Appleton Papers Inc. - Spring Mill - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

The Appleton Papers Inc., Spring Mill  (Spring Mill), Roaring Spring, Pennsylvania pulp and paper mill has been in operation at its current location since 1865. Appleton itself was founded in 1907, and has earned a reputation as an innovative producer of carbonless and thermal papers used in a variety of commercial printing and specialty applications. Our 485-employee workforce is comprised of production, maintenance, engineering, technical, clerical, and management personnel.  Many of our employees have been with us for 25 years.  We are proud of our facility and the stability of our workforce. 
 
The Federal Accidental Release Prevention Requirements under the Clean Air Act Section 112(r), codified in 40 CFR Part 68, were written to help prevent the accidental release of extremely hazardous substances and to minimize the consequences of any such release.  All facilities with threshold quantities (TQs) of the listed regulated acutely toxic and flammable substances are subject to these p 
rovisions.  The listed substances include 77 toxic chemicals with TQs ranging from 500 lbs. to 20,000 lbs., while the 63 flammable substances all have a TQ of 10,000 lbs. 
 
Spring Mill has two chemicals, chlorine (Cl2) and chlorine dioxide (ClO2), that are currently used to bleach pulp.  These chemicals meet the toxic chemicals TQs, and thus, these must be included in a Risk Management Program for their respective operations.   The TQ for Cl2  is 2,500 pounds and the quantity contained in our process exceeds the TQ.   Plans are currently underway at the facility to eliminate the use of Cl2 by October, 2000. 
 
The TQ for ClO2 is 1,000 pounds and the quantity contained in our process exceeds the TQ.  As part of Spring Mill's commitment to the environment, in 1997 a 2 million dollar air pollution control system was installed as an upgrade to the former pollution control system to control process emissions of Cl2 and ClO2 at the Roaring Spring facility. 
 
The major Clean Air Act Section 112(r 
) ("112(r)") requirements with which Spring Mill must comply for use of Cl2 and ClO2 include: 
 
    -  Management System development and documentation, 
    -  Hazard Assessment for each affected process, 
    -  Prevention Program completion, 
    -  Emergency Response Program coordination, and 
    -  Risk Management Plan submittal.   
 
In addition, Spring Mill recognizes its responsibility under Section 112(r)(1) (the "general duty clause") to handle all extremely hazardous substances safely to prevent their accidental release and to minimize the consequences of any such release.  
 
MANAGEMENT SYSTEM 
 
Spring Mill has established a management system to oversee the implementation of its Risk Management Program responsibilities.  The management system is designed to help ensure that each element of our program is fully and effectively completed.  The Mill Manager accepts overall responsibility for the development, implementation, and integration of the program elements. 
 
HAZARD ASSESSMEN 

 
The Hazard Assessment portion of the 112(r) rule requires facility owners or operators to prepare "worst-case" and "alternative" release scenarios as appropriate to the operations.  From the release scenarios, facilities are then to determine offsite impacts using specified offsite consequence analysis (OCA) parameters for worst-case releases and more realistic parameters for alternative releases. 
 
As described by the U.S. Environmental Protection Agency (USEPA) the worst-case scenario involves the release of the largest quantity of a listed toxic substance that is estimated to generate the greatest distance in any direction to a toxic endpoint defined in the 112(r) regulation.  The probability that a worst-case release might occur or the possible causes of such a release are not considered. 
 
Also, the alternative scenario involves an accidental release that is "more likely" to occur than the worst-case release scenario.  Scenarios to consider include transfer hose splits or uncoupl 
ing, process piping failures, process vessel or pump cracks and failures, vessel overfilling and spill or overpressurization and venting through relief valves or rupture disks, and shipping container mishandling and breakage or puncturing leading to a spill. 
 
Spring Mill prepared a worst-case release scenario analysis and alternative release scenario analyses for Cl2 and ClO2, based on requirements given in the 112(r) rule. 
 
Our worst-case release scenario is the rupture of a single Cl2 railcar and the release of its entire contents. 
 
Alternative Release Scenarios: 
 
    -  For Cl2, we assumed a failure in the liquid chlorine piping between the railcar hook-up and the  
       vaporizer. Approximately 203 pounds of chlorine is released, which is the quantity contained in  
       piping.  Safety systems limit the release duration to 1 minute. 
 
    -  For ClO2, we assumed a failure in the chlorine dioxide solution piping between the supply pump and  
       the end use points in the bl 
each plant. Approximately 167 pounds of chlorine dioxide is released from  
       a height of approximately 20 feet. Manual safety systems limit the release duration to 5 minute.  The  
       release quantity is based on the supply pump's discharge capacity against almost zero head. 
 
