P. H. Glatfelter Company - Bergstrom Division - Executive Summary

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The Bergstrom Division Facility located at Neenah, Wisconsin, is part of the P. H. Glatfelter Company.  It started operation at this site in 1904.  It is one of the larger employers in Winnebago County.  It currently employs approximately 420 people.  It manufacturers fine printing papers from recycled fiber that is de-inked in the on-site pulp mill. 
This facility has a long history of cooperating with local response agencies; in particular, the Neenah Fire department and the Winnebago County Local Emergency Planning Committee (LEPC). 
This facility is committed to operating in a manner that is safe for our workers, the public, and the environment.  As part of this commitment, the Bergstrom facility has established a system to help ensure safe operation of the processes at this facility.  One component of this system is a Risk Management Program that helps manage the risks associated with our chlorine use areas.  The program must also comply with the requirements of EPAs 40 CFR 68 "A 
ccidental Release Prevention Requirements: Risk Management Programs" and OSHAs 29 CFR 1910.119 "Process Safety Management of Highly Hazardous Chemicals." 
A.  Accidental Release Prevention and Emergency Response Policies 
The Bergstrom facility is committed to the safety of its workers and the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances.   The Companys Environmental Policy commits the Company to a continuing effort to reduce adverse environmental impacts, which may be caused by its operation.  In the Policys administrative direction, Paragraph D. specifically addresses emergency situations and is quoted below: 
"The Company will employ effective environmental protection technologies and strategies in all operating facilities as a means of both protecting the environment and also of reducing any environmental health and safety risk to our employees and the communities in which we operate. Further, the Compa 
ny will maintain procedures and equipment to handle environmental emergencies." 
B.  Bergstrom Facility and Regulated Substances 
The Bergstrom facility is an integrated paper mill producing fine papers from recycled fiber that is de-inked on-site.  The de-inked fiber is bleached using a hypochlorite process.  This facility handles only one substance regulated by RMP rules in sufficient quantities to be covered. 
As a result of the use of this regulated substance, the following process is covered by the RMP rule: 
                                        Regulated Process Quantity 
          Process                         ProgramLevel                  Substance               Pounds 
Chlorine Tank Car Unloading              3                               Chlorine                360,000 
C.  Off-Site Consequence Analysis 
The RMP rule requires that an off-site consequence analysis be conducted for a worst-case and alternate release scenario for the toxic substance chlorine. 
The wor 
st-case release scenario for chlorine is a failure of a 180,000-pound railroad tank car of chlorine at the chlorine rail car unloading area.  The maximum distance to the toxic end point concentration is 21.6 miles.  The residential population in this area is approximately 370,000 people and includes schools, residences, hospitals, prisons, recreation areas, and industrial areas.   The development of this scenario was required by the regulations.  However, it is an event that is extremely unlikely to occur.  The Company has checked with the Chlorine Institute regarding the possibility of a car rupture while in the possession of a user.  We were informed that the car is designed to withstand transportation accidents and there has never been a major rupture of a car while at a users site or at a producers site being loaded. 
The alternate release scenario for chlorine is a failure of the vaporizer gasket adjacent to the chlorine tank car unloading area.  This scenario assumes that chlo 
rine is released through a hole for 30 minutes before workers detect the release and isolate the vaporizer.  The maximum distance to the toxic end point 674 feet.  A small residential and commercial area that includes a small section of a city park is located within this distance.  The total population in this area is less than 150 people.   
D.  Accidental Release Prevention Program In Chemical Specific  
             Prevention Steps 
The RMP rule requires a Program 3 prevention program for the chlorine tank car unloading area. 
The prevention program is summarized in Chapter 18 "Prevention Program" of the Process Safety Management Manual.  Full details are given in the following chapters of Volume 1 of the Process Safety Management Manual: 
                                          Process Safety Management 
         Item                                    Chapter                                                 Title 
Hazard Review                                 3                
                     Process Hazard Analysis 
Operating Procedures                      4                                      Operating Procedures 
Training                                            5                                      Training 
Maintenance                                     8                                      Mechanical Integrity 
Incident Investigation                      11                                      Incident Investigation 
Compliance Audit                            13                                     Compliance withSafety Audits 
Management of Change                  10                                     Management ofChange 
Pre-startup Review                          8                                      Pre-startup SafetyReview 
Contractors                                      6                                      Contractors 
Employee Participation                     1                                       Employee Participation 
Hot Work Permi 
t                               9                                       Hot Work Permit 
Industry standards are followed at the Bergstrom facility to help ensure the safe handling of chlorine.  The chlorine vendor supplies chlorine by a Department of Transportation approved railroad tank car.  This railroad tank car is then used as an on-site supply for chlorine in the process.  All piping, valves, vaporizers, etc., are consistent with the Chlorine Institute standards.  Workers who perform operations involving chlorine receive training emphasizing industry accepted handling procedures that are consistent with the Chlorine Institute and OSHAs guidelines. 
E.  Five-Year Accident History 
The Bergstrom facility maintains a five-year accident history that fulfills the requirements of the RMP rule.  This history indicates a good record of accidental release prevention over the past five years.  Only one release of this regulated substance, which resulted in a consequence of interest, has 
occurred from the chlorine area in the last five years.  The release affected several railroad employees that were on-site at the time.  No members of the general public were involved.  
This release is documented in Chapter 17.  
F.  Emergency Response Programs 
The Bergstrom facility has established a written emergency response plan that complies with the RMP rule and with other federal contingency plan regulations.  The plan is described in detail in Chapter 12 of Volume 1 of the Process Safety Management Manual.  This plan has been communicated to local emergency response officials through the LEPC.  Notifications have been made to all counties in Wisconsin that may be affected under the worst-case modeling scenario.  Regular dialogue is maintained between Bergstrom Division and the LEPC, the local fire department, and the local rescue squad.  
G.  Planned Changes To Improve Safety 
The Bergstrom Division of P. H. Glatfelter Company constantly strives to improve the safety of the  
processes through both the Incident Investigation Program and a program to reduce chlorine usage.  The following change, which will improve process safety, is being implemented: 
1.  Replacing the biocide, chlorine dioxide, that was being used in the water treatment process with a non-chlorine base material.
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