Stone Container Corporation, Ontonagon Mill - Executive Summary |
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EXECUTIVE SUMMARY STONE CONTAINER CORPORATION ONTONAGON MILL Corporate Policies There is a written CORPORATE SAFETY MANUAL. This manual gives the detail requirement that must be taken by each facility to develop its safety program. The manual describes senior management's commitment to safety. The safety policy assigns the responsibility and authority to the management team at each facility for conducting an effective safety program. There is a written Corporate CHEMICAL HAZARD COMMUNICATION MANUAL. The manual describes how each facility is to develop its own local Hazard Communication program. The manual assigns the responsibility and authority to the management team at each facility for developing an effective Hazard Communication program. Ontonagon Mill Policy It is the policy of Stone Container Corporation, Ontonagon, Michigan to conduct its business to insure the likelihood of a release of CHLORINE or AMMONIA is minimized and if there is a release the offsite consequence will be reduced. To accomplish this the equipment associated with the chlorine and the ammonia systems are maintained according to good engineering and maintenance practices. Our operating and maintenance employees utilizing the chlorine and ammonia systems have been trained in the safety requirements of the two materials. Description of Ontonagon mill operation Stone Container Corporation's Ontonagon facility produces corrugating medium on two paper machines. The mill produces the pulp for the corrugating medium from recycle fiber and a carbonate-based semi-chemical pulping process. Description of RMP Systems Chlorine The mill has a high rate activated sludge wastewater treatment system. This wastewater treatment system is sensitive to stressors from the mill operations. Sometimes the stressors result in an imbalance in the microbiological system, generating filamentous organisms. These filaments in turn create poor settling in the final effluent. To control the filaments (settling rat e) chlorine is required. Chlorine is used from one ton cylinders and is injected into the wastewater treatment process as needed to control the undesirable microorganisms. The Ontonagon mill uses water from Lake Superior for all its process water needs. The intake water is treated with chlorine to prevent biological fouling of process equipment. Chlorine is used from one ton cylinders and is injected into the intake water as needed to prevent equipment fouling. There will be a maximum of five cylinders connected at any time. Four for the wastewater process and one for the intake water process. This number was determined by the need for chlorine. Each of the connected cylinders is a separate but identical process. There could be 20 cylinders (40,000 pounds) on site, connected and in storage, at a time. There are no more than five cylinders connected at any one time and each is a separate process. In this arrangement a problem as defined by the worst-case release scenario will only inv olve a single cylinder. Ammonia In an activated sludge wastewater treatment system nutrients are required for the microorganisms to properly digest the contents of the waste stream. Nitrogen is one of the required nutrients and it is supplied to the process by feeding ammonia. The storage tank has a total volume of 17,600 gallons. The maximum volume in the tank is controlled to 15,000 gallons of a 30 % solution of ammonia in water. Worst-case release scenario Chlorine The maximum quantity of chlorine that will be in the largest container on site at any one time will be 2,000 pounds. There can, however, be five of these containers in service at a time. The arrangement is that each cylinder is a separate but identical process and a worst-case release of any one cylinder will not cause an effect on the other cylinders. This will result in the worst-case release of 2,000 pounds or 200 pounds per minute. This will result in a distance to the endpoint is 3.0 miles using the Model Aloha 5. 2.1 There are no administrative controls on chlorine inventory in use at the facility. There are no passive control measures in place at the facility. Ammonia The maximum quantity of ammonia that will be in the largest container on site at any one time will be 33,608 pounds. Administrative Controls in place restrict the quantity of ammonia solution in the 17,608-gallon to 15,000 gallons. There are instructions to never fill the tank above the level of 15,000 gallons. Documentation of the ammonia tank level is recorded on the WWTP daily log sheet. There are instructions that the ammonia storage tank level must be below the 45-inch mark before ammonia is ordered. This level provides for the introduction of a full truckload of ammonia without exceeding the limit of 15,000 gallons (85 inch) control point. The ammonia tank has a passive containment system around