P. H. Glatfelter Company
Risk Management Plan Summary

Questions and Answers

Safety and accident prevention are two of our most important objectives at P. H. Glatfelter Company.

Our Corporate Environmental Policy states that "(We) will employ effective environmental protection technologies and strategies in all operating facilities as a means of both protecting the environment and also reducing any environmental health and safety risk to our employees and the communities in which we operate. Further, the Company will maintain procedures and equipment to handle environmental emergencies."

At each of our mills, we have put in place a number of safety programs, including Process Safety Management for highly hazardous chemicals. We provide our employees with regular reviews and training in accordance with Occupational Safety and Health Administration (OSHA) requirements to ensure their continued health and safety. In addition, we have installed a number of devices to monitor operations and alert us to potential problems that might occur.

We have emergency response plans in place and have worked with each Local Emergency Planning Committee (LEPC) to reduce the risk of accidental chemical releases and to effectively respond in the event of a chemical emergency.

We place a high priority on working closely with local fire departments and emergency response personnel. We educate them on our operations, including the chemicals we use in the papermaking process, and we conduct table-top exercises with them to prepare for handling emergencies.

Our processes

The pulping, bleaching and papermaking processes we use to make our paper products include the use of several different types of chemicals. Two of these chemicals are chlorine and chlorine dioxide. Here’s how they are used in our processes:


  • as a bleaching agent
  • as a biocide, or anti-bacterial agent used to purify water used at the mill (and in the case of our mill in Spring Grove, Pennsylvania, for public drinking water used by the Borough of Spring Grove)
  • As an ingredient in the production of sodium hypochlorite – a bleaching agent at the Neenah, Wisconsin mill.
  • As a disinfectant to prevent bacterial growth on papermaking equipment.

Chlorine Dioxide:

  • As a bleaching agent at the Spring Grove mill.

 Chlorine is stored on-site in the container or vessel in which it was shipped - either in rail cars or cylinders.

Chlorine dioxide is produced on site at the Spring Grove mill and is stored as a dissolved gas in cool water.

EPA’s Risk Management Plan Rule

Under EPA’s Risk Management Plan Rule, companies that exceed the regulated amount of one or more listed chemicals must come up with one "worst-case" and alternative or "more likely" accident scenarios for each regulated chemical. In developing these scenarios, we used a model that generates very conservative results. The results were used to develop our Risk Management Plans at each mill. Those plans have been provided to and reviewed with emergency planning agencies at each of our facilities.

Worst Case

The intent of the worst-case scenario is not to be realistic, but to define the upper bound impact of a release that is virtually impossible. The regulations define the parameters for a worst-case scenario very specifically. Our goal was to develop a plan for the truly worst-case scenario and err on the side of safety for emergency planning purposes.

According to the RMP rule, the worst-case release must involve the loss of the largest quantity of a regulated substance from a vessel or process line. Therefore, for all U.S. mills, the worst-case release for chlorine involves the loss of the entire contents of a rail car of chlorine shortly after it has been connected to a mill’s supply system. In order for a release of this nature to occur, the tank car would have to split in two. The affected area would be dependent upon wind direction and speed.

It is important to note that the national Chlorine Institute reports that such an event has never occurred with a rail car at a user’s site or when the car was being filled with chlorine at a producer’s site. These cars are designed to withstand transportation accidents in accordance with federal Department of Transportation safety standards.

 Alternative or More-Likely Case

The alternative release scenario for chlorine would be a failure of gasket material and the release of chlorine for up to 30 minutes, depending on the mill location. The alternative release scenario for chlorine dioxide would be a break in a pipeline and the release of chlorine dioxide for 60 minutes.

Both of these two alternative scenarios would have similar affected areas - a pie-shaped maximum distance of up to approximately 750 feet, depending on wind direction.

 Our Preventive Measures

To prevent the release scenarios and mitigate the consequences of a release,

P. H. Glatfelter Company has implemented numerous protective practices at its facilities, including:

  • Routine inspection of equipment, piping, storage vessels and instrumentation
  • Written operating procedures detailing process conditions and procedures
  • Continuous computer and operator monitoring of process systems
  • Chlorine handling training procedures set in accordance with OSHA and Chlorine Institute guidelines
  • Operator training in normal and emergency operating procedures
  • Manual and automatic shut-off valves, including an excess flow device located in the rail car
  • Mechanical integrity testing of critical vessels and piping
  • Walk-through inspections
  • Inspections following maintenance procedures
  • Detectors throughout the process to notify personnel to releases
  • An on-site emergency response team to respond to emergencies
  • Safety reviews of all changes
  • Hot Work Permit procedures
  • Contractor Safety procedures

 In-Plant Emergency Response Plan

At each of our facilities, we have emergency response plans that outline procedures for dealing with both on-site and off-site emergencies. As part of that plan, we:

  • Provide regular training to emergency response team members
  • Conduct emergency response drills
  • Maintain on site first-aid facilities
  • Maintain on-site emergency response personnel
  • Conduct tabletop exercises with local LEPC/Emergency Management Agencies
  • Maintain cleanup and containment equipment on-site for quick response

In the unlikely event that a release occurs:

  • Emergency alarms are sounded
  • Trained emergency response teams respond with the appropriate tools for making expeditious rail car and cylinder repairs
  • The Facility Emergency Coordinator initiates the appropriate response, and, if necessary, notifies the Local Emergency Planning Committee (LEPC)/Emergency Response Agency (EMA), regional and/or state emergency planning committees; and National Response Center.
  • Following an incident, response activities are reviewed and revised as appropriate.

 Our accident history

P. H. Glatfelter Company maintains a five-year accident history that fulfills the requirements of the RMP rule. No releases of regulated substances have occurred from any of the chlorine areas in the last five years that have resulted in either on-site or off-site deaths, or significant property damage. One release of chlorine occurred on site at the Neenah mill within the last five years in which four outside contractors were slightly injured. The general public was not affected in that incident.

About our Company

P. H. Glatfelter Company was founded in 1864 and employs approximately 2,750 employees in the United States. Worldwide, P. H. Glatfelter Company employees 3,800 and generates annual revenues of $705 million (1998).

Papers made at our domestic mills can be found in best-selling novels, postage stamps, greeting cards, medical and surgical products, envelopes, Bibles, hymnals and reference books - products you may use on a daily basis.

About our Environmental Commitment

P. H. Glatfelter Company is committed to employee and public safety and to the preservation of the environment through accident prevention. The company implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of an accidental release, the company controls and contains the release in a manner that will be safe for workers and will help prevent injury to the public and to the environment.

In April, 1999, P. H. Glatfelter Company's Spring Grove Mill became the first pulp and paper mill in the United States to achieve internationally-recognized ISO 14001 certification for its environmental management system and its commitment to environmental excellence. To earn ISO 14001 certification, an organization must commit to compliance, prevention of pollution, continual improvement of its environmental management system, and involvement by employees at all levels of the organization. Glatfelter is currently pursuing ISO 14001 certification for all of its U.S. facilities by the end of 2001.

ISO 14001 provides the framework for managing our environmental affairs with the goal of improving environmental performance. We are committed to this continuous improvement and to working with local emergency response officials to reduce risks and improve accident preparedness.

If you have any questions about our risk management plans, please contact us via e-mail on our website.



2001 The P.H. Glatfelter Company