International Paper Company - Riegelwood Mill - Executive Summary |
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EXECUTIVE SUMMARY The International Paper Riegelwood Mill operates as a pulp and paper manufacturing facility. This mill is located on approximately 1,200 acres in the eastern portion of Columbus County, North Carolina. The areas immediately adjacent to the Riegelwood Mill are populated by residences and businesses, and areas along the river are used for transit and sport. The International Paper facility is located immediately adjacent to the Cape Fear River, a chemical manufacturing facility, and other smaller businesses and residences. In addition, right-of-ways cross the mill providing access for the local power company, a water district, and railroad traffic. The International Paper facility receives raw wood materials that are processed, pulped and manufactured into various types of paper products. A number of chemicals are used to facilitate the processes and to support auxiliary mill operations. The International Paper Riegelwood Mill operates four covered processes th at are subject to EPA's RMP Rule, each with Program 3 reporting requirements. These processes include the use of: Anhydrous Ammonia a nutrient added to wastewater for the treatment of water at the mill. Chlorine added to raw waters to condition process water prior to use in the pulp and paper production process. Chlorine Dioxide added as a bleaching tool to provide the consumer desired "whiteness" of the final paper products. Sulfur Dioxide used in the pulping process to remove residual bleaching chemicals from the pulp product prior to use by the end consumer. In compliance with EPA's RMP Rule, the Riegelwood Mill has evaluated the four covered processes to select and determine a worst-case release scenario that would provide the most catastrophic impacts reaching beyond the boundaries of the mill. As prescribed by the RMP Rule, International Paper was not able to take into consideration the preventive, protective and response measures in place to mitigate the severity o f a worst-case release scenario. The worst-case release scenario occurs in the sulfur dioxide process as a result of the large quantity of materials stored in a railcar. The sulfur dioxide worst-case release scenario would occur from the unmitigated vapor-phase release of the entire chemical contents of a pressurized 90-ton railcar delivered and stored at the Riegelwood Mill. Since International Paper's Riegelwood Mill is located in a populated area, this release could reach off-site endpoints and nearby public receptors. In the 47 years of pulp and paper operations at this location, a release of this nature has never occurred. Alternative release scenarios that present more likely potential releases were developed for each of the four covered processes in accordance with EPA's RMP Rule. EPA allows International Paper to take into consideration the everyday preventive, protective and response measures that are in place at the mill for the sole purpose of preventing catastrophi c releases of toxic chemicals. As required under EPA's RMP Rule, alternative release scenarios were developed for each of the four covered processes. In accordance with the EPA RMP Rule, each of these alternative release scenarios was selected to represent a release that is sufficiently severe to provide impacts to off-site receptors; but more importantly, these releases represent incidents with a greater likelihood of occurring at the Riegelwood Mill. Brief summaries of these scenarios are provided below. Anhydrous ammonia A vapor-phase release of anhydrous ammonia as a result of the rupture or splitting of a pressurized transfer pipe during chemical delivery was selected as an alternative scenario. To mitigate the impacts from this type of release, a trained operator is present during transfer operations and is equipped to immediately respond to a release. This release could reach off-site endpoints and nearby public receptors. A release of this nature has not occurred previ ously at the Riegelwood Mill, and there have been no reportable accidents associated with the anhydrous ammonia process in the last five years. Sulfur dioxide A vapor-phase release of sulfur dioxide as a result of the rupture or splitting of a flexible hose during pressurized sulfur dioxide transfer was selected as an alternative scenario. To mitigate the impacts from this type of release, chemical detectors are located at the transfer location to detect and then to visually and audibly alert the operators of a release. In addition, the operator has use of a remote camera that can be used to assess the nature of the release. The early detection and reconnaissance of the nature of the release enable the coordination of a planned and rapid emergency response. This release could reach off-site endpoints and nearby public receptors. A release of this nature has not occurred previously at the Riegelwood Mill, and there have been no reportable accidents associated with the sulfur di oxide process in the last five years. Chlorine A vapor-phase release of chlorine as a result of a leak or rupture of a valve on a one-ton pressurized chlorine cylinder was selected as an alternative scenario. To mitigate the impacts from this type of release, chemical detectors are located in the cylinder storage location to detect and then to visually and audibly alert the area operators of a release. The early detection of the