takes a proactive view of preventing
incidents related to releases of hazardous chemicals. We value OSHA's PSM program and EPA's RMP program on the same level and in many cases combine into one effort those prevention activites which overlap. The key elements of our prevention program include:
* Process Safety Information
* Process Hazard Analysis
* Standard Operating Procedures
* Training Programs
* Mechanical Integrity Programs
* Management of Change Procedures
* Pre-Startup Safety Reviews
* Compliance Audits
* Incident Investigations
* Employee Participation
* Hot Work Permitting
* Management of Contractors within RMP systems
The Marlboro Mill developed an internal mill policy manual for the implementation of prevention items listed above for both RMP and PSM. The policy manual is reviewed and revised as necessary to ensure that the mill complies with both rules.
5.1 Process Safety Information
Process Safety Information consists of many different types of information related to hazardous chemicals and the proc
esses that contain them. Types of information that are available to all employees and contractors include MSDSs, Chemical Control Information, PSM/RMP files, Engineering files, process specific safety information, and Willamette Engineering standards.
MSDSs are available in hard copy in all control rooms and maintenance shops in the mill and are also located locally in Bennettsville at the Fire Department, LEPC, Hospital, and local company Doctor. MSDSs are updated periodically. The master MSDS files are kept in the Technical Servics Department. In addition, information from MSDSs is entered in a chemical control spreadsheet where all pertinent safety, hazard, and disposal information is kept. The chemical control information is located in the Technical Services Department. Special designated PSM/RMP files have been established to house all relevant information regarding PSM/RMP. This includes all documentaion regarding incident investigations, PHA's, MOC's, PSI, and all ot
her prevention areas. Engineering files are updated as projects are implemented or changes made to the process. All engineering files and vendor equipment files and information is located in a central mill engineering library. The library is accessible by all mill personnel. In addition, Willamette has implemented corporate engineering standards to be used during the design phase of projects.
5.2 Process Hazard Analysis (PHA)
PHAs are conducted on all covered RMP/PSM processes at least every five years. All covered systems in the mill have had at least one PHA completed. The Hazard and Operability (HazOp) technique is used to complete the PHA. The teams which comprise PHA teams meet the requirements of PSM/RMP both in terms of quality and quantity of personnel. PHAs are filed in the mill PSM/RMP file system.
5.3 Standard Operating Procedures
The mill has implemented SOPs in every operating area, including the four RMP covered processes. In every way, SOPs are a part of t
he Marlboro Mill culture and not just part of RMP. SOPs consider the correct operating procedures and techniques for equipment and processes, consider safety risks and precautions, include job safety analyses (JSAs), establish normal operating ranges and targets, incorporate start up and shut down procedures, and are established for maintenance activities. SOPs are routinely updated through the Technician review process. This frequent review results in SOP continual improvement. Knowledge and demonstration of skills required by SOPs is a part of a Technician's promotion process. Many SOPs consider safe work practices such as fall protection, hot work permit requirements, confined space entry requirements, lock out/ tag out procedures, and hole watch responsibilities.
All new Marlboro Mill employees go through PSM/RMP training as part of their new employee training process. In addition, all Marlboro Mill employees have refresher training at least every three ye
ars for RMP and PSM systems. In the PSM/RMP affected processes, employee training can occur on an annual basis. In addition, training for all affected teams occurs after an incident investigation is completed in their business unit. The objective is to ensure that all teams receive and understand the outcome of the incident investigation. All training events are documented and filed with the mill's training coordinator who then archives all training activities. In addition, written tests are generally given for the annual and every three year training events. This ensures employees retain information presented during the training sessions.
