Mead Coated Board - Executive Summary |
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Mead Corporation - Mahrt Coated Board Mill 1. EXECUTIVE SUMMARY The Mead Corporation -Mahrt Coated Board, Mahrt Mill is committed to operating in a manner that is safe for Mahrt workers, the public, and the environment. Employing over 700 people from the surrounding communities, Mead recognizes that it is a vital part of the community. It also recognizes its responsibility in informing the community of potential hazards associated with the processes at the Mahrt Mill. As part of this commitment, Mahrt has established a system to help ensure safe operation of the processes at this facility and in turn, reduce the risk to employee health, contractor health, community health and to the environment. Mead's Mahrt Mill risk reduction system includes a Process Safety Management system that complies with the requirements of the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.119. Another component of this system is a Risk Management Program (RMP) that h elps manage the risks at Mahrt and complies with the requirements of the Environmental Protection Agency's (EPA's) 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 Mahrt. This document is intended to satisfy the RMPlan requirements of the RMP rule and to provide the public with a description of the risk management program at Mahrt. 1.1 Accidental Release Prevention and Emergency Response Policies Mahrt is committed to the safety and health of Mahrt workers and the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. Mahrt implements reasonable controls such as operator training, preventive maintenance and safe operating procedures to prevent foreseeable releases of hazardous substances. Before using a hazardous substanc e at Mahrt mill, Mahrt considers using alternative substances that do not have the potential to adversely affect Mahrt workers, the public and the environment. In the event of a significant accidental release, Mahrt evacuates workers and contains the release to prevent and/or reduce the consequences of the release. 1.2 The Mead Corporation - Mahrt and Regulated Substances Mahrt is a paper mill without bleaching operations, producing coated unbleached Kraft paperboard, known as Coated Natural Kraft for use in multiple beverage packaging and folding cartons for food, pharmaceuticals and other products. Mahrt mill produces two grades of Coated Natural Kraft paperboard: Carrier Kote for Beverage packaging and Custom Kote for folding cartons. More than half of the mills total production is Carrier Kote. The covered process is defined as a regulated substance present in more than a threshold quantity as determined under 68.115 and includes any use, storage, manufacturing, handl ing, or the on-site movement of such substances, or combination of these activities. For purposes of this definition, any group of vessels that are interconnected, or separate vessels which are located such that a regulated substance could be involved in a potential release, shall be considered a single process. The facility handles one substance regulated by the RMP rule in sufficient quantities to be covered by the RMP rule: - Aqueous ammonia stored in the Color Plant area for use on the Paper Machines As a result of the use of regulated substances at Mahrt, the following process is covered by the RMP rule: Process - Aqueous Ammonia Program Level - 1 Regulated Substance - Ammonia (29 wt%) Process Quantity - 32,190 lbs 1.3 Off-site Consequence Analysis The RMP rule requires Mahrt Mill to perform an off-site consequence analysis for the following scenarios: - One worst case scenario for the toxic substance ammonia The purpose of the offsite consequenc e analysis is to determine the distance at which certain effects might occur to the public and environment in the event of an accidental release. The following information summarizes this off-site consequence analysis. 1.3.1 Aqueous ammonia Aqueous ammonia is a colorless liquid with a pungent odor. It is non flammable, mixes with water and contact should be avoided with the liquid and vapor. The worst case release scenario for toxic substances is failure of the 15,000-gal (32,190 lb.) aqueous ammonia (29 wt%) storage tank in the Rail car Unloading Area. A diked area contains the release aqueous ammonia, which evaporates, forming a vapor cloud. The maximum distance to the toxic endpoint concentration is 0.30 mile. No public or environmental receptors are located within this distance of storage tank. 1.4 Accidental Release Prevention Program and Chemical-specific Prevention Steps Mahrt maintains a number of programs to help prevent accidental releases and ensure safe o peration. The accident prevention programs in place at Mahrt include: Safety information. Mahrt maintains a variety of technical documents that are used to help maintain safe operation of the processes at Mahrt. Material safety data sheets (MSDSs) document the physical properties of hazardous substance handled at Mahrt, including the regulated substance in covered process. The information includes toxicity information, permissible exposure limits, physical data, reactivity data, corrosivity data, thermal and chemical stability data and the hazards of mixing substances in the process. The engineering design documents include the operating parameters, the design basis and configuration of the equipment in each covered process, and references to applicable codes and standards. Hazard Review. Mahrt performs and periodically updates hazard reviews of the covered process to help identify and control process hazards. Checklists are used to guide the hazard