Westvaco Luke Mill - Executive Summary

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Westvaco's Luke Mill in Luke, Maryland, has been a proud and responsible member of the Allegany County community since 1888.   During this time, the Luke Mill has safely converted millions of tons of pulp wood into Fine Paper.  Operations at the Luke mill include debarking, chipping, pulping, bleaching, paper coating production, paper making, and paper finishing.  In addition to producing paper, the Luke mill operates three power boilers to produce steam and electric for use at the facility, and operates a water filtration plant to produce drinking water for the mill and the town of Luke.   
On June 20, 1996, the Environmental Protection Agency published the final rule for its Risk Management Program (RMP).  This regulation is designed to assist facilities and communities in their efforts to reduce the number and severity of serious chemical accidents.  The EPA formally developed a final list of regulated substances, with threshold storage quantities established for each substance. 
 This list includes 77 toxics and 63 flammable substances. 
Only two regulated substances are handled at the Luke mill in excess of their applicable threshold quantities.  Chlorine dioxide has been used at the mill since 1958.  It is produced at the Luke mill's new (1997) state of the art R8 Chlorine Dioxide Plant and is used to bleach the raw pulp.  Chlorine is used at the Water Filtration Plant to disinfect drinking water for the mill and for the residents of the town of Luke.  
Each facility which stores a chemical above its threshold quantity is required to prepare one worst-case release scenario analysis.  In addition, an alternative release scenario must be prepared for each chemical.  By using the information from these Hypothetical Release Scenarios, the Luke mill, working with the Local Emergency Planning Committees and local fire departments, has developed emergency response plans and training procedures. 
The worst case release scenario is for chlorine dioxide and consists  
of the catastrophic failure of a storage tank and associated piping with the release of 156,742 gallons of chlorine dioxide solution spreading within a diked area.  This Hypothetical Release would result in chlorine dioxide concentrations that equal or exceed the EPA's designated endpoint concentration, from the tank out to a distance of 15.343 kilometers. The environmental and public receptors include a state forest, wildlife management area, public recreation areas, residences, schools, hospitals, commercial facilities, office buildings, and churches.  
The alternative release scenario for chlorine dioxide consists of the release of 1,530 gallons of chlorine dioxide solution, as a result of a pipeline breakage downstream of a storage tank. This Hypothetical Release would result in chlorine dioxide concentrations that equal or exceed the EPA's designated endpoint concentration, from the point of release out to a distance of 1,315 meters.  The following public receptors are within this 
distance from the point of release: residences, schools, commercial facilities, office buildings, recreation areas, churches, and a medical clinic. 
The alternative release scenario for chlorine consists of the release of 0.8 kilograms of chlorine over a duration of five minutes from the breakage of a pipeline due to a crane dropping a cylinder on a common line connected to three chlorine cylinders in the chlorine storage building.  This Hypothetical Release would result in chlorine concentrations that equal or exceed the EPA's designated endpoint concentration, from the point of release out to a distance of 15 meters.  There is no population, and there are no environmental or public receptors within this distance from the point of release. 
Although the Risk Management Regulations are new, the Luke mill has been in full compliance with the Process Safety Management requirements under 29 CFR Part 1910.119 for preventing or minimizing the consequences of catastrophic releases of chlori 
ne and chlorine dioxide since the early nineties.  In fact, the Luke mill has always been a leader in operational safety.  Over the past ten years we have implemented a multitude of programs designed to decrease the likelihood of these Hypothetical Release Scenarios.  These programs include extensive operator training, mechanical integrity procedures, written standard operating procedures, and management of change procedures.  We have also developed and implemented safe work practices such as lockout/tagout, confined space entry permits, hot work permits, and control over workplace entrances.  These programs were not only written by management personnel, but everyone including operators, contractors, and engineers was involved.  The Luke mill also has its own volunteer fire squad, rescue squad, and hazardous materials team.  These groups and their associated equipment may be used in the event of an accident involving chlorine or chlorine dioxide.     
Within the past few years the Luke 
mill has made operational changes which have had a direct impact on the Risk Management Plan.  Strict storage limitations have been placed on certain chemicals to guarantee amounts on-site remain small in quantity.  Secondary containment has been placed around the chlorine cylinders and chlorine dioxide tanks.  In addition the Luke mill has eliminated chlorine bleaching, an act which decreases the amount of chlorine stored on-site by approximately 360 tons. 
Over the past five-year period, 6/1/94 to 5/31/99, the Luke mill had one incident which involved chlorine or chorine dioxide.  On October 30th,1996, upset operating conditions at the Solvay chlorine dioxide generator caused a "designed loss of containment."  Four contractors inhaled chlorine dioxide gas and were taken to the hospital.  Three were released the same day and one was kept in the hospital for several days.  Since this time, the Luke mill has revised the contractor training and replaced the Solvay generator with the R8  
Process generator.  This new generator operates at a much higher vacuum, which causes greater operating stability, thus reducing the chances for a "designed loss of containment." 
The Luke mill maintains as part of its Process Safety Management requirements an emergency action plan in accord with 29 CFR 191.38(a).  The emergency response program includes the following items: 1) procedures for informing the public and local emergency response agencies about accidental releases, 2) documentation of proper first-aid and emergency medical treatment to treat accidental human exposure, 3) procedures for emergency response after an accidental release of a regulated substance, 4) procedures for the use of emergency response equipment and for its inspection, testing and maintenance, 5) training of all employees in relevant procedures, and 6) procedures to review and update the emergency action plan, as appropriate. 
Safety for the community, as well as employees, has been given top priority by  
the Luke mill.  By implementing safety procedures and installing and maintaining safety equipment, the Luke mill has been able to establish a good safety record.  In the event of an accident, the mill has a fire squad, rescue squad, hazardous materials team, and an emergency response program to deal with the situation.  Westvaco's Luke mill has been a proud and responsible neighbor for more than 100 years; we plan to continue that tradition.
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