Appleton Papers Inc. - West Carrollton Mill - Executive Summary |
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The paper mill operated by Appleton Papers Inc. at West Carrollton, Ohio (West Carrollton Mill) has been in operation at its current location since 1948. It was purchased by Appleton Papers Inc. in 1984. We at the West Carrollton Mill are proud to be part of a company that has earned a reputation as an innovative producer of carbonless and thermal papers used in a variety of commercial printing and specialty applications. Our 460 member workforce is made up of employees in production, maintenance, engineering, technical, clerical and management roles. Many of our employees have been with the company or employed at this location for 25 years or more. In many cases, multiple members of the same families earn their living here, parents and children, siblings, cousins, aunts/uncles and nieces/nephews. Most live within a few miles of the mill and are raising their families in West Carrollton and neighboring communities. Safety, of our employees and of the community is a high priority at Appleton Papers Inc. and at the West Carrollton Mill. We recognize that every person is irreplaceable and that injury or loss of live is devastating to whole families. We recognize the responsibility to our employees and the community that goes along with using hazardous chemicals. We have eliminated the use of pure ammonia as a nutrient in our wastewater treatment process replacing it with a less hazardous, liquid product. We have reduced the amount of propane stored on site to power forklifts and changed our storage method from a large tank to small cylinders. We have minimized the use of chlorine, for example, by eliminating its use for the treatment of our process water. Its only remaining use at the West Carrollton Mill is for the bleaching of recycled paper pulp. The West Carrollton Mill recycles 360 tons of wastepaper every day. That's over 250 million lbs of paper every year that would otherwise go to a landfill. Chlorine is used at the West Carroll ton Mill to bleach the pulp from the recycled paper so it can be made into paper that meets the requirements of our customers. We have begun the process of choosing a suitable replacement for chlorine in our process that will still allow us to produce paper from recycled fiber that meets our customers' requirements. There are three primary components of our Risk Management Plan. Following is an overview of how we are effectively protecting the safety of our employees and the community through: 7 Hazard Assessments 7 Accident Prevention 7 Emergency Response Planning Hazard Assessment In addition to identifying and planning to prevent a worst case or alternative release, we periodically examine every part of the process that contains chlorine. Each piece of equipment, every pipe, every fitting, every valve, every control loop is analyzed to identify what might go wrong and how to prevent it. For each situation identified, we plan a solution to eliminate th at potential cause of a release. The solutions are carried out as quickly as possible and their progress is tracked until all are complete. In addition, as required by the Risk Management Planning regulations we modeled our worst and alternative release scenarios using EPA's Offsite Consequence Analysis model. Air dispersion models are limited in their ability to accurately predict the impact of a chemical release. Their limitations increase as the complexity of the topography surrounding the release site increases. Although the model assumes almost no wind and flat terrain, buildings and terrain features such as hills would disrupt and redirect airflow. The model also assumes no reaction with the ground, air or water. However, it is likely that some of the chlorine would be consumed in reactions with elements found in the environment. EPA's worst case scenario requires facilities to predict the path of a release of the entire contents of our largest vessel in 10 minute s in calm sunny weather. Our hazard analysis shows that with even minimal preventive measures in place, this scenario is practically not possible. The next most likely scenario we could propose, our alternate worst case, is also extremely unlikely to occur and would result in a release of only 28 lbs in less than one minute. Within that time, safety features engineered into our process would detect and automatically shut off the flow of chlorine, ending the release. Following are some of the precautions and procedures in place to prevent accidental releases including the worst case and alternate release scenarios described in this report. Accident Prevention While preparation for response to a release is important, our primary goal is to prevent one from ever happening. Our prevention program, in compliance with OSHA's Process Safety Management and EPA's Risk Management Planning regulations, ensures that regulated substances are safely stored, used and handled. The West Carrollton Mill's accident prevention program consists of the following elements. Process Safety Information: We have compiled information to assist our employees who operate the process to identify and understand the hazards posed by it. This information comes from Material Safety Data Sheets and our chlorine and equipment suppliers. Process Hazard Analysis: A hazard evaluation has been preformed by an experienced team to identify, assess and control the hazards involved in each part of the process. Using "what if" scenarios and checklists, the team periodically evaluates the entire process for hazards. In addition, the team reviews all incidents that occurred since their last evaluation for their potential to result in a release. They examine engineering controls for situations that could result in failure and administrative controls and operating procedures for potential consequences of deviations from them. Operating Procedures: Written procedures have been developed and implemented to provide clear instructions for safely conducting activities and operating