St. Laurent Paper Products Corp. - Executive Summary

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Executive Summary 
Accidental Release Prevention and Emergency Response Policies 
St. Laurent Paper Products Corp. is committed to providing the optimum in employee and public safety and health.  It is the policy of St. Laurent to assure, so far as possible, that every employee has a safe and healthful place in which to work.  St. Laurent is dedicated to providing the resources necessary to fulfill these commitments.  It is also the policy of the company to expect each employee and contract employee to live up to the responsibility of following all safety rules and committing to safety.   
It is St. Laurent Paper Products Corp. policy to ensure adequate emergency response capabilities exist to handle an on-site emergency regarding RMP-covered chemicals.  St. Laurent executes this policy through employee training, equipment purchases, and coordination with local emergency response agencies. 
Facility Description 
St. Laurent Paper Products Corp. West Point Mill is located along the bank 
s of the Pamunkey River at 19th and Main Streets, in West Point, Virginia.  The facility's history began in 1913 with the construction of a pioneer mill at the head of the York River.  In 1914, Chesapeake Pulp & Paper Company began making pulp, which was sold to other mills.  The Chesapeake Corporation was formed in 1918.  The West Point Mill was one of the first American mills to produce "Kraft" pulp and paper.  St. Laurent Paper Products Corporation purchased the West Point Mill in 1997.  The West Point Mill is an integrated pulp and paper mill which yields approximately 2,000 tons of product per day, including Kraft paper, brown and white linerboard, and corrugating medium.  
The West Point Mill handles chlorine dioxide (ClO2) and aqueous ammonia (NH3), which are chemicals listed in 40 CFR Part 68 of the EPA's Risk Management Plans, CAA 112(r)(7) (RMP). The Mill operates under the Standard Industrial Classification (SIC) Code 2611 which is listed in 40 CFR Part 68 as one of the nine 
Highly Hazardous SIC Codes. The combination of the SIC code and the fact that they are captured under 29 CFR 1910.119 Process Safety Management (PSM) makes the Mill subject to Program 3 requirements as identified in the RMP.  
Chlorine dioxide is manufactured on-site for use in the Mill's bleach plant.  Chlorine dioxide is produced by combining sodium chlorate (NaClO3), methanol (CH3OH), and sulfuric acid (H2SO4).  Sodium chlorate is reacted under certain conditions of acidity (H2SO4) and temperature and with the addition of a reducing agent (methanol), chlorine dioxide is produced.  Mill production equipment can produce up to 25 tons per day of a 10-gram per liter (g/l) chlorine dioxide solution, which is stored in three aboveground storage tanks.  These tanks have total capacities of 68,000 gallons, 120,000 gallons, and 145,000 gallons.  Ammonia (aqueous, 24.5%) is purchased for use in the facility's process wastewater treatment facility.  A local supplier delivers ammonia to the si 
te via tanker truck.  The ammonia is stored in a 15,600-gallon tank.  The maximum intended mass of ammonia stored on-site is 29,000 pounds.   
Worst-Case Scenario 
A complex model, SLAB, developed by the Lawrence Livermore National Laboratories was used for  realistic modeling results. 
The worst-case release scenario for chlorine dioxide would be the complete rupture of the 145,000-gallon storage tank.  The results of SLAB modeling showed that the worst-case chlorine dioxide release would have an impact radius of 16.7 miles, for an impact area of 876 square miles.  This area has a population of approximately 48,000, and includes the following: portions of seven counties; West Point; Urbana; Camp Peary; York River State Park; Mattaponi Indian Reservation; Pamunkey Indian Reservation; and State Prison Camp No. 16.  The more likely chlorine dioxide release scenario would have an impact radius of 0.18 miles and would have no public receptors. 
The worst-case release scenario for aqueous a 
mmonia would be complete rupture of the storage tank, and subsequent pooling of the released aqueous ammonia.  The results of the SLAB modeling showed that the worst case aqueous ammonia release would not leave the mill fence-line at less than 48 feet elevation and thus has no off-site receptors.  The more likely release scenario also has no off-site public receptors. 
Pollution Prevention Program 
Process Safety Information 
Process Safety Information (PSI) relating to the covered processes is divided into three categories: chemical hazards, process technology, and process equipment.  PSI relating to the chemical hazards is included in MSDS's, that are kept in readily accessible locations for all employees.  PSI relating to the process technology is generally indicated on process drawings, and is referenced in applicable Operating Procedures and Process Hazard Analyses.  PSI relating to process equipment is located in equipment files maintained by the Engineering Department. 
Hazard Analysis 
Process Hazard Analyses (PHAs) will be conducted on each covered process every five years, or when the process changes.  A PHA on the chlorine dioxide process was conducted in 1996.  A PHA was conducted on the ammonia process on May 13, 1999.   Future PHAs will be conducted by a team of knowledgeable individuals representing, at a minimum: operations, maintenance, engineering, and safety.  PHAs will address the hazards of the process, identification of previous incidents that had a likely potential for a catastrophic release, engineering and administrative controls applicable to the hazards,  
Operating Procedures 
Written operating procedures are maintained by the Department responsible for the process.  One copy of the Operating Procedures for the chlorine dioxide system is located in the Bleach Plant Control Room for ready access by the Bleach Plant Operators.  Operating Procedures on the Wastewater Treatment Plant (WWTP), and correspondingly the ammonia system, a 
re in development.   
