Jefferson Smurfit Corporation (US) - Brewton Mill - Executive Summary |
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EXECUTIVE SUMMARY JEFFERSON SMURFIT CORPORATION (U.S.) BREWTON, ALABAMA MILL Brewton Mill Policy It is the policy of Jefferson Smurfit Corporation (U.S.), Brewton, Alabama mill to conduct its business to insure the likelihood of a release of chlorine or chlorine dioxide is minimized and if there is a release the 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 Brewton Mill Operation Jefferson Smurfit Corporation's Brewton facility produces a solid bleached sulfate paper and mottled white linerboard. In the process of bleaching pulp b oth chlorine and chlorine dioxide are utilized. Process water is treated with chlorine as part of our normal water treatment process. Description of RMP processes Chlorine - Bleach plant Chlorine is delivered to the mill in 90 tons rail cars that are used as the on-site storage container. The employees of the Bleach/Wash area connect the rail car to the mill unloading lines. This unloading process is continuous until the rail car is empty. From the rail car, the liquid chlorine is transferred to a chlorine header where the Bleach plant uses the amount they need for their particular process. When the liquid chlorine leaves the header, it flows into a vaporizer and is turned into chlorine gas. The chlorine gas flows through a pressure-regulating valve where the pressure is controlled to 85 psig. From the pressure-regulating valve the chlorine flows through a flow-control valve, through a barometric loop and into the chlorine mixer and is absorbed by the brown stock used for paperm aking. Chlorine - Water treatment The water treatment system receives their chlorine from the chlorine header described above under (Chlorine- Bleach Plant). When the liquid chlorine leaves the header, it flows into a vaporizer and is turned into chlorine gas and then into the chlorinator. The chlorinator injects chlorine gas into untreated mill water as long as mill water flow is maintained. Remotely operated isolation valves are provided in the liquid and vapor chlorine lines to and from this vaporizer. Chlorine Dioxide Chlorine dioxide is generated by combining R-2 solution (a mixture of sodium chlorate and sodium chloride) and sulfuric acid in an air-agitated reaction vessel called a generator. The gaseous chlorine dioxide is vented into two absorbers where it is absorbed in chilled water to create the liquid chlorine dioxide solution that is used to bleach the paper stock. The liquid chlorine dioxide is pumped to mixers or to stock pumps where it is blended into the stock. T he stock is then pumped into towers to provide the necessary residence time required for the bleaching to occur. Vapors that off-gas from the chlorine dioxide absorbers, storage tanks, standpipe, and stock towers are collected and sent to scrubbers to prevent their release to the atmosphere. The scrubbers use caustic solutions to scrub the vapors. Worst-case release scenario Chlorine - Bleach plant / Water treatment The worst-case scenario chosen is the catastrophic failure of a 90-ton chlorine railcar. A 90-ton chlorine railcar catastrophically fails releasing 180,000 pounds of pressurized liquefied chlorine over a 10-minute period. The resulting vapor cloud will be released as a dense gas. The "RMP COMP" model predicts that the resulting vapor cloud disperses downwind to the toxic endpoint of 0.0087 mg/L approximately 14 miles from the point of release. Alternative release scenario Chlorine dioxide The alternate release scenario chosen is the failure of the 3-inch diameter chlorine dioxide solution transfer line downstream of the storage tank transfer pumps. The 3-inch diameter transfer line downstream of the storage tank pump fails releasing 314 gallons per minute of chlorine dioxide solution. This release rate is based on the rated capacity of a single pump (214 gallons per minute) plus 100 gallons per minute to account for the additional solution that would be released through the pump that is not operating as a result of the liquid head in the two storage tanks. The operations personnel are assumed to detect and isolate the release within 5 minutes. The released chlorine dioxide solution is assumed to spread as an uncontained spill. The "RMP COMP" model estimated that the resulting vapor cloud disperses downwind to the toxic endpoint of 0.0028 mg/L, approximately 0.5 miles from the point of release. Chlorine - Bleach Plant The alternate release scenario chosen is the failure of a 1-inch diameter flexible hose connected to the chlorine railcar unlo ading line. The flexible hose connected to the chlorine railcar unloading line fails releasing pressurized liquefied chlorine at a rate of 15,000 pounds per hour. This release is assumed to be small enough to prevent the excess flow valve on the railcar from seating at its design flow rate of 15,000 pounds per hour. The operations personnel are assumed to detect and isolate the release within 5 minutes. The resulting vapor cloud will be a dense gas. The "RMP COMP dispersion model predicts that the resulting vapor cloud disperses downwind to the toxic endpoint of 0.0087 mg/L approximately 0.3 miles from the point of release. Five-year accidental release history There have been two RMP releases of chlorine or chorine dioxide within the five years of 1994 to date. Incident 1 Date: May 10, 1997 Time: 23:00 (approximate) Duration of release: Less than 1 minute Chemical Involved: Chlorine Dioxide - CAS 10049-04-4 Estimated quantity released in pounds: 18 pounds within a 1% solution 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 damaged during maintenance/repair 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. Incident 2 Date: June 6, 1997 Time: 08:40 (approximate) Duration of release: Less than 2 minutes Chemical Invol ved: Chlorine - CAS 7782-50-5 Estimated quantity released in pounds: 446 pounds Type of Release event: Breach of 1" flange connection on chlorine unloading line from chlorine railcar. Weather Conditions: Not documented On-Site Impacts: 8 on-site personnel exposed to release. 3 treated at hospital of which one was admitted for observation. Remaining 5 were treated on-site Known off-site impacts: No known off-site impacts Initiating event and contributing factors: Pipe was possibly bumped by employee during unloading activities. Notification of off-site Responders: 911 was notified of incident, ambulance was called to scene. Operational or process Changes that resulted from investigation of The release: Increased visual inspection, testing of involved components. Changes to respirator usage requirements Placement of additional chlorine sensors in area of railcar Refresher training of all personnel involved in chlorine railcar operations. Installation of additional emergenc y shutoff valves Accidental release prevention program Chlorine Dioxide Jefferson Smurfit Corporation, Brewton Mill 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. Chlorine - Bleach Plant / Water Treatment Jefferson Smurfit Corporation, Brewton Mill has a OSHA Process Safety Management program in place covering its chlorine operations in the bleach plant. 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 Jefferson Smurfit Corporation, Brewton Mill employees will implement emergency proce dures as outlined in the Brewton Mill's Emergency Action Plan and in the Chlorine / Chlorine Dioxide Operating Procedures manual. Mill personnel will handle incidental releases of both chlorine and chlorine dioxide as identified in the mill Emergency Action Plan. Emergency releases of both chlorine and chlorine dioxide will be handled in cooperation with the Brewton Fire Department and local emergency officials. Outside sources 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 and 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 help the Brewton Fire Department will contact additional response agencies such as Escambia County Emerg ency Management for the needed support. The mill has a written Emergency Action Plan which is up-to-date and copies are maintained throughout the mill and on the Brewton Mill Intranet Site. 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 is in the process of building a new bleaching process. This new bleaching process which is being implemented under the requirements of the EPA CLUSTER regulation will allow us to eliminate the use of chlorine in the mill for the bleaching process and treatment of the mill process water system. A new state-of-the-art chlorine dioxide generator will be installed which will replace the current chlorine dioxide generator. This new process should be operational byApril 2001. |