JSC Brewton, Inc. - Executive Summary

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Brewton Mill Policy 
It is the policy of the JSC Brewton, Inc., Brewton, Alabama mill to conduct its business to insure the likelihood of a release of chlorine dioxide is minimized and if there is a release the offsite consequence will be reduced. To accomplish this the chlorine dioxide process equipment is maintained according to good engineering and maintenance practices. Our operating and maintenance employees utilizing the chlorine dioxide system have been trained in the requirements of chlorine dioxide safety. 
Description of Brewton Mill Operations 
The JSC Brewton, Inc, facility produces a solid bleached sulfate paper and mottled white linerboard. In the process of bleaching pulp chlorine dioxide is utilized. Process water is treated with chlorine dioxide as part of our normal water treatment process.   
Description of RMP processes: 
Chlorine Dioxide 
Chlorine dioxide is used for the bleaching of pulp and for the treat 
ment of process water used at the mill. Chlorine Dioxide is manufactured on-site by combining sodium chlorate (NaCLO3), methanol (CH3OH), and sulfuric acid (H2SO4). Sodium chlorate is reacted under certain conditions of acidity and temperature and with the addition of a reducing agent (methanol) chlorine dioxide is produced. Mill production equipment can produce up to 35 tons per day of a 10 gram per liter (g/L) chlorine dioxide solution, which is stored in two above ground storage tanks. These tanks have a total capacity of 344,000 gallons (172,000 each).  
Worst-case release scenario 
Chlorine Dioxide 
The worst-case scenario chosen is the failure of the 172,000 gallon chlorine dioxide storage tank. The chlorine dioxide storage tank catastrophically fails releasing 172,000 gallons (approximately 1,435,400 pounds) of a 1% by weight chlorine dioxide / water solution. The released chlorine dioxide solution is contained within the diked area. The chlorine dioxide in the solution will eva 
porate from the spill. Therefore, the mass of chlorine dioxide in the spill (approximately 14,354 pounds) is assumed to be released as a gas over a 109-minute period. The  EPA "RMP Offsite Consequence Analysis"  model predicts that the resulting vapor cloud disperses downwind to a toxic endpoint of 0.0028 mg/L approximately 12 miles from the point of release.  
Alternative release scenario 
Chlorine dioxide  
The alternate release scenario chosen is the failure of the 6-inch diameter chlorine dioxide solution transfer line downstream of the storage tank transfer pumps. The 6-inch diameter transfer line downstream of the storage tank pump fails releasing 536 gallons per minute of chlorine dioxide solution. The operations personnel are assumed to detect and isolate the release within 5 minutes. The released chlorine dioxide solution would be contained within the diked storage tank area. The "RMP COMP" model estimated that the resulting vapor cloud disperses downwind to the toxic endpoin 
t of 0.0028 mg/L, approximately 0.9 miles from the point of release. 
Five-year accidental release history 
There has been one RMP releases of chorine dioxide within the five years of 1994 to date. Note that the accident occurred in a part of the Chlorine Dioxide process that was decommissioned in August 2000. 
Incident 1  
Date: May 10, 1997 
Time: 23:00 (approximate) 
Duration of release:  Less than one minute 
Chemical Involved: Chlorine Dioxide - CAS 10049-04-4 
Estimated quantity released in pounds: 18 pounds 
Type of Release event: Breach of 2 inch liquid line at ground floor level of bleach plant  
Weather Conditions: Not documented 
On-Site Impacts: Exposure to 3 on-site contractor personnel. No medical treatment required at time of release. One employee was seen by physician 3 days after the incident. 
Known off-site impacts: No known off-site impacts 
Initiating event and contributing factors: Failure of pipe during start-up following outage. Pipe possibly damage during maintenance/r 
epair activities in area. 
Notification of off-site Responders: No off-site response personnel were notified. 
Operational or process Changes that resulted from investigation of the release: Increased visual inspection of involved equipment. Use of escape respirators by all personnel in area. Enhancement of procedures for coordination of site hazards with contractors. 
Accidental release prevention program 
Chlorine Dioxide 
JSC Brewton, Inc., has a OSHA Process Safety Management program in place covering its chlorine dioxide operations. This PSM program meets the requirements of the RMP and is thus utilized as the prevention section of the Brewton facility's RMP. 
The OSHA PSM plan and documentation is maintained in the Technical  Department by the Process Safety / Risk Management Coordinator. 
All sections of the RMP prevention program are covered in the OSHA PSM program. 
Emergency response program 
JSC Brewton, Inc.,  mill employees will implement emergency procedures as outlined 
in the Brewton Mill's Emergency Action Plan and in the Chlorine Dioxide Operating Procedures manual. Mill personnel will handle incidental releases of chlorine dioxide as identified in the mill Emergency Action Plan. Emergency releases of chlorine dioxide will be handled in cooperation with the Brewton Fire Department and local emergency officials. Outside resources such as emergency response contractors will be utilized as necessary based on the severity of the situation. The Brewton Fire Department will be notified by calling 911. The Brewton Fire Department has been informed of the usage of chlorine dioxide and has been provided information on the covered RMP/PSM processes.  
Initial response to a 911 call will come from the City of Brewton Fire Department. If the incident requires additional equipment or assistance the Brewton Fire Department will contact additional response agencies such as Escambia County Emergency Management for the needed support. 
The mill has a written Emerg 
ency Action Plan which is up-to-date and copies are maintained through the mill. 
The Brewton Fire Department has been given the opportunity to visit the facility and tour the areas of concern for emergency response coordination. 
Planned improvements to improve safety. 
The Brewton Mill implemented a new state-of-the-art chlorine dioxide manufacturing process in 2000. This process has eliminated the use of elemental chlorine for our pulp bleaching and treatment of mill process water and replaced our previous R-2 chlorine dioxide process. The Brewton Mill continually looks for opportunities to improve the safety of its operations. This is accomplished through on-going safety audits, safety meetings and preventive maintenance and inspection activities. Opportunities for safety improvement are reviewed and implemented as appropriate. There are no other planned improvements to the new chlorine dioxide process at this time.
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