S.D. Warren Co. ( Muskegon Mill) - Executive Summary

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S. D. Warren Company operates an integrated pulp and paper mill.  The mill is located on Lakeshore Drive, Muskegon, Michigan.  The Pulp Mill and Utility Department operates four process units, which contain EPA listed highly hazardous chemicals over the regulated threshold.  Chlorine is used in both the Pulp Mill Bleach Plant and the Utility Water Treatment Plant.  Chlorine dioxide is generated in two separate production units that supply the Bleach Plant.   
S.D. Warren continuously strives to improve it's accident prevention, environmental protection and emergency response programs.  Since 1980 we have developed many programs that eliminate or minimize the effects of an accidental release.  In 1992 the mill adopted the OSHA Process Management Program and in 1999 the mill implemented the EPA's risk management program (RMP program).  S. D. Warren 's risk management program complies with the U.S. Environmental Protection Agency's ("EPA's") Chemical Accident P 
revention rule found in 40 C.F.R. Part 68.  One requirement of this rule is to submit a Risk Management Plan (RMP Plan) to the EPA.  This RMP Plan submission satisfies the requirement.  The Plan provides the public with information about processes, accident prevention programs, and emergency response planning efforts at the Muskegon mill.  S. D. Warren 's complies with EPA's RMP Program. 
S. D. Warren accidental release prevention policy involves a unified approach that integrates technologies, procedures and management practices.  Our prevention program complies with all applicable procedures of the U.S. Environmental Protection Agency (EPA) Risk Management Program (RMP) 40 CFR-68, Prevention Program. 
S. D. Warren has a management system in place, which oversees the implementation and on-going use of the RMP elements.  The Vice President / Mill Manager is responsible for RMP im 
plementation.  Attached is an organization chart that depicts the positions and lines of authority of this management system.  This program, along with other mill policies, eliminates and /or reduces the likelihood of a hazardous chemical release. 
S. D. Warren maintains policies, procedures and systems as part of their prevention program.  The program is based on the EPA Program Level   3- elements.  The RMP elements have been combined with the like elements of the mill's OSHA PSM program. 
The mill employs 684 full-time employees including all medical or other laid off employees some of whom operate the covered processes.  Chlorine is used in both the bleach plant and as part of the water production operations.  Chlorine dioxide is generated in two units that feed this 1% solution to the bleach plant. 
1.2.1.SITE DESCRIPTION  (b)(1) 
facility has covered chlorine storage at two locations.  First chlorine is received and stored in rail cars which can be unloaded, two at a time, to the evaporation and distribution system, The evaporation unit is contained in a process building.  The single rail car contains 180,000 lbs. The maximum inventory is 360,000 lbs.  Chlorine from this system is used in both the bleach plant and in the water treatment plant.  
The water treatment plant has an alternate source of chlorine from one-ton containers.  Two containers are connected to the water treatment evaporation system located in a process building.  Up to eight full containers are stored in a sheltered process area adjacent to the process building.  The maximum inventory is 20,000 lbs.   
The boundaries of the chlorine system subject to the RMP regulation include the bulk chlorine storage in rail cars, in one-ton containers, the bleach process evaporation building, and the associated vent and exhaust systems.  It also includes  
the water treatment chlorine storage and evaporation building plus its associated systems. 
The facility has two covered chlorine dioxide storage locations.  First is the original unit.  Chlorine dioxide comprises approximately 1% of a liquid mixture that is stored in two 15,000-gallon tanks that are surrounded by dikes.  The maximum inventory is 2,500 lbs. While a single vessel contains 1,250 lbs of chlorine dioxide.  The second process is a new larger unit.  Chlorine dioxide comprises approximately 1.2 % of a liquid mixture that is stored in two 60,194 gallon tanks that are surrounded by a dike system.  The maximum intended inventory of these storage tanks and associated piping, reaction vessels etc is equal o 10,850 lbs of chlorine dioxide.  A single vessel contains 4,700 lbs of chlorine dioxide.   
Chlorine and chlorine dioxide are the only regulated substance on site, which exceeds the EPA 40 CFR-68 rule threshold quantity.  
The worse case and alternate scenarios were evaluated using both EPA guidance and air dispersion modeling.   
An off-site consequence analysis is required by the RMP rule to estimate potential impacts to the community.  As required by RMP, S. D. Warren 's off-site consequence analysis included evaluation of a worst-case accidental release for all toxic chemicals and an alternative release for each covered chemical. 
1.3.1.WORST CASE   (c)(1) 
The worse case scenario involves the total release of an 180,000-pound rail car tank container to the atmosphere.  EPA guidance/RMP Comp was used to determine the release end point. 