5.5 Mechanical Integrity
The Marlboro Mill uses a computer based maintenance system, called MapCon, to manage maintenance and mechanical integrity activities. All response maintenance work orders as well as preventive maintenance inspection work orders are entered through MapCon. In addition, after the work order is completed, the results
of the work, particularly for PM inspections, can be stored in the MapCon system. This allows for a good mechanical integrity history to be compiled for all equipemnt. In addition, the MapCon system is able to rate the priority of work requests by the priority rating which has been assigned to each process. By using this system, all PSM/RMP covered processes receive the highest rating allowing prompt response to mechanical and maintenance issues as they arise. Last, the MapCon system is able to generate inspection work orders for covered processes based on frequency originally inputted into MapCon. This allows for vendor required routine inspections to take place on the prescribed frequency.
5.6 Management of Change (MOC)
The Marlboro Mill has implemented an MOC system for all covered processes such that any proposed change or modification to a covered process must first be reviewed for process safety considerations. A team comprised of operating, engineering, maintenance, and
process control personnel meet periodically to review MOC requests. Changes to the process can only occur after the MOC team approves the request. All MOC requests are documented and filed in the RMP/PSM file system. In addition, any PSI or engineering documentation change required because of an approved MOC are noted on the MOC form for follow up.
5.7 Pre-Startup Safety Reviews (PSSR)
PSSRs are conducted for any startup of projects that occur within the boundary of a covered process or after a major maintenance outage. The PSSR is conducted by operating, maintenance, engineering, and process controls personnel to ensure that all systems are verified safe prior to starting up. PSSR forms are used to facilitate the PSSR as well as document the PSSR. PSSR will verify that the physical system is as engineering drawings indicate, that valving and physical controls are set according to SOPs, and that process controls are operating per the design.
5.8 Compliance Audits
ompliance audits are conducted on an every three year basis per the requirements of PSM and RMP. These audits are third party audits and are used to uncover and correct program deficiencies. The last third party audit was conducted in 1997. Recommendations stemming from the audit were categorized, prioritized, and assigned to individuals to complete. A task group of technical support personnel met monthly tracking the status of work against audit recommendations until all recommendations were completed. The next third party audit will be held in 2000. In addition, internal audits are conducted on a frequent basis to uncover soft spots in the program. The same task group continues to meet on at least a semi-monthly basis to review implementation of the PSM/RMP program.
5.9 Incident Investigation
After each incident or near miss in a covered process, a formal incident investigation will occur. The incident investigation uses a team approach where a technical facilitator (the
Tech Services Manager) will facilitate a group of persons investigating the incident. The group will always include operating technicians and managers associated with the incident, process controls personnel, process and project engineers, and maintenance personnel.
The investigation objective is to identify incident root cause(s) as well as surface causes and to develop a list of recommendations designed to prevent reccurrence. The list of recommendations is presented to mill management for reconciliation. In addition, the investigation and results are shared with each operating team in the affected business unit (training) with the meeting being documented.
5.10 Employee Participation
Active employee participation is essential to the success of the RMP program. Employee participation minimizes the consequences of releases of toxic, reactive, flammable, or explosive chemicals. Communication is encouraged between and among all levels of the organization. To promote and i
ncorporate safety as a part of our business culture, at a minimum, monthly safety meetings are required for all mill employees. These safety meetings are documented for each employee. In adddition, the mill has implemented a central safety committee with millwide representation to set goals for safety performance as well as implement safety initiatives. Next, each mill business unit has its own safety committee which develops safety goals and expectations for that business unit. The business unit's safety goals support the mill's goals while tailored to meet specific department needs. In addition, daily safety meetings and discussions are held within each operating and support team in the mill on a daily basis. Millwide goals and safety results are communicated on a broad and frequent basis ensuring that all employees are aware of mill and department safety results.
5.11 Hot Work Permits
The mill has in place a hot work permit system for all cutting and welding acitivities
within the mill, including the four RMP covered processes. Hot work permit refresher training occurs on an annual basis for all mill and contractor personnel.
Contractors are an integral part of our business success. As such, contractors are included in all general mill safety training and safe practices as well as specific PSM/RMP safety training when working in or around PSM/RMP processes. All contractor safety training is documented and filed. As with Willamette employees, on-site contractors are required to have monthly safety training programs in place and implemented.
