International Paper - Courtland Mill - Executive Summary |
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International Paper (IP) owns and operates the Courtland Mill, an integrated pulp and paper manufacturing facility, located on an 1860-acre site in north Alabama about 5 miles north of Courtland. International Paper is committed to operating in a manner that provides for the safety of its employees and neighbors and for the protection of the environment. A key element of this commitment is the safe and proper handling of chemicals. Controls have been implemented to prevent accidental releases of hazardous substances. In the event of an accidental chemical release, mitigation steps are taken to stop, control, contain, and clean up the release. Two substances, chlorine dioxide for pulp bleaching and chlorine for water treatment, are utilized at the site. These substances are regulated under 40 CFR Part 68, Chemical Accident Prevention Provisions. Process, Program Level, Regulated Substance, Process Quantity, Largest Single Vessel Pulp Bleaching, 3, Chlorine Dioxide (1.1%), 51,000 lbs, 24,270 lbs Water Intake, 3, Chlorine (100%), 24,000 lbs, 2,000 lbs Water Treatment, 3, Chlorine (100%), 24,000 lbs, 2,000 lbs The Courtland Mill is committed to continuously improving the safety of its processes. One example of this commitment was the conversion of the pulp bleaching process from elemental chlorine (chlorine gas, or Cl2) to chlorine dioxide (ClO2) in March of 2000. Additionally, ongoing activities including training, process hazard analysis and auditing are utilized to identify ways to continuously improve the operation of these processes. As required by the rule, worst case and alternative release scenarios were analyzed. The worst-case release scenario for the Courtland mill is the complete rupture of a chlorine dioxide solution storage tank in the Pulp Bleaching Process. Based on this hypothetical release, combined with the conservative parameters mandated by U.S. EPA, the radius to the endpoint distance would have off-site impacts. Affected public and environmental receptors could include schools, residences, hospitals, recreational areas, and commercial areas. As noted in the quote from U.S. EPA, the worst-case scenario represents the "maximum possible area that might be affected in the unlikely event of catastrophic conditions". The alternative release scenario for the Pulp Bleaching process is a chlorine dioxide pipeline leak. This scenario assumes that responders require 30 minutes to detect and repair the leak. Mitigation measures considered in this scenario were emergency shutdown systems, chlorine dioxide monitors, directional curbing, sumps, drains, sewers, and scrubbers. Based on average weather conditions at the site, the endpoint distance does not include residential population and reaches no environmental receptors with the exception of a small portion of a the Tennessee river. The radius does extend offsite, but the offsite areas it covers are only the county road to the plant, a small portion of the river, and a small portion of a farmers field. The alternative release scenario for the Water Intake chlorine processes is a gas valve failure on a 1-ton chlorine cylinder. This scenario assumes that responders require 30 minutes to detect and repair the leak. Mitigation measures considered in this scenario were area chlorine monitors and vacuum operated regulator check valves. Based on average weather conditions at the site, the endpoint distance does not include residential population and reaches no environmental receptors with the exception of a small portion of a the Tennessee river. The radius does extend offsite, but the offsite area it covers is only a small portion of the river. The alternative release scenario for the Water Treatment chlorine processes is a gas valve failure on a 1-ton chlorine cylinder. This scenario assumes that responders require 30 minutes to detect and repair the leak. Mitigation measures considered in this scenario were area chlorine monitors and vacuum o perated regulator check valves. Based on average weather conditions at the site, the endpoint distance does not extend off-site or include residential population and reaches no environmental receptors. The following prevention elements for the chlorine and chlorine dioxide systems are employed at the Courtland Mill. Process Safety Information: A variety of technical documents that are used to help ensure the safe operation of these systems is maintained. Material Safety Data Sheets document the physical properties of these chemicals. Design standards are utilized to ensure that process safety information is incorporated into the construction and maintenance of these systems. Process Hazard Analysis: Process hazard analysis's (PHA's) were conducted on both the chlorine and chlorine dioxide systems. PHA's are structured ways to identify and reduce the hazards of a system. Routine review of these PHA's are performed as well. Operating Procedures: Written operating procedures h ave been developed and are maintained. These procedures define how tasks related to the process operations should be performed. They are used to train operators and serve as guides for appropriate steps to be taken during both normal operations and process upsets. Maintenance: The chlorine and chlorine dioxide systems are properly maintained. Preventative maintenance is routinely performed on these systems. Work on these systems is limited to employees and contract personnel who have received specific training on the maintenance and hazards of these systems. Compliance Audits: Compliance audits are conducted to ensure compliance with the requirements of the regulations. Incident Investigation: All incidents that could reasonably result in a serious injury to employees, the public, or the environment are investigated. All employees are encouraged to report any such incident. The results of the investigations are documented and appropriate actions are implemented. Train ing: Personnel are trained in the operating procedures to help ensure safe and effective performance of their assigned tasks. In addition