Buckeye Lumberton, Incorporated - Executive Summary |
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BUCKEYE LUMBERTON, INC. MILL RISK MANAGEMENT PLAN EXECUTIVE SUMMARY 1. Corporate Prevention and Emergency Response Approach The Buckeye Lumberton, Inc. Mill is located in Robeson County in the city of Lumberton, North Carolina. Buckeye requires each of its facilities to develop and maintain accident prevention programs and an emergency response plan appropriate to the site. Each site is also responsible for regulatory compliance issues that apply to the site. Buckeye's corporate environmental and safety personnel provide guidance to the sites on environmental and safety issues, including accident prevention and emergency response planning. Additionally, they provide training assistance and also assist in budgeting and procurement of environmental, safety, and training services. 2. Description of Stationary Source The Buckeye Lumberton Mill is located at 1000 East Noir Street in Lumberton, North Carolina. The mill processes cotton cellulose from cotton linters. Chlorine is used in the pulp bleaching process. Liquefied chlorine gas is delivered by rail in 90-ton tank cars. Normally, two tank cars are spotted at the chlorine unloading station, which is located outside of the digester building. The tank cars are connected to the process by flexible hoses, which connect to 1-inch diameter liquid chlorine piping. The piping transfers the liquid chlorine to the vaporizers, where the liquid chlorine is heated by steam and transformed into gas. Gaseous chlorine is then metered through a rotameter through 1-1/2" Kynar-lined steel piping to the chlorine mixer, where it is mixed with the pulp stock. Although facilities are present to connect two cars to the process, usually only one tank car is connected during normal operation. This means that, while the normal chlorine inventory in the process is less than 90 tons, or 180,000 lbs. the maximum amount possible is 180 tons, or 360,000 lbs. Since the threshold quantity for chlorine is 2,500 lbs., this proces s exceeds the threshold and must comply with the RMP rule. The largest vessel in the process is one tank car, as described above. The chlorine system is equipped with several active mitigation devices. Each of the tank cars is equipped with an excess flow valve that limits the flow rate of chlorine to 32,000 lb./hr. They also have safety relief valves set at 375 psi. The liquid chlorine process piping is equipped with an expansion chamber and rupture disk, which would open if the system pressure reached 270 psi. Similarly, the vaporizer is protected by a rupture disk and safety relief valve that would relieve chlorine gas into the scrubber if the vaporizer pressure exceeded 270 psi. The chlorine process is also protected by ambient chlorine monitors that are interlocked to audible and visual alarms in the chlorine unloading area and at the bleach plant operator's control panel. If the chlorine concentration in the unloading area exceeds 5 ppm, the bleach plant operators are n otified. At 10 ppm, the audible alarm will warn all Mill employees of the release. 3. Description of the Worst Case and Alternative Release Scenarios The Worst Case release scenario is the rupture of one tank car, releasing 180,000 lbs. of chlorine gas over a ten-minute period. Under worst case weather conditions, the chlorine gas could travel 25 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .0087mg/L), based on the WWTP Guidance lookup tables. The Alternative Release Scenarios is a leak at a rate of 153.3 lb./min. from a break in the liquid chlorine piping. Then, considering active mitigation of the employee's response to audible chlorine detectors and the newly installed Powell unit that would stop the flow of chlorine within one minute, only a total of 153.3 lbs. of chlorine would be released. Under normally expected weather conditions, and the active mitigation previously mentioned, the chlorine g as could travel 0.6 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .0087 mg/L), based on the WWTP Guidance lookup tables. 4. Prevention Program This process exceeds the chlorine threshold quantity for the OSHA Process Safety Management (PSM) Standard, 1910.119, and is therefore subject to the PSM requirements. For RMP compliance purposes, this places the Buckeye Lumberton Mill chlorine process in the Program 3 level. The Lumberton Mill will use its PSM program as the required Program 3 Prevention Program. The Buckeye Lumberton Mill has a program in place to comply with the OSHA Process Safety Management Standard, 29 CFR 1910.119. The PSM Program was developed in 1992 for the chlorine process. An Operations Team was set up to manage the PSM Program. The PSM Program includes a preventative maintenance plan, which requires all chlorine equipment to be periodically inspected and serviced. This will ensure that the equipment remains in good operating condition and will minimize the probability of accidents due to faulty equipment. In developing the PSM Program, the Buckeye Lumberton Mill also developed written operating procedures for the chlorine process. These procedures cover all phases of operation and include information on safety devices. These procedures will be used to train all operators and mechanics that work on the chlorine process to ensure consistency of operation and minimize human error. In addition, all employees who work on the chlorine system are trained in safe work practices and emergency evacuation and response. Other components of the prevention program include collection and review of all equipment information, the development of updated Piping & Instrumentation Diagrams (P&IDs), and the correction of any equipment design deficiencies found. These actions will ensure that the equipment meets all standards and that accurate equipment information will be avail able when needed. The staff also performed a PHA of this process. Other PSM procedures, including Management of Change, Pre-Startup Safety Review, Compliance Audits, and Incident Investigation are also part of the program to ensure continued safe operation and prompt correction of deficiencies. The PSM Program receives full support of plant management and involvement of employees at all levels. 5. Accident History The Buckeye Lumberton Mill facility has had no accidental release of chlorine in the past five years. 6. Emergency Response Program The Buckeye Lumberton Mill has an Emergency Response Program in place. The program complies with 29 CFR 1910.38. The site also has some internal emergency response capability. The current plan has been coordinated with the Lumberton Fire Department and Hazardous Materials Response Team, and the Regional Local Emergency Planning Committee. Notification is made locally by dialing 911, and by notifying North Carolina Division of Emergency Management at (800) 858-0368. |