SENA - Wisconsin Rapids Pulp Mill - Executive Summary |
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Stora Enso North America Corp. (SENA) is committed to operating in a manner that is safe for SENA workers, the public, and the environment. As part of this commitment, SENA has established procedures to help ensure safe operation of the processes at its facilities. SENA's Wisconsin Rapids Pulp Mill (WR Pulp Mill) has developed a risk management program (RMP) that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR Part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule) and helps to manage the risks of the covered substances and processes. One of the requirements of the RMP rule is to submit a risk management plan describing the risk management program at the WR Pulp Mill. This document is intended to satisfy the risk management plan requirements of the RMP rule. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES In April 1967, Consolidated Papers, Inc. adopted a corporate environmental p olicy that guides the continuous improvement of its environmental performance as it strives to prevent pollution and achieve the objective of operating facilities with minimal environmental impact. This policy was updated in November 1996. On August 31, 2000 Consolidated Papers, Inc. was aquired by Stora Enso, Oyj of Helsinki, Finland. SENA's environmental policy statement is publicly available on the Stora Enso Internet website. As part of its risk reduction objective, SENA will strive to minimize environmental, health, and safety risks to its employees and the communities in which it operates by employing safe technologies and operating procedures. SENA will be constantly prepared for emergencies. SENA will continually inform its employees and public of its progress in safety and environmental issues. SENA is one of 26 Wisconsin paper companies voluntarily participating in the Wisconsin Paper Council's Pollution Prevention Partnership with the Wisconsin Department of Natural Resources. As part of this membership, SENA produces an annual report that illustrates SENA and the Wisconsin paper industry's commitment to voluntarily reduce the release of substances that could have adverse environmental impacts. SENA's Pollution Prevention Partnership Progress Report is available to the public. SENA has also pledged to voluntarily align its corporate Environmental Management System to ISO 14001 international standards and to adhere to the American Forest and Paper Association's Environmental Health and Safety Principles. FACILITY DESCRIPTION AND THE REGULATED SUBSTANCES HANDLED SENA is a leading producer in North America of coated printing papers and a major manufacturer of supercalendered printing papers for the printing and publishing industries. In addition, SENA is a leading manufacturer of coated specialty papers used in consumer product packaging and labeling. SENA also produces elemental chlorine-free kraft pulp for its own use from virgin wood fib er, and recycled pulp from printed and post-consumer wastepaper. Other products manufactured by SENA include paperboard and paperboard products. Stora Enso, Oyj. is domiciled in Helsinki, Finland. SENA, a wholly owned subsidiary of Stora Enso, Oyj. is based in Wisconsin Rapids, Wisconsin. It operates paper and pulp manufacturing facilities in Biron, Kimberly, Appleton, Niagara, Stevens Point, Whiting, and Wisconsin Rapids, Wisconsin, as well as in Duluth, Minnesota. It also operates wastewater treatment plants in Stevens Point, Niagara, Kimberly, and Wisconsin Rapids, Wisconsin to treat wastewater generated by the pulp and paper manufacturing plants. Wastewater treatment is also done at the facilities in Duluth, Minnesota. The WR Pulp Mill is a pulp mill operated by SENA in Wisconsin Rapids, Wisconsin. At this facility, kraft pulp is manufactured from virgin fiber using an elemental chlorine-free process. The kraft pulp product is then used at various SENA paper mills for paper making. The pulp bleaching process in the manufacture of kraft pulp involves chemically treating the wood pulp fibers to reduce or remove lignin and resin. In the late 1980s and early 1990s, Consolidated Papers, Inc. (CPI) took voluntary steps to eliminate the use of elemental chlorine from its pulp-bleaching process by implementing a multi-million dollar multiphase chlorine-elimination program. In late 1996, CPI eliminated elemental chlorine from their entire kraft (chemical) pulp-bleaching process, thus achieving the commonly referred to position of elemental chlorine-free (ECF). CPI's mechanical pulps were already being bleached using a totally chlorine-free (TCF) process. Chlorine dioxide and chlorine are the chemicals regulated by the RMP rule that are stored or handled at this facility in total quantities greater than or equal to the threshold quantities. Chlorine dioxide is generated onsite as a gas under a slight vacuum and absorbed into water. The chlorine dioxide liqui d solution is stored in tanks and is used to bleach pulp. The chlorine dioxide solution is stored in three vertical aboveground tanks with design capacities of 60,000 gallons, 60,000 gallons, and 103,000 gallons. The chlorine dioxide solution has a concentration of 1% by weight of chlorine dioxide. Thus, the total quantity of chlorine dioxide stored at the WR Pulp Mill is 18,609 lb. The three chlorine dioxide tanks are partially located inside a building. Chlorine is stored in nine aboveground cylinder tanks, each with a design capacity of one ton. The total quantity of chlorine stored at this facility is 18,000 lb. The chlorine cylinders are kept inside a building. Chlorine is a toxic gas liquefied by pressure in the cylinder and is used to treat process water. WORST-CASE RELEASE AND ALTERNATIVE RELEASE SCENARIOS Worst-Case Release Scenarios Two worst-case release scenarios at WR Pulp Mill were analyzed, both involving toxic substances (chlorine dioxide