P. H. Glatfelter Co. - Spring Grove Mill - Executive Summary

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                                Process Safety/Risk Management Plan 
                      for the Spring Grove Mill of the P. H. Glatfelter Co. 
                                              June 1, 1999 
                                       Executive Summary: 
The Spring Grove Mill has had a long history of cooperating with local response organizations in emergency situations - both within the plant facility or outside the facility and whatever the cause.  This Process Safety/Risk Management Plan is another step in improving the emergency response process. 
The P. H. Glatfelter 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 bo 
th 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 Company will maintain procedures and equipment to handle environmental emergencies." 
There are two regulated substances used in the kraft pulp and paper mill located in the Borough of Spring Grove, York County, Pennsylvania.  The substances are classified as toxic chemicals.  The details for each regulated substance is given below: 
1. Chlorine is used in the pulp bleaching process and as a biocide in the process and potable water systems at the mill.  The potable water system is also the source of the Boroughs drinking water.  Chlorine is stored on-site in the transportation vessel - either 90-ton rail cars or 1-ton cylinders.  The 90-ton rail car is the primary source with the 1-ton cylinders used as backup during mill shutdowns. 
2. Chlorine dioxide is used in the pulp bleaching process and is required to obtain the pulp 
brightness and cleanliness necessary for the grades of paper manufactured at the Spring Grove Mill.  Chlorine dioxide is produced on-site and stored as a dissolved gas in cool water - 8 tons(16,000 pounds) maximum storage capacity. 
The worst-case release scenario for the two toxic substances is a major rupture of a 90-ton rail car of chlorine shortly after it had been connected to the Mills supply system.  The area affected would be dependent upon the wind direction and would be a pie-shaped area extending up to 21.6 miles from the mill in the downwind direction.  However, 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 would be a failure of gasket material and the rele 
ase of 10 pounds per minute for 30 minutes.  The alternate release scenario for chlorine dioxide would be a break in a pipeline and the release of 1 pounds per minute for 60 minutes.  Both of these two scenarios would have similar affected areas.  The area would extend in a pie-shaped area (depending upon the wind direction) for a distance of approximately 750 feet.   
In order to reduce the size of any area impacted (particularly off-site areas) during any of the release scenarios, the mill has taken several steps as described below: 
1. Chlorine - The chlorine system was completely redesigned about 8 years ago.  During the rebuild the following changes were made: (1)the liquid lines were shortened, (2)the unloading station was moved further from the property line, and (3)the rail cars being unloaded are on a separate spur - not on a side shunt. 
2. Chlorine Dioxide - A new chlorine dioxide system was installed about 7 years ago.  The system was designed with safety in mind and the fo 
llowing steps were specifically taken: (1)the storage tanks were changed from steel to fiberglass, (2)the storage area was moved further from the property line, and  (3)the area around the storage tanks was diked. 
The primary release prevention step is to maintain the system(s) in good working order.  This is done through routine inspections of the equipment, piping, storage vessels, and instrumentation.  The mill also has emergency equipment, i.e. capping kits, on hand to reduce any leaks.  The chlorine system is pressure-tested after every shutdown and whenever major repairs/modifications are performed.  There is a written procedure which must be followed before any modification may be made.  This insures that any changes are incorporated in the emergency response plan. 
As required by the regulations, personnel have reviewed the accident history over the last five years.  There have been no accidents of the magnitude described in the regulations at the Spring Grove Mill for any of  
the regulated substances since January 1, 1994.   
In dealing with emergencies involving any of the controlled substances, mill employees have the training and equipment to deal with minor on-site emergencies.  However, for emergencies requiring outside assistance (defined in our detailed plans) and for all emergency situations where the general public may be affected, York County Control("911") will be contacted and mill employees will respond to assist neighboring and York County Emergency Management Agency personnel. 
Since the systems are all relatively new and designed with safety in mind, there are no planned changes at this time.
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