Fort James Corporation, Naheola Mill - Executive Summary

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Fort James Corporation'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 Naheola 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 safe 
ty 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 Naheola Mill plans to meet or surpass all regulatory requirements.  In the attempt to accomplish this goal, the management systems at Naheola have been developed in such a way that the hazards are identified, understood, and controlled to prevent accidents.  The RMP regulated chemicals include chlorine and chlorine dioxide. 
The Naheola Mill of  Fort James Corporation manufactures, among other products, tissue, towels and paper board and pulp.  It is located on the Tombigbee River near Pennington, Alabama.  Total mill production is 1,600 -1,800 tons per day. 
Power generation consists of one recovery boiler, two combination boilers, which burn bark, wood waste and coal 
, one power boiler that burns oil and gas, and two package boilers, which burn natural gas.  The recovery boiler is of the low-odor design and equipped with state-of-the-art continuous emission monitors. 
Of the total pulp production, hardwood comprises 60% and softwood 40%.  Hardwood pulp is produced in eight batch digesters.  Softwood pulp is produced in one Kamyr continuous digester.  Non-condensable gases are incinerated in the mill's lime kiln. The kiln is equipped with modern continuous emission monitors.  A back-up incinerator is also used. 
Hardwood and softwood pulps are bleached in separate bleach lines using chlorine, chlorine dioxide and oxygen.  Emissions from each bleach line are collected and scrubbed separately with white liquor in two packed tower scrubbers.  Additionally, about 100 tons per day of broke are bleached with sodium hypochlorite.  This bleaching is performed as a separate operation from the two bleach lines. 
The paper mill operates seven paper machines an 
d a pulp dryer.  One of the paper machines is a board machine which produces cup stock.  Another board machine, which has an on-machine coater, produces plate stock.  The other five machines produce tissue and toweling. 
Paper and board are converted in the mill.  Some tissue and towels are printed.  Water based and low VOC inks are utilized.   
The mill operates on-site a waste water clarifier, ash ponds, and an aerated stabilization basin with 53 aerators and a 38 acre non-hazardous process waste landfill. 
The Naheola Mill operates three processes which have more than a threshold quantity of a regulated substance. These three are: 
1.) Chlorine unloading and vaporization:  This process stores liquid chlorine in 90-ton rail     cars. 
2.) Chlorine dioxide generation and storage:  This process stores chlorine dioxide solution in 200,000 gallon storage tanks at strengths as great as 1.15 grams per liter; this is equivalent to about 19,000 lb of chlorine 
3.) Water treatment:  This process utilizes chlorine stored in 1-ton cylinders.. 
The above process are Program 3 processes as defined by the risk management program rule. 
The Naheola Mill of Fort James Corporation 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. 
7 Process safety information. 
7 Process hazard analysis. 
7 Operating procedures. 
7 Training. 
7 Mechanical integrity. 
7 Management of change. 
7 Pre-startup review. 
7 Compliance audits. 
7 Incident investigation. 
7 Employee participation. 
7 Hot work permit. 
7 Contractors. 
Some elements of the prevention program are intended to assure that designs are revi 
ewed so that new processes 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 Corporation concurs with US EPA's assessment that, "Prevention of accidental releases requires a holistic approach that integrates technologies, procedures, and management practices".  Therefore, Naheola Mill' 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, Naheola Mill utilizes modern computer managing techniques in coordination with plant-wide awareness to ensure continued fulfillment of prevention requirements. 
Fort James Corporation has an outstanding re 
cord 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 consequences 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 over 
pressure 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 consequence analysis and alternate scenario consequence analyses.  These analyses  comprise the hazard assessment. 
The worst-case release scenario for a toxic substance at the Naheola Mill is a hypothetical release of the entire contents of a tank containing 19,000 pounds of chlorine dioxide as an 1.15% solution.  In accordance with RMP regulations, the entire 19,000 pounds of chlorine dioxide were assumed to be released as a gas cloud in ten minutes.  Fort James Corporation 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 d 
ioxide is generated within the mill utilizing the "R-8" process.  It is stored as an aqueous solution of up to 11.5 grams per liter strength (1.15% by weight) in two 200,000 gallon capacity storage tanks near the center of the mill.  This worst-case scenario consists of failure of the No. 1 (east) chlorine dioxide storage tank with a resultant overland flow to the east and northeast where there is no passive mitigation. 