5.13 Prevention Program Summary
The individual elements of our prevention program work together to prevent accidental chemical releases. Marlboro Mill employees are committed to the standard that these management systems set and incorporate these standards as part our the mill work culture. To ensure compliance, specific accountability and responsibilities have been established to
ensure that the prevention program is implemented in a quality manner.
6.0 Five Year Accident History
The Marlboro Mill investigates all incidents and significant near misses associated with covered PSM/RMP systems. The investigations are documented and filed in the PSM/RMP files.
During the last five years, the Marlboro Mill has had five incidents in which either a reportable quantity of toxic chemical was released or injuries occurred. Of the five incidents, four were associated with the Lurgi ClO2 process and one was associated with the chlorine railcar unloading and distribution system.
6.1 Lurgi ClO2 Release
On May 6, 1995, a process ClO2 tank, the ClO2 pump tank, ruptured spilling a mixture containing 193 lbs. of ClO2 and 41 lbs. of chlorine (Cl2). The tank rupture occurred as a result of a hydrogen and ClO2 reaction resulting in an over pressure situation and ultimately the rupture of the tank. The excess hydrogren present in the pump tank resulted from a back press
ure situation where the overflow line from a hydrogen safety seal tank was partially plugged by a personal escape respirator. The plugged line caused hydrogen to collect in the vapor space of the ClO2 pump tank since hydrogen was backing through a hydrogen cooler condensate drain and into the pump tank. ClO2 is explosive in the presence of hydrogen. No on-site or off-site injuries were reported, nor were any reports of off-site consequences received.
An RMP required incident investigation was begun on May 8 and concluded on May 9. A list of 16 recommendations was developed and forwarded to mill management for consideration.
6.2 Lurgi Incident, August 21, 1997
On August 21, 1997, a process tank associated with the ClO2 process, the electrolyte tank, ruptured resulting in the release of 540 lbs. of ClO2 and 85 lbs.of chlorine. The rupture was caused by contamination of the electrolyte tank as well as acid addition to the tank for pH control. The acid addition and contamination
caused a ClO2 decomposition in the presence of a higher than normal oxygen content. One mill technician required oxygen after being exposed to high concentration levels of ClO2 and Cl2 present in the Lurgi building. No off-site injuries or consequences were reported.
An RMP required incident investigation was conducted on August 22 and revised on September 5, 1997. A list of 31 recommendations was developed and forwarded to mill management for consideration.
6.3 Lurgi Incident, October 30, 1997
On October 30, 1997, the Lurgi waste gas scrubber plugged causing a back pressure situation in the corrosive vent system and resulted in the venting of 46 lbs. of chlorine and ClO2 through several tank pressure relief vents. While chlorine is not stored in the Lurgi process in a quantity that exceeds RMP threshold quantities, all incidents involving first aid or personnel injury are included in the RMP executive summary since the general Lurgi process is a listed RMP/PSM process. The
scrubber, which uses caustic as the neutralizing media plugged sufficiently that the inlet corrosive vent line filled with caustic and caused the chlorine back pressure situation in several process vessels. One mill employee and one contract employee were exposed to the chlorine gas and required first aid (oxygen). No off-site injuries or consequences were reported.
A PSM level incident investigation was conducted on October 31. A list of 12 recommendations was developed and forwarded to mill management for consideration.
6.4 Lurgi Incident, May 14, 1998
On May14, 1998, an undetermined amount of ClO2 gas was released momentarily from the Lurgi waste gas scrubber. The amount was thought to be less than 50 lbs. A 250 amp breaker located in the emergency power circuitry failed causing a short shutdown of the Lurgi process. In this situation some pieces of equipment are switched to emergency power, but not all equipment is tied to emergency power. During the short shutdown, t
he caustic recirculation pump was shut down since it was not on emergency power. This caused ClO2 to be pulled through the scrubber without conditioning and emitted as ClO2. One contractor working in an adjacent proces was exposed to the ClO2 gas requiring minor first aid treatment (oxygen). Three recommendations were identified as a result of the incident investigation. No off-site injuries or consequences were reported.
