Stone Container Corporation, Panama City Mill - Executive Summary |
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EXECUTIVE SUMMARY SMURFIT-STONE CONTAINER CORPORATION PANAMA CITY MILL Corporate Policies There is a written CORPORATE SAFETY MANUAL. This manual gives the detail requirement that must be taken by each facility to develop its safety program. The manual describes senior management's commitment to safety. The safety policy assigns the responsibility and authority to the management team at each facility for conducting an effective safety program. There is a written Corporate CHEMICAL HAZARD COMMUNICATION MANUAL. The manual describes how each facility is to develop its own local Hazard Communication program. The manual assigns the responsibility and authority to the management team at each facility for developing an effective Hazard Communication program. Panama City Mill Policy It is the policy of Smurfit-Stone Container Corporation, Panama City, Florida to conduct its business to insure the likelihood of a release of chlorine or chlorine dioxide is minimized and if there is a release t he offsite consequence will be reduced. To accomplish this the chlorine valves, regulators, heaters, vaporizers, controllers, lines, connections, fittings, injectors and the chlorine dioxide generator, storage tanks, pipe lines, mixers and pumps are maintained according to good engineering and maintenance practices. Our operating and maintenance employees utilizing the chlorine and the chlorine dioxide systems have been trained in the requirements of chlorine and chlorine dioxide safety. Description of Panama City operation Smurfit-Stone Container Corporation's Panama City facility produces kraft linerboard and bleached hardwood Market Pulp. In the process of bleaching pulp chlorine dioxide is utilized. Process water is treated with chlorine to prevent a slime buildup in the production process. Description of RMP processes Chlorine - Water treatment There are two locations on the mill site where chlorine is used to treat process water. The two systems are identical other than loca tion. Chlorine is used from one ton cylinders. There are two cylinders connected at each location. Chlorine vapors pass through an in line electric heater, a regulator and vacuum shutoff valve, a flow meter, a flow control valve, a water driven vacuum inductor and is injected into the process water line. Chlorine Dioxide Chlorine dioxide is generated on site in a process using sodium chlorate and methanol in a strong sulfuric acid solution. Chlorine dioxide is removed, as generated, by vacuum and absorbed in cold water (38-40 ?F) to a concentration of 9 to 10 grams / liter. There is a 244,000-gallon storage tanks for the chlorine dioxide solution. This solution is used at several locations in the bleach plant operations. The normal usage rate is 403 gpm with a maximum capacity of the system at 573 gpm. Worst-case release scenario Chlorine Dioxide The maximum quantity of chlorine dioxide that will be in the largest container on site at any one time will be 231,180 gallons of solution containing 19,248 pounds of chlorine dioxide. The tank is located in an area that serves to contain any non-EPA worst-case releases expected. This contained area has a maximum exposed surface area of 24,300 square feet. This will result in a worst-case release scenario quantity of 1069 pounds per minute of chlorine dioxide. For this worst-case calculation the total time of the release for all of the ClO2 to the atmosphere has been estimated to be about 18 minutes. There are administrative controls on chlorine dioxide inventory at the facility. The chlorine dioxide tank is 62 feet tall. There are operating instructions that restrict the operating level to only 58 feet. This allows room for holding the surge volume required when the bleach plant shut down quickly. The depths of solution will never reaches a level of over 58.9 feet (95% full. This level is recorded on the log sheet and will serve as the record that this level is not exceeded. There are passive control measures in place at the facility. The first passive control is a curbed pad area where the ClO2 storage tank is located. The volume of this contained area is 75,000 gallons. The surface area of this curbed area is 24,300 square feet. This will not contain an EPA defined worst-case release; however, it will contain the volume of any expected release scenarios. The second passive control is the drain from the contained area. This drain rated at 10,000 gpm will carry the released chlorine dioxide solution into a pond (emergency clarifier) to be mixed with other process sewer water. This could result in as much as 800 of the 1069 pounds per minute release reacting and not being released to the atmosphere. However, for the selected worst-case release rate it was assumed that all the ClO2 in solution going into the pond would be released. Chlorine - Water treatment The maximum quantity of chlorine that will be in the largest container at each water treatment process area will be 2,000 pounds. There wil l be two one ton cylinders connected and operating at each process. There is no known scenario that a failure of one cylinder will cause a failure in the other cylinders at the process. Under the restrictions of the worst-case scenario a one ton cylinder will fail and will release its entire content. The worst-case release scenario quantity will be 2,000 pounds at a release rate of 200 pounds per minute. There are no administrative controls on chlorine inventory. There are no passive control measures in place at the facility. Alternative release scenario Chlorine dioxide The chlorine dioxide solution pump to the