it. This passive containment system consist of a concrete wall that has a surface area of 1041 square feet and will contain all o f the ammonia solution with an excess volume of 805 cubic feet Using the EPA's May 24 1996 Offsite Consequence Analysis Guidance Document section 3.3, equation # 7 the release rate will be 37.9 pounds / minute of ammonia. This will result in a distance to the endpoint of 1046 yards using the Model Aloha 5.2.1. Alternative release scenario Chlorine A cylinder is in service with a regulator in place. The regulator is hit causing the regulator to break off. This will result in a leak equal to the maximum withdrawal rate from the cylinder. Release quantity of chlorine will be 23.4 pounds or 0.39 pounds / minute and last for 60 minutes. The distance to the endpoint using the model ALOHA 5.2.1 is 125 yards. Under all conditions of alternative release scenarios there will be no offsite impact from the chlorine system. Ammonia The hose used by the delivery truck to fill the ammonia tank breaks and releases the capacity of the truck pump. The amount of material released is 4145 pounds of so lution or 1244 pounds of ammonia. Based on EPA lookup tables the release rate will be 60.6 pounds / minute. The distance to the endpoint using the model ALOHA 5.2.1 is 196 yards. Under all conditions of alternative release scenarios there will be no offsite impact from the ammonia system. During a filling operation of the ammonia tank there is always a trained driver in attendance and would require only five minutes for the truck pump to be stopped and the valve closed. There will be a release to the atmosphere for 20 minutes from the puddle formed. Five-year accidental release history There have been no RMP releases of Chlorine or Ammonia within the five years of 1994 to date. Accidental release prevention program Chlorine The mill has an OSHA Process Safety Management program in place for chlorine. This PSM program meets the RMP requirements for a release prevention program. The Michigan Department of Consumer and Industry Services, Division of Occupational Health conducted an audit of the mill's PSM program on May 12-14,1998. There were several recommendations and corrections suggested and all have been addressed. The PSM program was approved as meeting the PSM requirements. Ammonia An OSHA PSM program is not required for this process, as ammonia is not on the list of materials requiring a PSM program. The mill, however, has taken steps to use the knowledge and practices from the PSM program to insure the safety of its ammonia process. Our operators are trained in ammonia safety and correct operating procedures. The operators conduct inspection rounds of the WWTP, including the ammonia system, to insure the WWTP is operating correctly. Any concerns, including safety of the ammonia process, are reported to the maintenance department so corrections can be made. Our maintenance employees are trained in ammonia safety and how to complete the required work. General prevention activities The mill has a staff of experienced and knowledgeable employees that receive refresher safety training annually. Each employee working with chlorine or ammonia has experience in the proper use of the personnel protective equipment, including the use of SCBA's, necessary for them to approach a leak and determine its cause and magnitude. The employees are trained to close the cylinder valves if this will stop the release otherwise the are to call the local fire department hazardous response team. Any event involving a release of chlorine or ammonia is investigated and a root cause determined. Emergency response program Stone Container Corporation, Ontonagon employees will not respond to the onsite cause of an emergency release of chlorine and ammonia. In the event of an emergency release which could have a possible offsite consequence from the release of chlorine or ammonia the Village of Ontonagon Fire Department will be notified by calling 884-2500. The Ontonagon Fire Department has been informed of the storage of one ton cylinders of chlorin e and the storage tank containing a 30% ammonia solution and they have a copy of this Risk Management Program. These two sources, chlorine and ammonia, are known by and are a part of the Ontonagon County's, LEPC, community emergency response plan. The WWTP facility has been used, by the local fire departments Hazardous Response Team to train and test their response efforts. The mill has an Emergency Response Team that is trained in emergency response procedures and in the implementation of the mill Emergency Operations Plan. This team is not trained to respond to a worst-case release of chlorine or ammonia. The Ontonagon Fire Department is trained and has the equipment required, supplied by the mill, to respond. The village of Ontonagon Fire Department is the first call for help if there is a release of chlorine or ammonia. The mill has provided equipment |