The OCA of the chemical release was analyzed using appropriate air dispersion analysis and modeling techniques.  Air dispersion modeling is the use of a computer to simulate the spread of air pollutants.  Dispersion modeling can be used to determine the movement and concentration of toxic gases emitted from an accidental release.  
 
To determine the OCA of worst-case and alternative releases of Cl2 and ClO2, Spring Mill used the most-recent version of USEPA's RMP*Comp modeling software.  RMP*Comp is based on the USEPA's RMP Offsite Consequence Analysis Guidance (May 1996) that provides rough estimates of offsite impacts from evaporating pools of chemicals and vapor clouds. 
 
The OCA for our worst-case rele 
ase indicated that the Cl2 railcar rupture could impact an area with an estimated population of 130,000.  The OCA for our Cl2 alternative release scenario indicated that the Cl2 piping failure could impact an area with an estimated population of 80.  The area of impact was determined to be that area which could experience a Cl2 concentration above the Emergency Response Planning Guideline - Level 2 (ERPG-2).  According to USEPA documentation, this level represents the "maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action." 
 
The OCA for our ClO2 alternative release scenario indicated that the ClO2 piping failure could impact an area with an estimated population of 1,300.  The area of impact was determined to be that area which could experience a ClO2 concentrat 
ion above one tenth the "Immediately Dangerous to Life or Health" level. 
 
Populations were determined using Landview III, a computer program which incorporates U.S. Census data.  Population estimates for the two alternative release scenarios were refined based on a windshield survey of the area surrounding the mill. 
 
Should an accidental release occur that has potential for offsite consequences, plant-wide alarms will sound.  Trained plant personnel will take immediate and rapid action, and emergency shutdowns systems and procedures will be activated. 
 
Modeling Limitations and Assumptions 
 
Air-dispersion models are limited in their ability to accurately predict the impact of a chemical release.  Their limitations increase as the complexity of the topography surrounding the release site increases.  In general, the USEPA-recommended models used for the Spring Mill worst-case and alternative release scenarios have likely over-estimated the impact distance, because of several complicating  
conditions: 
 
    -  Surrounding the Cl2 rail cars, ClO2  storage tanks, and associated system piping are large industrial 
       buildings and structures.  These features disrupt and redirect air flow, but the models used assume  
       winds are steady and moving in a straight line. 
 
    -  Beyond plant property, buildings, structures, vegetation, and terrain features also serve to disrupt  
       and redirect air flow. 
 
    -  The chemicals emitted are assumed to have no reaction with the ground, other chemicals, or other  
       potential release conditions. However, it is likely that a release of Cl2 and ClO2 will deposit on the  
       ground and other surfaces as it disperses from a ground-level source. Cl2 and ClO2 may also react  
       with other chemicals or with fire.  In each case, the resulting impact distance is likely to be less than  
       the distance predicted by the models.  Note that a "synergistic effect" can occur from two chemicals  
       interacting 
during an accidental release.  Such synergism results when the effect of two substances  
       acting together "is greater than the sum of their individual effects." 
 
PREVENTION PROGRAM 
 
The Prevention Program ensures that regulated substances are safely stored, used, and handled.  In addition, if a chemical release occurs, the Prevention Program ensures that procedures and equipment are established to detect and mitigate the impact of such a release. The completion of Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) requirements essentially satisfies the 112(r) Prevention Program requirements for Cl2 and ClO2 in the Program-level 3 processes. 
 
Safeguarding the public from accidental releases through an effective Prevention Program is an important component of the 112(r) rule. Spring Mill has been diligent in its completion of the Program 3 Prevention Program requirements for: 
 
    -  Process safety information: Spring Mill compiled written proce 
ss safety information that is completed   
       prior to conducting any process hazard analysis required by the rule.  This written information  
       enables Spring Mill and the employees involved in operating the process to identify and understand  
       the hazards posed by those processes involving regulated substances.  Minimum information  
       includes hazards data such as that found on a Material Safety Data Sheet, technology information,  
       and equipment information. 
 
    -  Process hazard analysis:  A hazard evaluation has been performed by an experienced team to  
       identify, assess, and control the hazards involved in each of the covered areas.  The "what  
       if/checklist" and HAZOP methodologies were used for determining and evaluating the hazards of the  
       process.  The analysis addressed the hazards of the process, the identification of any previous  
       incident which had a likely potential for catastrophic consequences, engineering a 
nd administrative  
       controls applicable to the hazards and their interrelationships such as appropriate application of  
       detection methodologies to provide early warning of releases, consequences of failure of engineering 
       and administrative controls, stationary source siting, human factors, and a qualitative evaluation of a  
       range of possible safety and health effects of failure of controls. These analyses are being updated  
       and revalidated on a five year basis. 
 
