EPA issues RMP citations @ paper mill (ClO2 & $32K)

It’s never a good sign when the EPA inspector is in the process and the operator’s personnel detector goes into alarm and the worried inspector is told… it was typical for the alarm to sound during sampling.  This led the inspector to inquire about this level of exposure for a repeated task such as sampling and that opened the door to three (3) SOP findings!

Respondent operates a pulp bleaching mill that has on–site for use, 19,022 pounds of chlorine dioxide.  The process is an RMProgram level 3 covered process, which stores or otherwise uses chlorine dioxide in an amount exceeding its applicable threshold of 1,000 pounds.  On August 13, 2019, the EPA conducted an on–site inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent’s compliance with the RMProgram requirements and the implemented recognized and generally accepted good engineering practices (RAGAGEP) for its covered process at its Facility.

1. At the time of the inspection, during the field walkdown, discrepancies were found with a piping and instrument diagram (P&ID);
   1. outlet piping from the chlorine dioxide storage tank had multiple extra bleeder valves after valve V56–0446 that were not denoted on the associatedP&ID.
2. At the time of the inspection, the Facility did not demonstrate that the written operating procedures addressed precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment.
3. At the time of the inspection, while in the processing area near the chlorine dioxide storage tank, the chlorine dioxide alarm sounded. The EPA inspector was informed it was typical for the alarm to sound during sampling.
4. During the sampling process, the sampler was observed wearing safety glasses, hearing protection, gloves, and a hard hat. The sampler was not wearing extra respiratory protection for increased levels of exposure. The standard operating procedure (SOP) for sampling states, “required PPE that includes: gloves, hard hat, safety glasses, earplugs, steel toe footwear, ClO2 monitor, H2S monitor, and escape respirator. If there is not enough draft being pulled on the sample pots, a full–face respirator is required while catching generator solution or ClO2 analyzer samples.”
5. The SOP called for a full face respirator to be used during sampling, if there is not enough draft on the sample pots, but this procedure was not being implemented at the time of the inspection because the sampler was observed without a full face respirator while there was not enough draft on the sample pots, as evident by the chlorine dioxide alarm.
6. At the time of the inspection, the printed version of the operating procedure available for employees to use was revision 4, dated 8/7/2015. The facility had updated the operating procedures on September 13, 2018 and called the 2018 operating procedures Version 5. Version 5 of the operating procedures was not the printed version of the operating procedures available to employees on the date of the EPA 2019 inspection.

1. Failed to compile written process safety information for the equipment in the process which includes a P&ID as required by 40 C.F.R. §68.65(d)(1)(ii);
2. Failed to implement, in the written operating procedures, precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment as required by 40 C.F.R. § 68.69(a)(3)(ii); and
3. Failed to make the operating procedures readily accessible to employees who work in or maintain a process as required by 40 C.F.R. §68.69(b).

Respondent consents to the payment of a civil penalty, which was calculated in accordance with the Act, in the amount of $32,844.

CLICK HERE for the CAFO

Consent Agreement and Final Order, Docket No. CAA–04–2020–0200(b)Page 5of 13implementing regulations, and that all violations alleged herein, which are neither admitted nor denied, have been corrected;e.waives any right it may have pursuant to 40 C.F.R. § 22.8 to be present during any discussions with, or to be served with and reply to, any memorandum or communication addressed to EPA officials where the purpose of such discussion, memorandum, or communication is to persuade such official to accept and issue this CAFO;andf.agrees to comply with the terms of thisCAFO.20.In accordance with 40 C.F.R. § 22.5, the individuals named in the certificate of service are authorized to receive service related to this proceeding and the parties agree to receive serviceby electronicmeans.VII.TERMS OFPAYMENT21.Respondent consents to the payment of a civil penalty, which was calculated in accordancewith the Act, in the amount of $32,844 which is to be paid within thirty (30) calendar days of the Effective Date of this CAFO.22.Payment(s)