and chlorine.) T he worst-case release scenario involving chlorine dioxide is defined as the rupture of the largest chlorine dioxide storage tank, instantaneously releasing its entire contents directly into the building. The largest chlorine dioxide tank stores 8,595 lb of chlorine dioxide. The building enclosure contains the entire spill and reduces the release rate into the atmosphere. This scenario was modeled using a chemical specific evaporation model to calculate the release rate and the Environmental Protection Agency's (EPA) Offsite Consequence Analysis Guidance document to predict the toxic endpoint. The worst-case release of chlorine dioxide is predicted to have offsite impacts on public and environmental receptors. The worst-case release scenario involving chlorine is defined as the rupture of one of the nine chlorine storage tanks, instantaneously releasing its entire contents into the building. The building enclosure contains the entire spill and reduces the release rate into the atm osphere. The release rate from the building is based on the EPA's RMP Off-site Consequence Analysis Guidance document. This scenario was modeled using the Dense Gas Dispersion (DEGADIS) model to predict the toxic endpoint. The worst-case release of chlorine is predicted to have offsite impacts on public receptors. Alternative Release Scenarios Since the worst-case release scenario predicted offsite impacts, an alternative release scenario involving chlorine dioxide is reported. The alternative release scenario is defined as an indoor spill due to a leak in the piping connecting the largest chlorine dioxide tank to the process. The amount of the spill is 1,000 gallons of aqueous chlorine dioxide solution. The quantity of chlorine dioxide in the 1,000-gallon aqueous solution spill is 83 lb. The building enclosure contains the entire spill and reduces the release rate into the atmosphere. This scenario was modeled using a chemical specific evaporation model to calculate the relea se rate and the EPA's Offsite Consequence Analysis Guidance document to predict the toxic endpoint. The alternative release of chlorine dioxide is predicted to have offsite impacts on public and environmental receptors. Since the worst-case release scenario predicted offsite impacts, an alternative release scenario involving chlorine is reported. The alternative release scenario is defined as an indoor release of chlorine due to the failure of the tubing connecting the chlorine tank to the water chlorination process. The total quantity of chlorine released into the building is 88.6 lb. The building enclosure contains the entire spill and reduces the release rate into the atmosphere. The release rate from the building is based on the EPA's RMP Off-site Consequence Analysis Guidance document. This scenario was modeled using the Areal Locations of Hazardous Atmospheres (ALOHA) model to predict the toxic endpoint. The alternative release of chlorine is predicted to have no offsite impact on public or environmental receptors. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS As part of its environmental policy, SENA will continue to protect the environment and the health and well-being of employees and communities by monitoring existing facilities to ensure that they meet all legal requirements through the use of safe technologies and operating procedures. The WR Pulp Mill complies with the prevention and emergency response procedures from all applicable regulations including certain applicable sections of RCRA and the Occupational Safety and Health Administration (OSHA) Emergency Action Plans (29 CFR 1910.38). FIVE-YEAR ACCIDENT HISTORY There have been no accidents at the WR Pulp Mill in the past five years that resulted in any adverse offsite impacts. On July 13, 1995, bleached stock from process equipment was spilled into the Phase 3 construction site within the Wisconsin Rapids Pulp Mill facility. This spill caused respiratory distress and injury to seven non-Wisconsin Rapids Pulp Mill employees and three Wisconsin Rapids police officers who responded to the call. No one offsite was injured. EMERGENCY RESPONSE PROGRAM The WR Pulp Mill emergency response program includes a written Emergency Response Plan that discusses procedures to be followed in the case of a general emergency and specific procedures for the handling of chlorine dioxide and chlorine spills to prevent and minimize the effects of an emergency involving these chemicals. The WR Pulp Mill current Emergency Response Plan works with the Incident Command System. The Incident Command System is designed to provide both public and private sector emergency response personnel with a logical building block system for managing hazardous material emergencies. The system is designed to begin at the point where emergency response personnel recognize that they are in fact, dealing with a hazardous material emergency, even when the exact ha zardous material has not be identified. The local fire department is also trained to the Incident Command System and will join with the WR Pulp Mill team members and co-command on an incident. The Incident Command System identifies a chain of command in response situations. It also identifies specific responsibilities for the various levels in that chain. The WR Pulp Mill has trained incident commanders, specialists, and technicians. Additionally, SENA has a Spill Reporting Policy that addresses the notification requirements in the event of an accidental release. The Spill Reporting Policy also identifies contacts and notification responsibilities. The WR Pulp Mill conducts incident investigations for all events, including minor situations that involve chlorine and/or chlorine dioxide. PLANNED CHANGES FOR SAFETY IMPROVEMENTS This facility will undergo regular scheduled maintenance and update to meet any new or revised applicable regulation and industry standard to continue to operate safely. |