    -  Operating procedures: Written procedures have been developed and implemented to provide clear  
       instructions for safely conducting activities involved in each covered process consistent with the  
       process safety information.  Elements that are addressed include steps for each operating phase,  
       operating limits, safety and health considerations, and safety systems and their functions.  Operating  
       procedures are readily accessible to employees who work i 
n or maintain a process.  These  
       procedures are reviewed as often as necessary to assure they represent current operating  
       practice.  In addition, safe work practices, applicable to employees and contractor employees, are  
       developed and implemented to provide for the control of hazards during a variety of plant operations. 
 
    -  Training:  Initial and refresher training is conducted as appropriate for each employee involved in  
       operating a process. Spring Mill ascertains and documents that each employee has received and  
       understood the required training. 
 
    -  Mechanical integrity: Spring Mill has developed a comprehensive mechanical integrity program that  
       applies to pressure vessels and storage tanks, piping systems, relief and vent systems and devices,  
       emergency shutdown systems, controls, and pumps in the covered processes.  Written procedures,  
       training for process maintenance activities, inspection and testing 
, correction of equipment  
       deficiencies, and quality assurance are all included in Spring Mill 's mechanical integrity program. 
 
    -  Management of change:  Written procedures have been established and implemented to manage  
       changes (except for "replacements in kind") to process chemicals, technology, equipment, and  
       procedures; and changes to other stationary sources that affect a covered process.  The rocedures  
       assure that the technical basis for the proposed change, the impact of the change on safety and  
       health, the modifications to operating procedures, the necessary time period for the change, and  
       authorization requirements for the proposed change are all addressed.  Appropriate employees and  
       contractors are informed of, and trained in, the change prior to startup of the process or affected part 
       of the process. Updates to the RMP are made if required by the nature of the change. 
 
    -  Pre-startup review:  A  
pre-startup safety review is performed for new covered processes and for  
       significantly modified covered processes at Spring Mill.  Such review confirms that prior to itroduction 
       of regulated substances to the process that construction and equipment is in accordance with design  
       specifications; safety, operating, maintenance, and emergency procedures are in place and  
       adequate; for new stationary sources, a process hazard analysis has been performed and for  
       modified stationary sources, management of change requirements have been met; and training of  
       each employee involved in operating a process has been completed. 
 
    -  Compliance audits: Spring Mill evaluates compliance with the provisions of this section at least every  
       three years to verify that the procedures and practices developed under the standard are adequate  
       and are being followed. Spring Mill 's compliance audit is conducted by a team consisting of outside 
 
       auditors, the Manager of Safety & Training and representatives from each covered process.  A report 
       of the compliance audit findings is developed. Spring Mill promptly determines and documents an  
       appropriate response to each of the audit findings, establishes a schedule for acting on the findings  
       and documents that deficiencies have been corrected.  The two most recent audit reports are  
       retained. 
 
    -  Incident investigation: Spring Mill will investigate each incident that results in, or could reasonably  
       result in a catastrophic release of a regulated substance.  This investigation shall be initiated as  
       promptly as possible, but not later than 48 hours following the incident.  An incident investigation team 
       will be established with appropriate personnel.  A report, which shall be retained for five years, is  
       prepared at the conclusion of the investigation.  A system has been established to promptly addres 
s  
       and resolve the findings and recommendations of the incident report, with documentation of  
       resolutions and corrective actions.  The report shall be reviewed with all affected personnel,  
       including contract employees where applicable, whose job tasks are relevant to the incident findings. 
 
    -  Employee participation: Spring Mill has developed a written plan of action regarding employee  
       participation.  Employees and their representatives are consulted with on the conduct and 
       development of process hazards analyses and on the development of the other elements of process  
       safety management in the 112(r) rule.  Employees and their representatives are also provided access  
       to process hazard analyses and to all other information required to be developed under the rule. 
 
    -  Hot-work permit: Spring Mill issues a hot-work permit for hot-work operations conducted on or near a  
       covered process.  The permit documents that 
the fire prevention and protection requirements in 29  
       CFR 1910.252(a) have been implemented prior to beginning the hot-work operations.  The permit  
       further indicates the date(s) authorized for hot work and identify the object on which the hot work is 
       to be performed. The permit is kept on file until the hot-work operations is completed. 
 