to the required prevention program elements, the Courtland Mill has implemented safety features specific to the hazardous substances. The following paragraphs describe some of these safety features: Chlorine Dioxide: Chlorine dioxide is produced at the Courtland Mill and stored as a dilute aqueous solution. Chlorine dioxide gas is produced in the chlorine dioxide generators and piped to absorber columns, where a 1.1 wt. % chlorine dioxide solution is generated. Storing the substance as an aqueous solution greatly reduces the potential for a release. A curbed area with sewers at the storage tank further reduces the consequences of a release. Detectors and alarms provide continuous monitoring in all areas where the potential for chlorine dioxide exists, providing early detection, and helping to ensure a quick response in the event of a leak. An emergency shutdown system is used to isolate the process if there is an upset or a release. Chlorine: Chlorine is supplied to the Courtland Mill in DOT-approved 1-ton cylinders. Chlorine is metered from a vacuum operated regulator/check valve attached directly to the cylinder through a short length of piping to an injector, where it is safely absorbed into process water. This vacuum operated system provides a high degree of reliability and safety. In the event of an unlikely failure in the piping downstream of the vacuum regulator/check valve, the valve will automatically close and shut off the flow of chlorine from the cylinder. Chlorine detectors and alarms are provided in areas where chlorine could be present if a release occurs. As defined by the rule, three accidental releases have occurred in the past five years. No permanent injury resulted from these accidents and information learned because of them was used to improve our prevention programs. All appropriate local, state, and federal emergency management officials were notified. The three accidental releases that occurred were related to chlorine exposure in the pulp bleaching process. The pulp bleaching process, now elemental chlorine free was converted from chlorine to chlorine dioxide in March of 2000 and the source chlorine removed from the mill site. The Courtland Mill facility has a written emergency response plan that complies with the RMP rule and with other federal contingency plan regulations to mitigate and minimize the affects of any accidental release. Trained response personnel and equipment are on site 24 hours a day. Training on and drills of the response plan are periodically conducted. The response plan has been communicated to local emergency response officials through the local emergency planning commission (LEPC). Regular dialogue is maintained between the Courtland Mill and the LEPC, and the Courtland Mill provides appropriate information to the LEPC. The Courtland M ill constantly strives to improve the safety of the processes through both the incident investigation program and a program soliciting safety suggestions from the workers. Routine safety audits are conducted through out the mill on a continuous basis in order to keep safety at the utmost level of concern. International Paper (IP) owns and operates the Courtland Mill, an integrated pulp and paper manufacturing facility, located on an 1860-acre site in north Alabama about 5 miles north of Courtland. International Paper is committed to operating in a manner that provides for the safety of its employees and neighbors and for the protection of the environment. A key element of this commitment is the safe and proper handling of chemicals. Controls have been implemented to prevent accidental releases of hazardous substances. In the event of an accidental chemical release, mitigation steps are taken to stop, control, contain, and clean up the release. Two substances, chlorine dioxide f or pulp bleaching and chlorine for water treatment, are utilized at the site. These substances are regulated under 40 CFR Part 68, Chemical Accident Prevention Provisions. Process, Program Level, Regulated Substance, Process Quantity, Largest Single Vessel Pulp Bleaching, 3, Chlorine Dioxide (1.1%), 51,000 lbs, 24,270 lbs Water Intake, 3, Chlorine (100%), 24,000 lbs, 2,000 lbs Water Treatment, 3, Chlorine (100%), 24,000 lbs, 2,000 lbs The Courtland Mill is committed to continuously improving the safety of its processes. One example of this commitment was the conversion of the pulp bleaching process from elemental chlorine (chlorine gas, or Cl2) to chlorine dioxide (ClO2) in March of 2000. Additionally, ongoing activities including training, process hazard analysis and auditing are utilized to identify ways to continuously improve the operation of these processes. As required by the rule, worst case and alternative release scenarios were analyzed. The worst-case rel ease scenario for the Courtland mill is the complete rupture of a chlorine dioxide solution storage tank in the Pulp Bleaching Process. Based on this hypothetical release, combined with the conservative parameters mandated by U.S. EPA, the radius to the endpoint distance would have off-site impacts. Affected public and environmental receptors could include schools, residences, hospitals, recreational areas, and commercial areas. As noted in the quote from U.S. EPA, the worst-case scenario represents the "maximum possible area that might be affected in the unlikely event of catastrophic conditions". The alternative release scenario for the Pulp Bleaching process is a chlorine dioxide pipeline leak. This scenario assumes that responders require 30 minutes to detect and repair the leak. Mitigation measures considered in this scenario were emergency shutdown systems, chlorine dioxide monitors, directional curbing, sumps, drains, sewers, and scrubbers. Based on average weather con ditions at the site, the endpoint distance does not include residential population and reaches no environmental receptors with the exception of a small portion of a the Tennessee river. The radius does extend offsite, but the offsite areas it covers are only the county road to the plant, a small portion of the river, and a small portion of a farmers field. The alternative release