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Ketchikan Pulp Company Pulp Mill, Ketchikan, Alaska

Standard Operating Procedures

During performance of a PSM Compliance Audit of the Ketchikan Pulp Company (KPC) pulp mill it was determined that adequate operating procedures were not in place and documented. KPC, therefore, requested that new procedures consistent with PSM requirements be written for each process area in the mill, even those which were not covered by PSM. The standard operating procedures were to cover all operating conditions. The following operating procedures were developed:

Bleach Plant Hypo System Redesign

Ketchikan Pulp Company (KPC) operates a pulp bleaching system that uses chlorine and sodium hypochlorite. UDA was requested to evaluate means of reducing the chlorine release potential from the chlorine unloading, chlorine scrubber, and hypo systems.

UDA performed the following tasks:

1. Examined the chlorine railroad car unloading system. As a result of the audit, UDA recommended several methods of reducing chlorine emissions including:
   • minor piping changes which would limit the amount of chlorine being purged to the scrubber by discontinuing complete purging of the chlorine cars
   • installation of motion and pressure sensors as recommended by the Chlorine Institute for minimizing releases from broken or uncoupled hoses
2. Examined the chlorine scrubber
   • UDA performed an analysis of the scrubber operating history and control philosophy. UDA found that significant improvements in scrubber capacity would result from minor modifications to the control system and piping rearrangement.
3. Examined the hypo system
   • Control system parameters were examined by UDA to improve the performance of the hypo manufacturing system. Modest process changes were recommended that substantially improved the overall system's capabilities.

Mechanical Integrity Program

Ketchikan Pulp Company (KPC) operates a magnesium bisulfite dissolving pulp mill. Three chemicals (chlorine, sulfur dioxide, and anhydrous ammonia) are used at the mill in quantities that exceed OSHA's threshold limits for highly hazardous chemicals, and are therefore regulated under the Process Safety Management (PSM) regulation.

KPC requested a Mechanical Integrity program be written which would incorporate the inspections being performed and be expanded where necessary. UDA developed a Mechanical Integrity program encompassing all equipment from each of the regulated process areas in the mill. The mechanical integrity program covers inspections and tests for all applicable equipment, a maintenance training program, and a quality assurance program.