Failure of No. 2 storage tank would have passive mitigation by the open process sewer adjacent to the tank on the west and south sides.  Therefore, failure of No. 2 tank would not represent worst-case.  
The worst case scenario for chlorine dioxide was initially modeled using SLAB, which indicated a distance to the toxic endpoint of 23 miles.  Since then, EPA has released and re-released their RMPComp program, which indicated no significant difference in the distance to the toxic endpoint. 
Per 40 CFR 68.22(e), surface roughness criteria used in the consequence model,  
obstructions such as trees would be interpreted as an urban area for modeling purposes.  Given the densely populated forest surrounding the plant, an urban model is appropriate.  Both urban and rural settings in RMPComp produced results indicating 22 miles to the toxic endpoint. 
The affected area predicted by the analysis includes Demopolis and Butler, Alabama. 
The Fort James Naheola Mill does not store flammable materials regulated by the RMP Rule in quantities over the threshold amount. 
Liquid chlorine is pressure unloaded from a rail tank car through a 1.5 inch pipeline at the normal flow rate of 5.6 gallons per minute.  Unloading takes place outside of any building or enclosure.  This alternate scenario assumes that the 1.5 inch unloading pipeline is severed and chlorine is released at the normal flow rate.  It is assumed that 1 
0 minutes elapse before the release is detected and stopped by closing the unloading valve on the tank car.  Under these conditions, 665 pounds of chlorine are released over a 10 minute period. 
EPA's RMP Offsite Consequence Analysis Guidance was used to estimate the distance to the EPA toxic endpoint of 0.0087 mg/L.  The Guidance estimated a maximum distance of 1.0 mile to the EPA toxic endpoint.  No mitigation of the release was considered. 
Mill supply water is treated with chlorine in the water treatment plant, which is located towards the north end of the mill.  Under normal operation, chlorine for this process is obtained from the mill's chlorine unloading and vaporization process.  However, when the chlorine vaporizers are down, chlorine is obtained from one of three 1-ton chlorine storage cylinders maintained at the water treatment plant.  Connections are arranged so that only one chlorine cylinder can be connect 
ed at a time. 
This scenario is a leak in one of the 1-ton chlorine cylinders inside the water treatment building which empties a full cylinder in 10 minutes. The 1-ton cylinders are kept within the water treatment plant building.  One door from the room containing the cylinders opens to the outside.  Therefore, in accordance with EPA's guidance, an offsite impact mitigation factor of 55% can be applied to a gas release within the building.  EPA's RMP Offsite Consequence Analysis Guidance was used to estimate the distance to the EPA toxic endpoint, which is 1.4 miles. 
Chlorine dioxide solution is pumped from generation and storage to other processes within the mill.  These other processes include two bleaching processes and a TRS control process.  The bleaching and TRS control processes do not have chlorine present in more than the threshold quantity. 
Chlorine dioxide is pumped to the above mill processe 
s through a 6-inch diameter pipeline.  This chlorine dioxide solution pipe line is supported by a pipe bridge, which is approximately 350 feet long.  Normal solution strength is about 10 grams per liter. 
This alternate-scenario is the rupture of the 6-inch diameter chlorine dioxide pipe line on the pipe bridge between chlorine dioxide storage and the bleach plant.  It is assumed that the rupture would result in a 10 minute release of the chlorine dioxide solution at the normal pumping rate.  The toxic endpoint concentration for chlorine dioxide is 1 ppmv (0.0028mg/L) and the endpoint distance following the Offsite Consequence Analysis Guidance is 1.7 miles. 
Naheola Mill of Fort James Corporation 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 Naheola 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 plan.  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 eme 
rgency response officials, local government officials, and industry representatives.  Naheola 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.
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