The worst-case release is defined by EPA as "a release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to an endpoint defined in ? 68.22."  40 C.F.R. ? 68.3.   EPA requires the worst-case accidental release to be modeled using highly conservative meteorologica 
l data designed to result in the maximum possible adverse impact.  For example, EPA requires worst-case models to be based on the hottest day of the year, occurring at night with a very slow, steady wind, which would not disperse a release effectively. Further, the model assumes that the entire contents of the largest vessel are released instantaneously.  According to the chlorine institute, no 90-ton rail car has ever instantaneously released its contents. The chances of such an event occurring on a 98?F night when the wind is blowing at 3.4 miles per hour is extremely remote.   
Worst-case releases for the other three processes were evaluated.  Each case had a significantly smaller distance to the endpoint than the release of 180,000 lbs pf chlorine.  Under the EPA mandated scenario described above, the worst-case release at the mill (for purposes of RMP) would result in a vapor cloud that could extend beyond the mill's property line. 
1.3.2.ALTERNATIVE CASE   (c)(2) 
S. D. Warren dev 
eloped alternative scenarios for chlorine and chlorine dioxide, which focus on more realistic releases occurring during more common meteorological conditions.  However, EPA requires modeling a release, which could impact off-site locations. After considering all criteria in the RMP rule, the process hazard analyses ("PHAs") performed on covered processes, and all past releases from covered processes, S. D. Warren chose the following alternative release scenarios: gasket failure in the chlorine liquid line from the 90-ton rail car to the vaporizer building; failure of a chlorine valve whip; and insufficient supply of water to the bleach plant original chlorine dioxide absorption tower. leak of a chlorine dioxide transfer pipe from the R-8 unit storage tank that feeds the bleach plant.  The leak was estimated at 10% of the total liquid solution flow or 12,500 gallons of liquid per hour. 
Each of these release scenarios could result in a 
vapor cloud that could extend beyond the mill's property line.  
S. D. Warren accidental release prevention program is based on OSHA's PSM program and EPA's RMP Level 3 prevention program.  The PSM program has been in place and effectively used for several years.  It is part of the standard operating procedure for the facility.  There are two parts to the program.  The first is the general overall site program.  The second is the chlorine-and chlorine dioxide specific actions within the site program.  These programs are coordinated with Muskegon fire department. 
Facility-wide, elements of the prevention program are used for all operations.  The basic elements are described below: Participation.  S. D. Warren has developed and implemented a written plan of action regarding employee participation in the safety and accident prevention process.  The plan descri 
bes how employees are:  (A) consulted with and what input they would have in the development of Process Hazard Analysis (PHA) and other PSM and RMP safety elements.   (B) Given employees and their representative's access to PSM and RMP information. Safety Information:  In accordance with applicable requirements, S. D. Warren has compiled and maintains process safety information about the design, installation, maintenance, and operations of its covered processes.  This ensures that information remains current. Process Hazard Analyses.  S. D. Warren performed process hazard analyses (PHA) on its PSM/RMP covered processes.  The PHA is a key component of the process safety management system and S. D. Warren 's RMP accident prevention program.  It is a thorough, orderly, systematic approach for identifying, evaluating, and addressing potential hazards posed by the covered processes   Specifically, the PHA addressed: (1) hazards of the process; (2) engineerin 
g and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases (e.g., process monitoring and control instrumentation with alarms); (3) consequences of failure of engineering and administrative controls; (4) facility siteing; (5) human factors (human error); and (6) a qualitative evaluation of a range of the possible safety and health effects of failure of controls on the employees in the work place.  S. D. Warren provides employees, contractors and visitors with training that focuses on the special safety and health hazards posed by the mill's operations, RMP and PSM covered processes, emergency operations including shutdown, and safe work practices applicable to the employees job tasks.  S. D. Warren confirms that employees and contractors involved in operating covered processes have successfully completed the required periodic training.  S. D. Warre 
n documents that covered employees and contractors have received and understood the required training.  Documentation, at a minimum, includes the identity of the employee or contract employee, the date of training, and the means used to verify that the employee understood the training.  As part of S. D. Warren 's contractor selection process we obtain and evaluate information regarding contract employer's safety performance and programs.  29 C.F.R. ? 1910.119(h).  S. D. Warren also:  
A. Informs contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the covered processes; 
B. Explains to contract employers the applicable provisions of the facility's integrated contingency plan (discussed below); and 
C. Controls the entrance, presence and exit of contract employers and contract employees in covered process areas. Pre-startup Safety Review:  As required, following installation of new and or 
modifications to a covered process, a pre-startup review is conducted to ensure that the process is constructed and the equipment is designed in accordance with specifications; and that appropriate safety, operating, maintenance, and emergency procedures are in place to adequately protect the health and safety of employees and the public. Hot Work Permit:  As part of its overall fire protection program, S. D. Warren implements a hot work permit program for all hot work operations (e.g., welding, soldering, etc.) conducted through out the mill and on or near RMP covered processes. of Change:  S. D. Warren has established and implements a procedure to authorize and document changes in covered processes.  This procedure ensures that all required considerations are addressed prior to any change to equipment, facilities, raw materials, and procedures being implemented. Investigation.  S. D. Warren investigates each incident, which resulted  
in, or could reasonably have resulted in, a significant release of a highly hazardous chemical in the workplace.  An incident investigation team is established and consists of at least one person knowledgeable in the process involved, including a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident. Planning and Response.  S. D. Warren has developed an integrated contingency plan that satisfies all applicable state and federal emergency response and accidental prevention planning requirements (described under emergency response policies below). Audits.  S. D. Warren has evaluated its compliance with OSHA's PSM and EPA RMP Standard in November 2000 and again in February 2002.  We also require an audit at least every three years to verify that the procedures and practices it has developed are adequate and being followed. Secrets.  S. D. Warren makes all necessary information available to those persons responsible for compiling process safety information and those assisting in the development of the process hazard analysis.  