all parts of the process consistent with the process safety information and hazard analysis. Operating procedures are readily accessible to employees who work in or maintain the process. New employees are carefully trained by experienced employees and their supervisor. Training: Initial and refresher training is conducted as appropriate for each employee involved in operating a process. Management ascertains and documents that each employee has received and understood the training. Mechanical Integrity: The West Carrollton Mill has developed a comprehensive maintenance program that applies to tanks, piping systems, relief and vent systems and devices, emergency shutdown systems, controls and pumps in the covered process. Written procedures, training for process maintenance activities, monthly inspection and testing, prompt correction of equipment deficiencie s and quality assurance are all included in this program. Management of Change: Written procedures have been established and implemented to assure that changes made to the process will have no adverse impact on safety. This process is a HAZOP analysis that looks at all possible impacts of the change. Any proposed change that increases the likelihood of a release won't be made. The management of change procedures include review and approval, provisions for documentation of the change in all other areas of the accident prevention program and requirements for training. This Risk Management Plan will also be updated if a change results in a change in the information it contains. Pre-Startup Review: A pre-startup safety review is performed whenever the process is modified significantly. This review confirms, prior to startup, that construction and equipment is in accordance with the design specifications; safety, operating, maintenance and emergency procedures are in place and adequate; if needed, a process hazard analysis has been performed; management of change requirements have been met and training of each affected employee has been completed. Compliance Audits: The West Carrollton Mill periodically evaluates compliance with the provisions of Process Safety Management and will evaluate compliance with Risk Management Planning as well to verify that the procedures and practices developed under the standards are adequate and are being followed. The compliance audit is conducted by an internal auditor. A report of any deficiencies found during the audit is prepared by the auditor. Corrective action plans are documented by the West Carrollton Mill and include an expected completion date. Progress toward completion is documented as well. Incident Investigation: The West Carrollton Mill will investigate each incident that results in any release of chlorine, or could reasonably have resulted in a catastrophic release. As for an audit, a repo rt is prepared at the conclusion of the investigation. Intended corrective actions and expected completion dates are documented. Progress reports are written. The incident report and corrective actions are reviewed with affected employees. If the change is significant, management of change procedures are followed. Employee Participation: The West Carrollton Mill values the input of its employees, especially those who operate or maintain the equipment on a daily basis. They participate in analysis of proposed changes, periodic hazard analyses, training, audits and incident investigation. Hot Work Permit: The West Carrollton Mill issues a hot-work permit for any cutting or welding jobs done anywhere in the mill. The permit documents that fire prevention and protection procedures have been followed prior to beginning the hot work. The permit also indicates the date(s) authorized for the work and identifies the object upon which the work is to be done. Contractors : Contractors need special training to work safely on our chlorine process equipment. We work closely with the owners of the contracted company, the supervisors of the contracted employees and the employees themselves to ensure that they are well trained and qualified to work on the chlorine using process safely. Emergency Response In-house emergency response consists of training and planning for response to and recovery from emergencies. Emergencies for which we have planned responses include not only chemical release, but also fire, explosion, floods and severe weather, including tornadoes. These plans begin with internal warning alarms, a chain of command and specific responsibilities for key employees. An emergency response team known as the Mill Emergency Organization responds to fires and chemical spills (except chlorine), provides first aid and coordinates evacuation of the mill if necessary including during a chlorine emergency. A second team consisting of the employees who work with chlorine and know the processes the best, is known as the Chlorine Response Team. They have the equipment and training to respond to, isolate and repair leaks in the chlorine system. Should the Chlorine Response Team or the Mill Emergency Organization feel that the community is threatened, the community emergency response plan is activated. The community emergency response plan is activated by contacting the West Carrollton Fire Department for assistance. The Fire Chief assumes command of the situation upon arrival. If additional assistance is needed, he contacts the Dayton Regional HazMat Response Team. The Local Emergency Planning Committee has procedures in place for notifying the public, and if necessary coordinating evacuation or sheltering in place. Summary Appleton Papers Inc. and its West Carrollton Mill are committed to a continuous effort to protect the community, the environment and our employees from accidental releases. There have been no releases of chlorine from the West Carrollton Mill that resulted in deaths, serious injuries or significant property damage onsite or deaths, injuries, evacuations, sheltering in place, property damage or environmental damage offsite since Appleton Papers Inc. assumed responsibility for the facility in 1984. |