Great Northern Paper, Inc. - Executive Summary |
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RISK MANAGEMENT PLAN EXECUTIVE SUMMARY Facility and Regulated Substances The Millinocket mill of Great Northern Paper, Inc. manufactures coated and uncoated groundwood printing papers using groundwood and recycle pulp from a sister mill in East Millinocket, sulfite pulp manufactered on-site and kraft pulp purchased on the open market. Historically Great Northern has used two substances covered by the RMP Rule, chlorine as a disinfectant for incoming process water and aqua ammonia as a nutrient for wastewater treatment. By June 21, 1999, aqua ammonia will be replaced with urea. Chlorine is stored and used in the chlorine house adjacent to the process water filter house in one ton cylinders. Chlorine is delivered 12 cylinders at a time approximately every two months, with the maximum on-site at one time being 16 tons. Facility and Corporate Policies It is Great Northern's policy to reduce toxic chemical use when such reduction is based on sound science and results in measurable p ositive environmental impact. Where toxic chemicals are used, best management practices, monitoring, training and preventive maintenance procedures are implemented to minimize the likelihood of chemical releases and injuries. Periodic audits are conducted to assure that policies are being adhered too. Employees are encouraged to participate in all safety programs and their suggestions for program improvement are actively solicited. A hazardous materials emergency response team of facility employees is trained, equipped and available to mitigate any toxic chemical releases which may occur. These policies and practices are endorsed and actively supported by top management. Worst Case and Alternate Release Scenarios The worst case release scenario for chlorine involved the loss of the entire contents of one 2,000 lb. cylinder inside the chlorine house in ten minutes, a release of 200 lbs. per minute. In accordance with RMP OCA for a release inside a building, the release rate from the building was considered to be 55% of the release rate from the cylinder or 110 lbs. per minute. The release rate was used as input to the DEGADIS model and the distance to the toxic end point determined to be 2.89 miles. The number of people potentially impacted was determined to be 7,800. Public receptors within the radius of impact included motels, an airport, a hospital, two schools and residential housing developments. The alternate release scenario was considered as a leak around a failed gasket with an effective diameter of 0.5 inches square. Active mitigation included a withdrawal system which stops chlorine flow when vacuum is lost. This scenario was selected since gasket leaks on chlorine cylinders have caused most historical releases, although not as large as that proposed in this scenario. The release rate was reduced as above to account for the cylinders being in a building. The DEGADIS model was used with typical meterological conditions. The distance to the t oxic end point was 0.195 miles with 150 people potentially impacted. No public receptors were identified. Accidental Release Prevention Program Summary Environmental laws and requlations to which Great Northern is subject include state and federal clean air and clean water legislation, RCRA, TSCA, EPCRA and OSHA regulations, including the HAZWOPER standard. The chlorine system is subject to the requirements of the OSHA Process Safety Management Standard. Great Northern has had written procedures and policies in place to address spill prevention and response since the early 1970's. These procedures address methods of and responsibility for evaluation and approval of new chemicals, materials handling, spill prevention, security, inspections, training and emergency response. For covered systems, procedures have been revised and augmented to address PSM and RMP requirements including employee participation, process safety information, process hazard analysis, operating procedures, t raining, contractor safety, pre-startup review, mechanical integrity, hot work, management of change, accident investigation, emergency response, audits and trade secret issues. The original chlorine feed system at this facility took pressurized liquid chlorine from the bottom valve on the chlorine cylinder, put it through a vaporizor to convert the liquid to gas and then added the gas to a water stream. A leak in the line could result in liquid chlorine being released into the chlorine house. A given volume of liquid would evaporate immediately to about 500 times that volume of chlorine gas. This system has been replaced with one which draws chlorine gas by vacuum from the top valve of the tank and injects it into a water stream. If the vacuum fails due to a leak, air enters the chlorine line and the chlorine regulator valve fails closed, resulting in little if any chlorine being released. Since installation of this new system, releases of chlorine have been far less frequent an d much smaller. Five-Year Accident History There have been no accidents or incidents involving covered chemcials during the past five-years which caused injury, death or significant damage to property or the environment either on or off site. Emergency Response Program Employees who handle chlorine are trained to recognize chlorine emergency situations, including spills and releases, and to immediately report any situations beyond their capaibilities to the Security force through the mill emergency phone number. Chlorine concentrations are monitored at the chlorine building and high levels result in local alarms as well as an alarm at the Steam Plant control room. Employees are trained to contact emergency response personel when an alarm occurs. Training is provded to all new hires with refresher training conducted annually. Approximately thirty employees are trained to the HazMat technician and incident command level with a like number available from our sister mill eight mile s away if needed. Either or both groups can be mobilized by pager through the facility Security Department around the clock. A fully equipped HazMat response trailer is available at both facilities. Chlorine repair kits are located at the chlorine house. The facility Security Department has at least one Emergency Medical Technician on duty at all times with others available for call-in. The facility has written mutual aid agreements with the local communities, and written procedures addressing both on-site and off-site response are maintained. Training is provided monthly for facility emergency response personnel and a full scale drill involving facility employees, employees from the sister mill and municipal emergency response personnel is conducted annually. Continuous Improvement Great Northern is currently evaluating the technical and economic feasibility and desirability of replacing chlorine for process water disinfection with an alternate material such as sodium hypochlo rite. Spill prevention and control policies and procedures are reviewed at least annually by Environmental, Safety, Operations and Maintenance Personnel to assure that Best Management Practices are followed and to identify opportunities for improvement. |