Boise Cascade Wallula Mill - Executive Summary
Per the requirements of Section 112(r) of the Clean Air Act Amendments of 1990 as codified in Title 40 of the Code of Federal Regulations (CFR) Part 68, this Risk Management Plan (RMP) is submitted to the United States Environmental Protection Agency (U.S. EPA) in a timely manner for Boise Cascade Corporation's (Boise Cascade's) pulp and paper mill in Wallula, Washington. The Wallula mill handles one or more regulated substances listed in Appendix A of Part 68.
STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED
Boise Cascade owns and operates a pulp and paper mill located in Wallula Washington, which is an existing major stationary source per the requirements of Title V of the Clean Air Act Amendments of 1990. The regulated substances handled by this facility are chlorine and chlorine dioxide, which are considered hazardous by the United States Environmental Protection Agency (U.S. EPA).
The Wallula mill uses the kraft and neutral sulfite semi-chemical (NSSC) pulpi
ng processes to produce pulp and paper from wood chips. Chlorine and chlorine dioxide, both regulated substances under the Risk Management Program, are used at the mill to bleach the pulp. Paper, the final product of the mill, is made from bleached pulp.
Chlorine is brought onto the mill site by railcar; up to four railcars of chlorine may be present at the mill at any time. The maximum amount of chlorine that is stored at the site is 720,000 pounds.
Chlorine dioxide is generated at the mill using the R-8 generation process. Chlorine dioxide is stored in an aqueous solution in two 272,000 gallon storage tanks. The maximum amount of chlorine dioxide that is stored in the tanks is 52,220 pounds.
Boise also stores the following listed chemicals on-site, in quantities below the RMP thresholds for each process: aqueous ammonia, propane, hydrochloric acid, acetylene, and Chlorine for process water treatment.
ACCIDENTAL RELEASE PREVENTION
Boise Cascade takes a systematic, proact
ive approach to preventing accidental releases of hazardous chemicals. The Wallula mill's management systems, which cover the chlorine and chlorine dioxide processes, address each of the following key features of successful prevention programs.
1. RMP Management System
A management system was established to identify responsibility for the development, implementation, and maintenance of the Risk Management Program. The RMP is required to be updated every five years, or any time a covered process modification involves Process Hazard Analysis.
The Risk Management Program development, implementation, and maintenance is the responsibility of the following team members:
Dennis Ross, RMP Manager, Environmental Department
Ken Arnold, Hazard Assessment Coordinator, Power and Recovery Department
Kris Lagers, Emergency Response Coordinator, Power and Recovery Department
Karen Caddey, Communications Coordinator, Public Affairs Department
Ken Arnold, Prevention Program Coordinator, Power an
d Recovery Department
The RMP Manager has the responsibility for the administration of the program.
2. Process/Chemical Safety Information
A comprehensive chemical data base has been assembled to include regulatory reporting, action thresholds, health hazard and chemical exposure limitations, and list the physical properties of each regulated substance. This information was compiled from numerous sources for easy access by a reader seeking data on these substances.
Process safety information was carefully assembled for the chlorine and chlorine dioxide processes. Process specifications on each process are collocated in one area for easy reference. Detailed specifications on such items as maximum intended inventory, safe upper and lower temperatures, and codes and standards used to design, build and operate the processes are on file at the mill.
3. Process Hazard Analysis
A hazard analysis was conducted for each of the covered processes. The hazard analysis team was made up
of representatives from plant management, maintenance experts, process and project engineers, and process operating personnel. The hazard review utilized the Hazard and Operability Study (HAZOP) approach, which was supplemented by the completion of design checklists.
4. Operating Procedures
A rigorous detailed Standard Operating Procedures (SOP) program has been developed, and is stringently reviewed and adhered to by all employees at the Wallula Mill. The SOP provides system descriptions, specifications, and operating procedures for the chlorine and chlorine dioxide operating systems. The SOP covers startup; shutdown; normal, abnormal, and emergency operation; maintenance; and troubleshooting procedures.
5. Operator Training Program
Boise utilizes experienced personnel to train employees to safely and effectively perform their assigned tasks. The Wallula training program for the covered processes includes both initial and refresher training courses, a general overview of the
process, the properties and hazards of the substances in the process, and a thorough review of the standard process operating procedures and safe working practices. Oral reviews and written tests are given to ascertain if the empoyee understands the materials.