St. Laurent provides on-the-job and/or classroom training to all employees responsible for operating each of the covered processes.  The trainees must demonstrate to the satisfaction of the supervisor that they possess the skills and knowledge to perform the required duties prior to being assigned the responsibilities.  Hazard Communication and Chemical Training are provided to each operations employee on an annual basis. 
Mechanical Integrity 
St. Laurent Paper Products West Point Mill maintains written instructions for inspection and testing of pressure vessels, storage tanks, piping systems (including valves), relief and vent system devices, emergency shutdown systems, controls, alarms, and interlocks that are part of the covered processes.  Tests and inspections follow applicable and acceptable codes and standards.  Inspection and testing is performed at a frequency called for by the applicable codes and more often if test data indicates it is warran 
ted.  Maintenance employees are trained on the acceptable work practices relating to the inspection and testing requirements.  Maintenance Procedures are housed in a database along with work orders.  Employees can generate work orders for repairs, inspection and testing.  Critical safety and environmental pieces of equipment are given top priority. 
Management of Change 
St. Laurent has a management of change policy and guidance procedures to implement a review process when any component of a process safety management system is modified, replaced or upgraded beyond replacement in kind components or design.   In addition, St. Laurent is ISO 9001 certified and quality control operating procedures for chlorine dioxide generation are documented and can not be amended without going through a document change proposal.  Quality control procedures reside on an electronic database available to operators and are tied into interlock protection mechanisms built into the process so operators can no 
t willingly make changes to quality control operating procedures without prior approval.   ISO quality  procedures for ammonia to be developed. 
Pre-Startup Safety Review 
St. Laurent has policy guidelines indicating the necessity to perform pre-start up safety reviews prior to implementing any change in a covered system.  Documentation is in place to indicate a pre-start up safety review was completed prior to implementing the latest major construction project that involved a covered process, i.e. the start up of the R8 Plant for the generation of chlorine dioxide. 
Compliance Audits 
St. Laurent Paper Products Corp.will conduct a compliance audit of the RMP program at the West Point Mill at least every five years.  The most recent audit of the RMP program in place at the Mill was conducted May 10 through 14, 1999.  The audit consisted of a records review, evaluation of on-site conditions, and interviews with employees.  The audit was conducted by an independent third-party consulting 
company and certified/qualified auditors were used.  Since St. Laurent is a Program 3 facility as defined by the RMP, the OSHA CPL 2-2.45a was used to assess the facility's compliance to the PSM requirements.  The auditing checklist was modified to include those elements required for inclusion in the RMP. 
Incident Investigations 
Incident investigations are conducted for each incident, which resulted in, or could have reasonably resulted in, a catastrophic release of a covered chemical.  Investigation teams are comprised of representatives from the Safety and Industrial Health (SIH) Department, the affected Operating Department, or any other affected group (i.e. contractors).  Investigations are initiated within 48 hours of the incident, or sooner.  Investigation reports contain, at a minimum: date of incident, description of the incident, investigation team members, factors contributing to the incident, and the recommended corrective actions.  Management reviews open corrective acti 
on items on a regular basis to ensure they receive a high priority for accomplishment. 
Employee Participation 
The St. Laurent Paper Products Corp. actively encourages employee participation at all levels of development, implementation, and maintenance of the RMP program at the West Point Mill.   
Hot Work Permit 
The St. Laurent Paper Products Corp. West Point Mill maintains an active Hot Work Program.  A permit system has been developed to cover such items as: appropriate fire protection, fire watch requirements, timeframe for work to be conducted, equipment to be worked on, the responsible individual for the work, and signatures/approval of the supervisor, operating department, and shift safety watchman. 
Contract personnel at St. Laurent Paper Products Corp. provides service in supplementing the existing work force during peak work load periods and in providing specialized expertise in servicing process components.  St. Laurent has requirements for the mill personnel 
that are supervising the contract work to provide safety orientation to the contractor and in some cases directly to the contractor's employees.  A safety manual for contractors is developed and distributed to all contractor groups and purchase orders contain contractual language that all incoming contract groups will abide by all applicable government safety and environmental regulations.  
Five-Year Accident History 
The St. Laurent Paper Products Corp., West Point Mill, has had no releases of RMP-covered chemicals which resulted in on-site deaths, injuries, or significant property damage or known off-site deaths, injuries, property damage, environmental damage, evacuations, or sheltering in place.  In preparation of this RMP, St. Laurent conducted an extensive review of previous incidents at the facility, to include a records review and personnel/contractor interviews. 
Emergency Response Program 
The St. Laurent Paper Products Corp. West Point Mill is considered to be a Non-Respon 
ding Facility under 40 CFR Part 68.90.  The Mill has coordinated emergency response issues with the West Point Volunteer Fire Department and the King William County Local Emergency Planning Committee.  Both entities have received the Mill's Comprehensive Crisis Management Plan which details how emergency notifications will be made, and contains detailed information on the facility (locations of hazardous chemicals, fire hydrants, etc.). 
Planned Changes to Improve Safety 
A compliance audit was recently performed for the covered processes at the West Point Mill. St. Laurent plans to correct the deficiencies identified during the audit by November 30, 1999.  Additionally, a PHA was conducted for the ammonia system on May 13, 1999.  St. Laurent plans to implement the recommendations of the PHA within the timeframes established during the assessment.
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