scenario for the Water Intake chlorine processes is a gas valve failure on a 1-ton chlorine cylinder. This scenario assumes that responders require 30 minutes to detect and repair the leak. Mitigation measures considered in this scenario were area chlorine monitors and vacuum operated regulator check valves. Based on average weather conditions at the site, the endpoint distance does not include residential population and reaches no environmental receptors with the exception of a small portion of a the Tennessee river. The radius does extend offsite, but the offsite area it covers is only a small porti on of the river. The alternative release scenario for the Water Treatment chlorine processes is a gas valve failure on a 1-ton chlorine cylinder. This scenario assumes that responders require 30 minutes to detect and repair the leak. Mitigation measures considered in this scenario were area chlorine monitors and vacuum operated regulator check valves. Based on average weather conditions at the site, the endpoint distance does not extend off-site or include residential population and reaches no environmental receptors. The following prevention elements for the chlorine and chlorine dioxide systems are employed at the Courtland Mill. Process Safety Information: A variety of technical documents that are used to help ensure the safe operation of these systems is maintained. Material Safety Data Sheets document the physical properties of these chemicals. Design standards are utilized to ensure that process safety information is incorporated into the construction and maintena nce of these systems. Process Hazard Analysis: Process hazard analysis's (PHA's) were conducted on both the chlorine and chlorine dioxide systems. PHA's are structured ways to identify and reduce the hazards of a system. Routine review of these PHA's are performed as well. Operating Procedures: Written operating procedures have been developed and are maintained. These procedures define how tasks related to the process operations should be performed. They are used to train operators and serve as guides for appropriate steps to be taken during both normal operations and process upsets. Maintenance: The chlorine and chlorine dioxide systems are properly maintained. Preventative maintenance is routinely performed on these systems. Work on these systems is limited to employees and contract personnel who have received specific training on the maintenance and hazards of these systems. Compliance Audits: Compliance audits are conducted to ensure compliance with the requir ements of the regulations. Incident Investigation: All incidents that could reasonably result in a serious injury to employees, the public, or the environment are investigated. All employees are encouraged to report any such incident. The results of the investigations are documented and appropriate actions are implemented. Training: Personnel are trained in the operating procedures to help ensure safe and effective performance of their assigned tasks. In addition to the required prevention program elements, the Courtland Mill has implemented safety features specific to the hazardous substances. The following paragraphs describe some of these safety features: Chlorine Dioxide: Chlorine dioxide is produced at the Courtland Mill and stored as a dilute aqueous solution. Chlorine dioxide gas is produced in the chlorine dioxide generators and piped to absorber columns, where a 1.1 wt. % chlorine dioxide solution is generated. Storing the substance as an aqueous solut ion greatly reduces the potential for a release. A curbed area with sewers at the storage tank further reduces the consequences of a release. Detectors and alarms provide continuous monitoring in all areas where the potential for chlorine dioxide exists, providing early detection, and helping to ensure a quick response in the event of a leak. An emergency shutdown system is used to isolate the process if there is an upset or a release. Chlorine: Chlorine is supplied to the Courtland Mill in DOT-approved 1-ton cylinders. Chlorine is metered from a vacuum operated regulator/check valve attached directly to the cylinder through a short length of piping to an injector, where it is safely absorbed into process water. This vacuum operated system provides a high degree of reliability and safety. In the event of an unlikely failure in the piping downstream of the vacuum regulator/check valve, the valve will automatically close and shut off the flow of chlorine from the cylinder. Chlo rine detectors and alarms are provided in areas where chlorine could be present if a release occurs. As defined by the rule, three accidental releases have occurred in the past five years. No permanent injury resulted from these accidents and information learned because of them was used to improve our prevention programs. All appropriate local, state, and federal emergency management officials were notified. The three accidental releases that occurred were related to chlorine exposure in the pulp bleaching process. The pulp bleaching process, now elemental chlorine free was converted from chlorine to chlorine dioxide in March of 2000 and the source chlorine removed from the mill site. The Courtland Mill facility has a written emergency response plan that complies with the RMP rule and with other federal contingency plan regulations to mitigate and minimize the affects of any accidental release. Trained response personnel and equipment are on site 24 hours a day. Training on and drills of the response plan are periodically conducted. The response plan has been communicated to local emergency response officials through the local emergency planning commission (LEPC). Regular dialogue is maintained between the Courtland Mill and the LEPC, and the Courtland Mill provides appropriate information to the LEPC. The Courtland Mill constantly strives to improve the safety of the processes through both the incident investigation program and a program soliciting safety suggestions from the workers. Routine safety audits are conducted through out the mill on a continuous basis in order to keep safety at the utmost level of concern. |