    -  Contractors: Spring Mill and contract-company owners and operators comply with the requirements  
       for contractors performing maintenance or repair, turnaround, major renovation, or specialty work on 
       or adjacent to a covered process. Contractor issues include, among other responsibilities, evaluation  
       of past contractor safety performance and programs, and informing contractors of known potential  
       fire, explosion, or toxic release hazards related to the contractor's work and the affected processes. 
       (Note that this part of the RMP requirements does not apply to contractors providin 
g incidental  
       services that do not influence process safety, such as janitorial work, food and drink services,  
       laundry, delivery or other supply services.) 
 
In summary, Spring Mill is prepared to prevent and mitigate accidental releases by safe process and equipment design, maintenance of equipment, operating safely, and auditing our operations. 
 
    -  Process and Equipment Design:  Backup safety systems, pressure relief valves, insulated vessels  
       and piping, local emergency shut down system, and an air pollution control scrubber system for Cl2  
       and ClO2, are used to help mitigate the potential for leaks from the affected processes and equipment. 
 
    -  Equipment Maintenance: Spring Mill has a preventive maintenance program in place along with work  
       planning, safety checks and reviews, periodic inspections, and qualified maintenance personnel. 
 
    -  Safe Operations: Operators are trained and certified.  Operations are continuously monitor 
ed by  
       computer. Written procedures are in place and followed by operators. 
 
    -  Operations Auditing:  Internal and Independent audits of the Cl2 and ClO2 systems are performed. 
 
FIVE YEAR ACCIDENT HISTORY 
 
Within the past five years, one RMP reportable accidental release occurred at Spring Mill.  On September 21, 1996 an accidental release of an estimated 35 pounds of chlorine from the bleaching process caused an injury to an employee working at the wet end of No. 2 Paper Machine.  The employee suffered from a sore throat and coughing following an exposure to the chlorine release.  The employee sought treatment from his family doctor following the exposure.  His physician treated the symptoms, and subsequently performed a chest x-ray to check for any serious or lingering effects of the chlorine exposure - none were indicated.  The employee's chlorine exposure did not result in any lost time or long-term health effects.  This injury was the only onsite impact of the release 
, and there were no known (or expected) offsite impacts. 
 
Two corrective actions were taken following the accidental release.  The direct cause of the release , a malfunctioning automatic valve, was repaired.  Also, two additional sensors were added to the mill's existing chlorine/chlorine dioxide detection and alarm system.  These sensors improve employee safety in the No. 2 Paper Machine wet end area, and allow quicker bleach plant operator response (shutdown of chemical feed, etc.) in the event of any future incidents of this nature. 
 
EMERGENCY RESPONSE PROGRAM 
 
An Emergency Action Plan is in place at Spring Mill and will be implemented as required for the purpose of protecting our employees, the public and the environment.  Spring Mill is also included in the Emergency Response Plan maintained by the Blair County Local Emergency Planning Committee (LEPC). 
 
Our Emergency Action Plan consists of training and planning to prepare for, prevent and mitigate the release of chemicals from  
the covered processes.  As it applies to our two covered processes and chemicals, the program makes use of our multi-point chemical detection and alarm system and our Bleach Plant operating personnel.  Bleach Plant personnel were chosen for this task for two primary reasons: 
 
    -  There are three Bleach Plant personnel in the mill at all times, and they work in the immediate vicinity  
       of the covered processes and chemicals. 
 
    -  They posses more training on, and working knowledge of, the covered processes than anyone else  
       in the mill. 
 
The plan dictates the nature and extent of our actions based on the magnitude of the release, as indicated by the detection system (for Cl2) or by use of an MSA "Kwik-Draw" Sampler (for ClO2).  All Bleach Plant personnel have been trained in the procedures called for in the Emergency Action Plan, as have all Pulp Mill Shift Supervisors. 
 
In addition to in-plant activities, the Emergency Action Plan contains provisions to notify ou 
tside personnel and obtain emergency response assistance as necessary depending on the type and severity of the event.  All necessary assistance (hazmat, fire, ambulance, police, etc.) would be contacted by dialing 911 and would be coordinated by Blair County 911 Emergency Operations Center. 
 
PLANNED CHANGES TO IMPROVE SAFETY 
 
Spring Mill is in the midst of making comprehensive changes to its bleaching process which will result in significant environmental and safety improvements.  Upon completion of these changes, currently planned for October 2000, we will eliminate the use of Cl2 in our bleach plant.  
 
We are committed to the safety and well being of our employees, our community and the environment.  To that end, we will continue to explore measures aimed at reducing the risks posed by our processes.
Click to return to beginning