Fort James Operating Company, Old Town Mill - Executive Summary

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Fort James Operating Company's (Fort James) basic commitment to responsible stewardship of the environment, protection of the community, protection of employee health, and assurance of product safety extends to the processes covered by the new EPA Risk Management Plan (RMP) requirements.  The Fort James Old Town Mill has developed management systems in compliance with various applicable regulations to prevent the release of regulated substances especially in locations that may cause detrimental effects to employees, the community, or the environment.  This is accomplished through a systematic evaluation of process design, process technology, operational procedures, maintenance activities, non-routine procedures, emergency preparedness, training, and several other factors. 
Fort James has a long-standing commitment to worker and public safety.  This  
commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes.  Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances.  However, if a release does occur, our trained personnel will respond to control and contain the release. 
The Fort James Old Town Mill plans to meet or surpass all regulatory requirements.  In the attempt to accomplish this goal, the management systems at Old Town have been developed in such a way that the hazards are identified, understood, and controlled to prevent accidents.  The RMP regulated chemical is chlorine dioxide. 
The Fort James Old Town Mill has developed a management system to oversee the implementation of the Risk Management Program in accordance with the requirements of 40 CFR Part 68, Subpart G.  The management system identifies job functions by responsibility level. 
The Old Town Mill of Fort James Operating Company manufactures kraft market pulp and tissue products.  It is located on the Penobscot River near Old Town, Maine.  
The facility produces northern hardwood pulp.  Hardwood pulp is produced in two Kamyr kraft continuous digesters. Non-condensable gases are primarily incinerated in the mill's lime kiln. The kiln is equipped with a TRS continuous emission monitor.  The facility uses the #5 power boiler as a back-up incineration location. 
Hardwood pulp from the two digesters is combined and piped to the bleach plant.  The bleaching operations use chlorine dioxide, sodium hydroxide, hydrogen peroxide and oxygen.  Emissions from the chlorine dioxide stages of the bleach plant are collected and scrubbed with white liquor in a packed tower scrubber.  Chlorine dioxide is generated on-site and stored as a dilute aqueous solution.  The emissions fro 
m this process are also controlled by a packed tower scrubber. 
The Old Town Mill operates a process that has more than a threshold quantity of a regulated substance: chlorine dioxide generation and storage.  This process stores chlorine dioxide solution in a 190,000 gallon storage tank at typical concentrations of 9.5 grams per liter with maximum concentrations up to 9.7 grams per liter (equivalent to about 15,438 lb of chlorine dioxide).  
Since the resulting toxic endpoint distance predicted for the "worst-case" release of chlorine dioxide potentially encompasses public receptors, and the bleaching process is subject to OSHA's Process Safety Management (PSM) standard, this process is subject to Program 3 requirements.  
The Old Town Mill of Fort James Operating Company has developed and implemented an accidental release prevention program to continuously  
comply with OSHA's 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals and EPA's 40 CFR Part 68 subpart D, Accidental Release Prevention provisions in the Risk Management Program.  The prevention program thus developed and implemented consists of twelve elements which are listed below. 
* Process safety information. 
* Process hazard analysis. 
* Operating procedures. 
* Training. 
* Mechanical integrity. 
* Management of change. 
* Pre-startup review. 
* Compliance audits. 
* Incident investigation. 
* Employee participation. 
* Hot work permit. 
* Contractors. 
Some elements of the prevention program are intended to assure that designs are reviewed so that new plant and equipment are in conformance to safe design principles.  The remainder of the elements assure that the operation, maintenance and control of hazards are performed to prevent inadvertent changes outside the safe design and operating envelope. 
Fort James Operating Company concurs with US EPA's assessment that 
, "Prevention of accidental releases requires a holistic approach that integrates technologies, procedures, and management practices".  Therefore, Old Town Mill's prevention program is designed to provide for ongoing management of highly hazardous substances.  It is not a list of "once and done" actions.  Rather it provides a means for assuring safe operations throughout the life of the facility.  To this end, Old Town Mill utilizes modern computer managing techniques in coordination with plant-wide awareness to ensure continued fulfillment of prevention requirements. 
Fort James Operating Company has an outstanding record of accident prevention over the past five years.  This good record is demonstrated by the lack of any accidental release which had offsite consequences over the past five years and by the decreasing frequency of any kind of accident. 
The hazard assessment evaluates the offsite consequence 
s of accidental releases on public and environmental receptors.  Pubic receptors are offsite residences, institutions (such as schools and hospitals), commercial and office buildings, parks, or recreational areas inhabited or occupied by the public at any time where members of the public could be exposed to toxic concentrations, radiant heat, or overpressure, as a result of an accidental release.  Environmental receptors are natural areas such as national or state parks, forests, or monuments; officially designated wildlife sanctuaries, preserves, refuges, or areas; and federal wilderness areas, that could be exposed at any time to toxic concentrations, radiant heat, or overpressure greater than or equal to the endpoints in the risk management program rule, as a result of an accidental release. 
This section describes the worst-case and alternate scenario consequence analyses.  These analyses  comprise the hazard assessment. 
ES 5.1 Worst-Case Release Scenario Analysis for a Toxic Subs 
tance Release 
The worst-case release scenario for a toxic substance at the Old Town Mill is a hypothetical release of the entire contents of a storage tank containing 190,000 gallons of chlorine dioxide solution.  In accordance with the definition of worst case for toxic gases under RMP regulations, the entire 15,438 lb of chlorine dioxide were assumed to be released as a gas cloud from the spilled solution over a ten minute period.  Based on the structural integrity of the tank and interconnected piping, Fort James Operating Company considers such an event to have an extremely small probability of occurrence and, thus, not of practical interest in terms of risk management and emergency response planning.  Therefore, such a scenario is included in the Risk Management Plan for administrative completeness. 