review. These ch ecklists include items to help ensure the Mahrt operates and maintains the equipment in a manner consistent with the applicable design specifications, codes, standards, and regulations. Operating Procedures. Mahrt 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. Mahrt 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. Mahrt properly maintains the process equipment. The Mahrt maintenance program includes (1) procedures to safely guide workers in their maintenance tasks, (2) worker training in the maintenance procedures, a nd (3) an inspections and testing program to help identify equipment deterioration and damage before the equipment fails. Compliance Audits. Mahrt performs periodic compliance audits of the covered process to verify that the process is operating in compliance with the requirements of the RMP rule. A compliance audit report is prepared after each audit, and any deficiencies noted by the audit are corrected in a timely manner. Incident investigations. Mahrt investigates all incidents that could reasonably resulted in a serious injury to personnel, the public, or the environment. Mahrt trains employees to identify and report any incident requiring investigation. An investigation team is assembled, and the investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendation is resolved, and appropriate process enhancements are implemented. Chemical-specific prevention steps-ammonia. Industry standards are followed at Mahrt to help ensure safe handling of aqueous ammonia. The ammonia vendor supplies aqueous ammonia via Department of Transportation (DOT)-approved tank truck and follows DOT standards when loading the aqueous ammonia storage tank. The storage tank design and construction are consistent with American National Standards Institute (ANSI) standards. Workers who perform operations involving ammonia receive training emphasizing safe handling procedures for ammonia developed by Mahrt. 1.5 Five-Year Accident History No releases of regulated substances have occurred from Mahrt in the last five years that have resulted in consequences of interest (i.e., death, injuries, or significant property damage on site; or known death, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off-site). 1.6 Emergency Response Program Mahrt Mills Emergency Response Program contains procedures for accidental releases and hazards associated at the Mahrt Mill. Mahrt fire brigade and hazmat team have been trained according to these procedures and will respond to fires and releases. 1.7 Planned Changes to Improve Safety Mahrt constantly strives to improve the safety of the process at Mahrt through both the incident investigation program and a program soliciting safety suggestions from the workers. 2. REGISTRATION SOURCE IDENTIFICATION: Name: Mead Coated Board Street: Hwy 165 South City: Cottonton County:Russell State: Alabama Zip: 36851 Latitude: 320 10 minutes 30 seconds Longitude: 850 1 minute 0 seconds EPA Facility ID: 1000 0012 4304 SOURCE DUN AND BRADSTREET NUMBER Corporate parent name: Mead Corporation Dun and Bradstreet number: 004231445 OWNER/OPERATOR Owner/Operator Name: Mead Coated Board Owner/Operator phone: 334-855-5290 Owner/Operator mailing address: P.O. Box 940 Phenix City, AL 36868 EMERGENCY CONTACT Emergency contact name: Boyd A. Giles Emergency contact title: Mill Emerge ncy Response Director Emergency contact phone: 334-855-5200 Emergency 24 hour phone: 334-855-5230 COVERED PROCESS Chemical name: Aqueous Ammonia CAS number: 7664-41-7 Quantity: 32,190 lb SIC code: 2631 Program Level: 1 EPA identifier: ALD041006297 No. of full time employees: 756 WORST CASE RELEASE SCENARIO Chemical name: Aqueous Ammonia Physical State: Liquid Results based on: Aloha model Scenario: Toxic Gas Release Quantity Released: 1311 lbs. Release Rate: 30.1 lbs/min Release duration: 43.6 min Wind speed: 1.5 m/sec Stability: F Topography: Rural Distance to endpoint: .30 miles Population within distance: NA Public receptors: NA Environmental Receptors: NA Passive Mitigation Considered: Diked wall already in place 3. OFFSITE CONSEQUENCE ANALYSIS EPA defines the worst case release inventory as the largest quantity in a single vessel or pipe, excluding flow from other connected equipment. A worst case release scenario must re sult in the greatest distance to the endpoint for the substance. AQUEOUS AMMONIA CAS NO. 7664-41-7 Vapor Pressure: 247mmHG @ 20-25 deg C WORSE CASE SCENARIO Given: Toxic gas release of 15,000 gal tank into a dike Tank volume(gal): 15,000 NH3 Concentration (%): .29 Solution Density (lb/gal): 7.40 Mass of NH3(lb): 32,190 Liquid Factor Ambient: .026 Wind Speed(m/s): 1.5 Height of Dike(ft): 2.5 Length of Dike(ft): 36 Diameter of Tank(ft): 12 Area of Dike(ft2): 844 Volume of Dike(cu ft)= dike area*dike hieght*7.48 gal/cu ft: 15,776 Percent capacity(%)= 105 Release rate= 30.09 Drain rate(gpm)= 344 Drain time(min)= 44 Total Amount Released(lb)=1311 Toxic Endpoint= .14 Release Rate/Toxic Endpoint= 215 Release Endpoint(miles)= .43 QR= Release rate (lb/min)via Trinity consultants calculations= 10.44 Distance to endpoint(miles)= .30 NO OFFSITE IMPACT NO FIVE YEAR ACCIDENT HISTORY - PROGRAM LEVEL 1 FIVE-YEAR ACCIDENT HISTORY No relea ses of the regulated substance has occurred from Mahrt in the last five years that have resulted in consequences of interest (i.e., death, injuries, or significant property damage on site; or known death, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off-site). 5. PROGRAM 2 PREVENTION PROGRAM 6. PROGRAM 3 PREVENTION PROGRAM 7. EMERGENCY RESPONSE PROGRAM Emergency Response Program is based upon Mead Coated Board's Emergency Response Plan "ERP2-prgm". |