6. Mechanical Integrity Program
An experienced and well-trained maintenance staff maintain the mechanical integrity of the process equipment to minimize and prevent equipment failures that could endanger workers, the public, and/or the environment. The mechanical integrity program covers inspections and testing to identify equipment deterioration or damage before equipment failure. The elements of this program include:
a. Specifications for inspection and testing of process equipment
b. Specifications for replacement parts and equipment
c. Procedures for inspecting, testing, and maintaining process equipment
d. Procedures for safe work practices such as lockout/tagout, hot work permits, and confined space entry
intenance personnel training procedures
f. Documentation of maintenance activities
7. Management of Change
The Wallula mill's management of change program requires approval by the management team for all proposed changes to chemicals, equipment, and procedures for the chlorine and chlorine dioxide processes to ensure that the change does not affect safe operations. Process changes that are determined to be replacement in kind are allowed without completing a full management of change procedure. All other changes must be confirmed through the full management of change procedure to help ensure that inadvertent consequences of process changes are prevented, safety consequences of changes are addressed, and affected employees are notified of the changes.
8. Pre-startup Review
Boise Cascade performs a safety review of a new or modified process at the Wallula facility before it is activated for operation to ensure the process is safe to operate. To ensure that the appropriate issue
s have been addressed, a pre-startup review checklist is complete to document the review.
9. Internal Compliance Audits
Internal compliance audits are conducted every three years to verify compliance with the programs and procedures contained in the Accident Prevention Program. Boise Cascade assembles an audit team that includes personnel knowledgeable in the RMP rule and in the process. This team evaluates whether the prevention program satisfies the requirements of the RMP rule and whether the prevention program is sufficient to help ensure safe operation of the process. The audit results are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented.
10. Incident Investigations
All incidents are investigated at the Wallula mill that could have resulted in an injury to personnel, the public, or the environment to ensure that similar situations can be prevented. Boise Cascade trains employees to recognize unsafe situation
s and report the incident for follow-up investigation. An investigation team is assembled and an investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendations resolved, and appropriate process changes or enhancements are implemented.
11. Employee Participation
Boise Cascade has developed a written program for the covered processes to ensure that safety concerns of employees are addressed. The facility personnel are encouraged to actively participate in the prevention program activities for all the processes. Employees are consulted and informed about all aspects of the RMP rule prevention program including process hazard analyses and operating procedures.
12. Hot Work Permits
Boise Cascade has established a hot work program to manage spark or flame-producing activites that could result in fires or explosions at the mill. A hot work activity requires a hot work form be filled and properly signed by the appropriate
supervisor before work commences. Training in the hot work permit procedures is included in the Wallula mill's safety training requirements.
Boise Cascade has established a contractor safety training program that ensures that all contract work is performed in a safe manner. The Wallula facility provides safety training for all contractor personnel on the hazards of the process, emergency response procedures, safe work practices, and personnel protection. The contractor and their employees are required to have this training before beginning work at the facility. All the contractor training is documented by the safety department.
WORST CASE AND ALTERNATIVE RELEASE SCENARIOS
The RMP rule requires that Boise Cascade provide an off-site consequence analysis for the worst-case release scenarios and alternate release scenarios for the facility. The only covered processes at the Wallula mill are the Program 3 covered processes for chlorine unloading and storage, and
chlorine dioxide generation and storage. Therefore, Boise Cascade must submit a single worst-case release scenario for all RMP covered substances at the mill, and an alternate release scenario for each covered processes.
The worst-case scenario for the Wallula mill is a gaseous release of the entire contents of a 90 ton chlorine railcar over a 10-minute period. The release rate for this scenario is 18,000 pounds of chlorine per minute. The release was modeled using the DEGADIS dispersion model for dense gas releases. Under this scenario, the maximum distance to the toxic endpoint concentration (8.7 mg/m3) is 10.62 miles. Approximately 4,500 people live within this distance of the mill, as estimated using the U.S. Census Bureau's LANDVIEW3 software. Additionally, several schools, several industrial facilities, and the Columbia River are located within this distance.