Chlorine dioxide has a molecular weight that is substantially greater than that of ambient air.  For this reason, a concentrated plume resulting from a large accidental release would 
display dense-gas behavior.  That is, the near-field dispersion would be controlled by gravitational "slumping" caused by the density difference.  EPA's 1996 RMP Off-site Consequence Analysis Guidance (OCAG) lists a number of refined dense-gas dispersion models that are available for off-site hazard assessment applications for risk management programs.  Among these models is the DEnse Gas DISpersion (DEGADIS) Model (Version 2.1).  DEGADIS, developed by the U.S Coast Guard and the Gas Research Institute to simulate dispersion of dense-gas releases, is the only dense-gas model included in U.S. EPA's Guideline on Air Quality Models (40CFR Parts 51 and 52, Appendix B).  DEGADIS has therefore been used to model the chlorine dioxide worst-case release.  
The modeling was conducted using the prescribed weather conditions of 1.5 meters per second wind speed and F stability.  These low dispersion conditions are common at night with fair skies.   No passive mitigation measures were considered f 
or this hypothetical release.   
The toxic endpoint for chlorine dioxide is set by regulation to 1 ppm.  This is equal to the Immediately Dangerous to Life or Health (IDLH) level of 10 ppm, divided by a safety factor of 10 to account for sensitive individuals.  The IDLH, developed by the National Institute of Occupational Safety and Health (NIOSH) is intended to protect healthy workers from irreversible health effects or escape-impairing symptoms for exposures of up to 30 minutes. 
Under Section 68.22 (e), the RMP rule identifies "surface roughness" as a parameter to be specified in the hazard assessment. The surface roughness affects the amount of dispersion that occurs within a released plume and influences the distance to toxic endpoint. The surface roughness used in determining the distance to toxic endpoint should be characteristic of the transport path of the plume from the release point to the endpoint distance.  'Urban' surface roughness indicates areas where there are many obs 
tacles, such as industrial buildings or trees.  'Rural' indicates that there are few buildings or forests and that the terrain is generally flat and unobstructed.  
In the immediate vicinity of the Old Town Mill, the aerodynamic surface roughness is clearly 'urban' in nature, whereas at greater distances, the surface roughness is more 'rural', especially along the Penobscot River.  In order to report the most conservative 'distance to toxic endpoint' estimates in the Risk Management Plan, for the worst-case, Fort James has elected to include only the modeling results obtained assuming 'rural' surface conditions.  This is reflected in the use of a low 10 cm surface roughness in DEGADIS. 
The modeling indicated a considerable distance to chlorine dioxide's toxic endpoint, affecting both public and environmental receptors. 
ES5.2    Alternative Release Scenario for Chlorine Dioxide  
Chlorine dioxide solution is pumped from generation and storage to the bleach plant through a 6-inch diame 
ter pipeline.  The chlorine dioxide pipeline is supported by a pipe bridge, which is approximately 250 feet long.  Normal solution strength is about 9.5 grams per liter. 
This alternative release scenario is the rupture of the 6-inch diameter chlorine dioxide pipeline on the pipe bridge inside the bleach plant.  It is assumed that the approximately 250 feet of pipe would drain before the flow could be shut down.  This would release a total of 31.2 lb of ClO2.   
Alternative release dispersion modeling was conducted using the U.S. EPA's RMP*Comp(Version 1.06) software. In accordance with the RMP rule, alternative releases are modeled under typical (rather than worst-case) dispersion conditions.  The EPA OCAG default dispersion conditions are neutral atmosphere, with dispersion neither enhanced nor limited (D stability and 3 m/sec wind speed).   No mitigation of the release was considered. Because the surface roughness in the immediate vicinity of the Old Town Mill is urban in nature, an 
urban surface roughness value was utilized in the alternative release modeling.  
The estimated distance to toxic endpoint extends a minimal distance offsite, affecting public receptors.  No environmental receptors would be affected by the release. 
Old Town Mill of Fort James Operating Company maintains a comprehensive written emergency response program to protect plant workers, the general public and the environment.  The program includes plans and procedures for responding to a wide range of events, caused either naturally or accidentally, which have the potential to result in a release of a regulated substance.  The Old Town Mill emergency response program utilizes the Incident Command System (ICS) which parallels the National Interagency ICS.  This is an "all risk" system developed for on-scene management of any emergency event.  The functional design of the ICS minimizes the impact of personnel changes upon the emergency pla 
n.  Periodic emergency drills are conducted within the plant to maintain preparedness and to identify areas for improvement.  The emergency response program is updated when necessary, based on modifications made to the plant processes or facilities.  In addition, the plant has an emergency preparedness program that addresses maintenance, inspection and testing  of response equipment as well as instructions and training that govern use of this equipment. 
The overall emergency response program is coordinated with the LEPC.  This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives.  Old Town Mill has around-the-clock communications with the LEPC to ensure notification of the public in event of an incident, if necessary, as well as facilitating a quick response. 
The Fort James Operating Company continually strives to improve operatio 
ns at its facilities in order to reduce the potential of an accidental release to the environment. To that end, the Fort James Old Town Mill has replaced the chlorine bleaching system with an elemental chlorine-free system. The new system consists of a chlorine dioxide oxidizing bleaching system. This change has resulted in the complete phase-out of elemental chlorine from the Old Town Mill. The use of chlorine dioxide greatly reduces the risks of any potential off-site impacts associated with an accidental release, while also reducing the quantity of organically bound halide effluents produced in the paper pulp bleaching process. The elimination of elemental chlorine in the bleaching process has reduced the worst-case distance to toxic endpoint.  Fort James believes that the conversion to an elemental chlorine-free bleaching process reduces potential risks to its employees, the local communities, and the environment.
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