bleach plant is in operation and pumping at a rate of 403 gallons per minute. The line breaks releasing this flow of a 10 gram per liter solution. On rupture there will be a loss of pressure notifying the bleach plant control room operator that something has happened. It was estimated that it would require no more than 10 minutes to locate the problem and to stop and valve o ut the pump. This release will involve a total of 4030 gallons or 504 pounds for a release rate of 33.6 pounds per minute. The distance to the endpoint will be 1.3 miles. The release rate assumption for these alternative release scenarios is that 100% of the Chlorine Dioxide in the released solution is released to the air as soon as it reaches the ground. Chlorine - water treatment A tank is in service with the regulator in place. The regulator is hit causing the regulator to break off. This will result in a leak equal to the maximum withdrawal rate from the cylinder. The release rate will be 0.39 pounds per minute and the duration of the leak could be 3 to 4 hours until the next round by the operator. The distance to the endpoint is 125 yards. Five-year accidental release history There have been no RMP releases of chlorine or chorine dioxide within the five years of 1994 to date. There also have been no RMP releases of chlorine dioxide since the October 15, 2000 startup of th e new process. Accidental release prevention program Chlorine Dioxide Smurfit-Stone Container Corporation, Panama City has an 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 Panama City facility's RMP. Chlorine - Water treatment Smurfit-Stone Container Corporation, Panama City has an OSHA Process Safety Management program in place covering its Chlorine operations at water treatment. This PSM program meets the requirements of the RMP and is thus utilized as the prevention section of the Panama City facility's RMP. General prevention activities at the mill The mill has a staff of experienced and knowledgeable employees that receive refresher safety training annually. Each employee working with chlorine or chlorine dioxide has experience in the proper use of personnel protective equipment. The mill has a trained and qualified Emergency Res ponse Team that includes use of SCBA's and full protective suites, which are necessary for approach into a release up to the worst-case level. Any event involving a release of chlorine or chlorine dioxide is investigated and a root cause determined. An incident investigation team will accomplish this and mill procedures are that all findings and recommendations of the team will be addressed. Emergency response program Smurfit-Stone Container Corporation, Panama City's employees will respond to the onsite cause of an emergency release of chlorine or chlorine dioxide. In the event of a possible off site consequence from the release of chlorine or chlorine dioxide The Bay County Emergency Management Center will be notified by calling 911. Bay County Emergency Management Agency has been informed of the usage of one ton cylinders of chlorine and a 244,000 gallon tank of a water solution of chlorine dioxide and have a copy of this Risk Management Program. Initial response to a 911 ca ll will come from the City of Springfield Fire Department. If the incident requires additional equipment or help the Springfield Fire Department will call the Bay County Emergency Management Agency for the needed support. The mill has a written Emergency Action Plan which is titled " EMERGENCY RESPONSE PLAN" and there are up-to-date copies maintained through the mill. The mill has an Emergency Response Team that is trained in emergency response procedures, including chlorine and chlorine dioxide, and in the implementation of the mill Emergency Operations Plan. Bay County Emergency Management Agency was given the opportunity to inspect the site and make recommendations for inclusion in this Risk Management Program development. There have been no recommendations for inclusion in the documentation. Planed Improvements to Improve safety. The Panama City mill is constantly improving upon its safety program. A strict monthly Safety and Housekeeping Calendar ensures all safety systems ar e maintained in the highest level of effectiveness and preparedness. As process and systems change, so does our methodology for protecting our employees. Our mill holds the safety of our employees on the same level as producing a quality product - number one. We are the trend setters in both of these area's, not the follows. As a residual affects, our neighbors in the community and the surrounding area benefit. The less problems within the mill means, less likeiihood of problems for our neighbors. As we move into the next millennium we will continue to look at out methods and to ask ourselves can we achieve the same results in a safer and more efficient manner. The following changes to the 112(r) Risk Management covered process have been made. The Panama City mill on October 15, 2000 completed a major modification of its pulp bleaching process. During this modification of the process the following changes were made that affect the 112(r) Risk Management Program. ? The use of elemental chlorine, as a bleaching agent, was stopped. This change in the bleaching process has removed the 180,000-pound railcars from the mill. ? A new state-of-the-art chlorine dioxide generator was installed to replace the 25-year-old unit. This new chlorine dioxide generator is more efficient, safer, and has all the up-to-date controls and protective equipment. ? This changes the EPA defined worst-case release scenario from a release of 180,000 pounds of chlorine to a release of 19,250 pounds of chlorine dioxide. |