release enables the coordination of a planned and rapid emergency response. This release could reach off-site endpoints and nearby public receptors. A release of this nature has not occurred previously at the Riegelwood Mill, and there have been no reportable accidents associated with the chlorine process in the last five years. Chlorine dioxide An aqueous-phase release of a dilute solution of chlorine dioxide as a result of the overtopping of a storage tank that results from a process upset was selected as an alternative scenario. The mill fire prot ection system and area drainage piping system enable dilution and collection of the released material for rapid conveyance to the mill wastewater treatment system. A release of this nature has previously occurred at the Riegelwood Mill with no reportable injuries to site personnel. In the past five years, the chlorine dioxide process has experienced one reportable accident occurring in 1994. This incident involved a release of chlorine dioxide solution with approximately 7 pounds released. As a result of this incident, the International Paper Riegelwood mill implemented revisions to its system, including a change in material specifications for the process, and the addition of computerized sensors designed to monitor and alert if system pressures were to fluctuate. In compliance with EPA's RMP Rule, the International Paper Riegelwood Mill has developed and implemented a detailed Prevention Program. This Prevention Program was originally formatted to meet the requirements of OSHA' s Process Safety Management Standard. The Prevention Program, in its existing form, has been in place and operational since 1995 but was built upon the mill's long standing commitment to safe chemical management. The Riegelwood Mill's Prevention Program encompasses all 12 elements of a Prevention Program as defined by both EPA and OSHA. These 12 elements can be classified into three categories including: the technology of the covered processes (provides for the collection of information and development of tools to better understand the processes and chemicals used at the mill); facilities related to the covered processes (administers the systematic monitoring and upkeep of the processes); and the personnel involved in supporting the processes (facilitates the training of and communication with people responsible for the safety and operation of these processes.) As an example of International Paper's commitment to a successful Prevention Program, the Riegelwood Mill has enhanced an existing Safe Works Practices Program. This program represents an expanded version of a Hot Works Program that requires personnel to receive a permit prior to using spark generation equipment in potentially flammable or combustible environments. International Paper's Safe Works Practices programs also includes provisions requiring preventive measures to be exercised prior to execution of other potentially risky or hazardous activities such as confined space entry or work occurring on energized equipment. International Paper's Riegelwood Mill has developed and implemented a comprehensive Emergency Response Program that is detailed in the mill's Emergency Response Plan. The Emergency Response Plan (ERP) was revised and expanded in response to the emergency planning requirement under OSHA's PSM Standard and has been in its existing format since 1995. This ERP has been continually updated to reflect both policy and procedural changes related to emergency planning and response at the m ill. The ERP was most recently updated in early 1999 and meets the requirements of both EPA's RMP Rule and OSHA's PSM Standard. The strength of the Riegelwood Mill's Emergency Response Program lies in the fact that International Paper supports and operates an on-site emergency response team 24 hours a day at the Riegelwood Mill. Mill personnel are fully trained and equipped to respond to a release of hazardous chemicals. The close proximity of these trained personnel and equipment to potential on-site releases at the mill allow for timely and efficient mitigation of releases. In addition to the development and implementation of emergency response planning and training at the mill, International Paper has provided comprehensive information to and has participated in the preparation and coordination of emergency services with the Local Emergency Planning Committee. Through the continued implementation of the mill's Risk Management Program, International Paper strives to provide a s afer workplace for its employees, to be a good neighbor, to protect the environment and its natural resources, and to comply with the provisions of the EPA's RMP Rule. As the Riegelwood Mill continues to manufacture quality pulp and paper products, International Paper's corporate commitment to safety and the protection of the environment focuses on the continued improvement of our policies and procedures. With this corporate focus, the Riegelwood Mill has implemented an Elemental Chlorine Free (ECF) process for bleaching pulp. The ECF process replaces the chlorine gas used in the bleaching process with hydrogen peroxide, a safer chemical. The introduction of the ECF process has enabled International Paper to completely eliminate the use of chlorine railcars at the Riegelwood Mill. International Paper stands committed to providing a safe workplace for its employees and to be a good corporate neighbor while continuing to provide quality pulp and paper products. |