6.5 Chlorine Railcar Unloading System Incident, January 6, 1999
On January 6, 1999, 220 lbs. of chlorine was released from a vaporizer instrument fitting during a weather related event (freezing conditions). In this system, chlorine vaporizers are used to vaporize liquid chlorine pulled from the adjacent chlorine railcars. On the night of January 6, steam flow to the vaporizers was lost when the mill boilers were tripped off-line due to weather related issues. As a result, liquid chlorine level in the vaporizers contined to build to a high level. In additio
n, when steam was lost, condensate, which had formed in the steam line, froze creating a pipe plug. Once steam was restored and after a period of time, steam melted the plug and rushed into the vaporizer vaporizing the high liquid level and creating an over pressure situation. High chlorine pressure caused a rupture disc to fail and for chlorine to be routed to the process safety system. However, one of the rupture disc holders contained a drilled instrument tap, which had not been plugged by the manufacturer. The open 0.25" tap allowed chlorine to escape. One contract person working in the vicinity was exposed to the chlorine gas requiring minor first aid treatment (oxygen). No off-site injuries or consequences were reported.
An RMP/PSM incident investigation was conducted on January 7. A list of nine recommendations was forwarded to mill management for consideration.
7.0 Emergency Response Plan
The Marlboro Mill incorporates a comprehensive emergency response plan into its
every day operations. The Emergency Response Plan contains 19 sections and includes the following specific emergency response procedures:
* Responsibilites and procedures for the mill's Emergency Response Team (ERT)
* Employee Protection and Evacuation
* Medical Emergency Response
* Fire Emergency Response
* Chemical Release Response
* Severe Weather Response
* Utilities Outages Response
* Emergency Shutdown Procedures
* Explosion Response
* Bomb Threat Procedures
* Flood Response
* Earth Quake Response
* Radiological Response
All mill employees and on-site contractors are required to attend annual refresher training on the mill's emergency response plan.
A key element of the mill's plan is the formation of the Emergency Response Team (ERT). Each shift team in the mill has an ERT so that at all times emergency response personnel are on site. The ERT team is trained in advanced emergencies such as fire fighting, advanced first aid response, chemical/hazardous spil
l response, and advanced rescue and recovery techniques. Each shift ERT has designated persons to serve as site and incident commanders. In addition, up to eight persons on each shift team can comprise the ERT.
In addition, the mill contract security force is required to have one Emergency Medical Technician (EMT) on site at all times.
Other items and systems available in the mill to help in emergency response include:
* Gaitronics phone system and department radios to aid in quick and effective communications.
* Personal protective equipment requirements such that all persons working in the mill, contractor or mill employee, are required to have hard hat, eye protection (with side shields), steel toed shoes, hearing protection, and an emergency escape respirator.
* Many local area audible process alarms to warn of process upsets.
* Process interlocks designed to minimize process upsets and increase personnel safety.
* Many personal safety devices, such as eyew
ash stations and safety showers available throughout the mill for emergency response.
8.0 Planned Changes to Improve Safety
The Marlboro Mill strives to improve safety performance by continual evaluation of mill process systems, and by motivation and management of mill employee and contractor behaviors. The Marlboro Mill continues to emphasize safety performance through short term goals, safety promotions, and the reconciliation of unsafe behaviors or actions.
While too numerous to list here, the mill prioritizes safety work orders ensuring that unsafe conditions discovered, are also resolved. In addition, the mill uses a "flash card" system such that any unsafe condition or behavior that is found or confronted, is documented and addressed relieving that specific concern. The flash card system's success is exhibited by it's use by all mill and contract employees.