Bowater Newsprint and Directory Division - Executive Summary
RMP EXECUTIVE SUMMARY |
1. Accidental Release Prevention and Emergency Response Polices
We at Bowater Newsprint and Directory Division are strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also completely coordinated with Calhoun and Charleston Fire Departments which provides additional emergency response expertise.
2. The Stationary Source and the Regulated Substances Handled
Our facility's primary activities encompass Pulp and Paper Manufacturing. We have 2
regulated substances present at our facility. These substances include Chlorine dioxide and Chlorine Ton Cylinders. The regulated substances at our facility are involved in several uses. Chlorine dioxide is used as a bleaching agent for pulp. Chlorine is used as a disinfection for drinking water.
The maximum inventory of Chlorine dioxide at our facility is 13,553 lbs., while Chlorine is present at our facility in a maximum quantity of 8,000 lbs. Chlorine dioxide is stored in two tanks in a solution of 10 grams per liter. Chlorine is stored in 1 ton cylinders.
3. The Worst Case Release Scenario and the Alternative Release Scenario
To perform the required offsite consequence analysis for our facility, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance.
Worst Case Scenario - Chlorine Dioxide
The worst case release scenario involves a catastrophic release from the Chlorine Dioxide Plant. The scenario involves t
he release of 8,731 lbs. of Chlorine dioxide from the larger of the two storage tanks. All of the tanks liquid is assumed to be immediately release to form a pool of height 1 cm, from which evaporation takes place. The entire pool is estimated to have evaporated over 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 14 miles is obtained corresponding to a toxic endpoint of 0.0028 mg/L.
Worst Case Scenario - Chlorine
The worst cases release scenario involves a catastrophic release of Chlorine from the Filter Plant. The scenario involves the release of 2,000 lbs. of Chlorine from a 1-ton chlorine cylinder. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 1.3 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L.
Alternative Release Scenario (Chlorine dioxide)
An alternative release scenario for Chlorine dioxide involves a release from one of the tanks at the Chlorine Dioxide Plant process. Th
e scenario involves the release of 33 lbs. of Chlorine dioxide. After performing maintenance to replace a section of the solution line a 75 horsepower motor with a 400 gallon/min. capacity was restarted. Ten minutes after the pump was started, a leak was found from a flange on the section of the pipe. The pump was immediately shutdown. Solution from the process line spilled to the ground at a rate of 3.3 lbs./min. The release formed a pool and it is estimated to have evaporated over 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance at 0.2 miles is obtained corresponding to a toxic endpoint of 0.0028 mg/L.
Alternative Release Scenario (Chlorine)
An alternative release scenario for chlorine involves the release from one of the 1-ton cylinders at our water treatment plant. The scenario involves a leak occurring where the portable tank is connected to the chlorine system. The system is equipped with a chlorine gas detector which would aler
t the operator who would then be able to shut off the gas flow. It is assumed that the release lasted for 10 minutes at 1 pound of chlorine per minute. In this scenario, at Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 0.1 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L.
4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.
Process Safety Infor
Bowater Newsprint and Directory Division maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes.
Process Hazard Analysis
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is Hazard and Operability Study (HAZOP). The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of time/period. Any findings related to the hazard analysis are addressed in a timely manner.
For the purposes of safely conducting activities within our covered processes, Bowater Newsprint and Directory Division maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, tem
porary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes.
Bowater Newsprint and Directory Division has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these PSM processes. Refresher training is provided at least every three years and more frequently as needed.
Bowater Newsprint and Directory Division carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Fu
rthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Bowater Newsprint and Directory Division. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
Bowater Newsprint and Directory Division conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every three years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner.
Bowater Newsprint and Directory Division promptly investigates any
incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of five years.
Bowater Newsprint and Directory Division truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular.
Our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performa
nce of the contractor is carried out. Bowater Newsprint and Directory Division has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur.
5. Five-year Accident History
Bowater Newsprint and Directory Division has had an excellent record of preventing accidental release over the last five years. Due to our stringent release prevention policies, there has been no accidental release above the threshold quantity during this period.
6. Emergency Response Plan
Bowater Newsprint and Directory Division carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first-aid and medical treatment, evacuations, notification of local emergency response agencies and the
public; as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.
7. Planned Changes to Improve Safety
Bowater Newsprint and Directory Division is always seeking ways to improve their overall safety program. Any findings or developments resulting from the implementation of the various elements of our accidental release prevention program will be implemented as soon as practical.
By September 1, 1999, we will be replacing our Chlorine dioxide tanks that currently do not have secondary containment, with a larger tank that will have containment. This containment system will also be equipped with a gas detection system, remote cameras and a foam suppression system.
Using EPA's DEGADIS model, the passive containment; i.e
. dike, would reduce a catastrophic release toxic endpoint to 7.7 miles. Assuming a 90% reduction for the foam suppression system, the toxic endpoint drops to 0.9 miles.
8. Certification Statement for Program Level 3 Processes
See attached paper certification statement.