The alternative release scenario for the chlorine unloading and storage process is a 30 minute release from the r
upture of a 1-inch diameter hose used to unload the chlorine from the railcars. The amount of chlorine released under this scenario is 1,922 pounds per minute, resulting in a total release of 57,646 pounds of chlorine. The release rate is based on an engineering estimate using the diameter of the hose and the flow coefficient for the rupture. The release was modeled using the DEGADIS dispersion model for dense gas releases. The maximum distance to the toxic end point concentration (8.7 mg/m3) is 6.30 miles. Approximately 890 people live within this distance of the mill, as estimated using the U.S. Census Bureau's LANDVIEW3 software. Additionally, several industrial facilities, and the Columbia River are located within this distance.
The alternative release scenario for the chlorine dioxide generation and storage process is a 30 minute spill from the rupture of an 8-inch diameter pipe used to transfer chlorine dioxide from one of the two storage tanks to the bleach plant. The am
ount of aqueous chlorine dioxide released under this scenario is 500 gallons per minute, at a chlorine dioxide concentration of 11.5 grams per liter (g/L). The total amount of chlorine dioxide released is 1440 pounds. The chlorine dioxide concentration is based on the acceptable operating range of 9.5 to 11.5 g/L. The release rate from the liquid pool was modeled using the Kawamura-Mackay evaporation model, modified to account for the changing concentration of chlorine dioxide in the remaining liquid. The release was then modeled using the DEGADIS dispersion model for dense gas releases. The maximum distance to the toxic end point concentration (2.8 mg/m3) is 1.66 miles. Approximately 21 people live within this distance of the mill, as estimated using the U.S. Census Bureau's LANDVIEW3 software. Additionally, the Columbia River is located within this distance of the release.
FIVE-YEAR ACCIDENT HISTORY
Boise Cascade keeps records of all significant accidental chemical release
s that occur at the Wallula mill. This history indicates a good record of accidental release prevention over the past five years. No releases of Chlorine or Chlorine Dioxide have occurred from Boise Cascade that have resulted in consequences of interest (i.e., deaths, injuries, or significant property damage on site; or known deaths, injuries, evacations, sheltering-in-place, property damage, or environmental damage off site). The Wallula Mill continues to stress the importance of safety and achieving no reportable incidents within its next five-year accident history.
EMERGENCY RESPONSE PROGRAM
In addition to the prevention program, Boise Cascade maintains a written integrated emergency response plan to safely respond to accidental releases of hazardous substances. The plan identifies personnel roles at the mill for handling the emergency, provides emergency recognition and prevention information, includes procedures for evacuation area shutdowns, includes important community res
ponse information, and provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, Boise Cascade coordinates the plan with the community emergency response plan by covering the following procedures:
a. Informing the local fire department and the public concerning accidental releases that could reasonably result in off-site consequences
b. Providing proper first aid and emergency medical treatment to accidental human exposure to hazardous substances
c. Controlling and containing accidental releases of hazardous substances
d. Inspecting and maintaining emergency response equipment
e. Reviewing and updating the emergency response plan
The Wallula mill maintains a trained emergency response team trained to the 24-hr Technician Level to initiate these emergency procedures if an incident should occur. All the facility personnel are trained in evacuation procedures. Drills are conducted in
emergency response procedures, including coordinated drills with the local fire department. The plan has been communicated to the local emergency response officials and the local fire department.
PLANNED CHANGES TO IMPROVE SAFETY
Boise Cascade strives to continue improving the safety of the Wallula mill's processes through employee accountability and responsibility by working safely, following procedures, encouraging employee safety suggestions, and follow-up investigations on safety related incidents.
Additionally, Boise Cascade is on a schedule to eliminate the use of chlorine in the bleaching process at the mill, thereby eliminating the use of chlorine railcars. This change would greatly reduce the potential consequences of an accidental release at the mill.
For all covered processes, the undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the other information submitted in this RMPlan is true, ac
curate, and complete.
RMP DATA ELEMENTS
The following pages present additional information about our risk management program that EPA's RMP rule has asked us to provide. This information is categorized as follows:
* Offsite consequence analysis
* Five-year accident history
* Program 3 prevention program
* Emergency response program