Chemical-specific prevention features at the facility include specific procedures for the operation and maintenance of the chlorine system. Operating Procedures.  S. D. Warren has developed and implements written operating procedures that provide clear instructions for safely operating the covered processes.  These procedures are consistent with the process safety information described earlier and include: 
A. Initial startup; the first time and after major shutdowns 
B. Normal operations; 
C. Temporary operations; 
D. Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that eme 
rgency shutdown is executed in a safe and timely manner; 
E. Emergency Operations; 
F. Normal shutdown;  
G. Startup following a turnaround, or after an emergency shutdown; 
H. Consequences of deviation from operating limits; 
I.  Steps required to correct or avoid deviation; 
J. Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment; 
K. Control measures to be taken if physical contact or airborne exposure occurs; 
L. Quality control for raw materials and control of hazardous chemical inventory levels; and 
M. Safety systems and their functions are included in the procedure. 
S. D. Warren has also developed and implements safe work practices that provide for the control of hazards during operations.  For example, S. D. Warren has programs that govern the following activities: breaking into chemical lines and equipment, lockout/tag out; confined space entry; and control over entrance into PSM and RMP covered process  
areas of the mill by maintenance, contractor or other support personnel. Mechanical Integrity.  S. D. Warren has developed and implements written procedures to maintain the ongoing integrity of the process equipment listed below.  S. D. Warren also trains employees to maintain the following process equipment: 
A. Pressure vessels and storage tanks; 
B. Piping systems (including piping components such as valves); 
C. Relief and vent systems and devices; 
D.  Emergency shutdown systems; 
E. Controls (including monitoring devices and sensors, alarms, and interlocks); and 
F. Pumps 
G. All other critical equipment identified in the covered processes. Design 
Both chlorine evaporation buildings are equipped with fan ventilation systems, chlorine monitors and alarms. 
The R-8 facility for chlorine dioxide generation building is equipped with a normal and emergency ventilation system.  The facility also has fire sprinkler and deluge systems.   Plus all chlorine dioxide stor 
age vessels fumes are vented through a scrubber. Design 
Both the chlorine systems are designed to meet the equipment design criteria of the Chlorine Institute.  The Chlorine Dioxide R-8 unit's design is as prescribed by the unit manufacturer Sterling Chemicals.  It meets or exceeds industry standards.  .  
S. D. Warren has had two minor vhlorine dioxide releases in the past five years.  One was due to equipment failure and was a very small (less than 1 lb.) chemical release.  The other was equally small and due to human error.  There have been no loss time cases or off-site impacts to either the population or enviromment in the past five years.  
Emergency response procedures are contained in S. D. Warren's Emergency Response Plan (ERP). 
The ERP is coordinated with and reviewed by the Muskegon Fire Department, which coordinates with the Local Emergency Planning Committee (LEPC) and HazMat Team 
#3, Muskegon, Michigan. 
1.6.1.PERSONNEL  (f)(1) 
S. D. Warren has a dedicated Plant Protection Department that is responsible for all the above mill wide safety programs.  Plus mill employees make up the operator, maintenance and emergency response teams.  
S. D. Warren plans to discontinue use of two processes that contain regulated substances.   The first process to be shut down, isolated and decontaminated is the chlorine rail car and evaporation system.   This will reduce the maximum quantity in a single vessel from 180,000 pounds to 2,000 pounds.   Based on preliminary off site impact studies, the area and number of home and facilities impacted will be drastically reduced.  The second process to be shut down is the original chlorine dioxide generation facility.  This will reduce that chemical's inventory by 2,500 pounds.   
Changes to improve safety (recommended actions) were also identified during the recent safety tour audit and hazards analys 
is.  The recommended actions have now been evaluated and are being implemented as required  
S. D. Warren continually reviews implemented and potential safety improvements for all of its operations.  Currently, S. D. Warren management team and process safety team are reviewing potential upgrades to the existing design of the water treatment chlorine operations to make the system even safer, to prevent a release and minimize consequences in the event of a release
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