WAUNA 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.  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 Wauna mill plans to meet or surpass all regulatory requirements.  To accomplish  
this goal, the m 
anagement systems at Wauna have been developed in such a way that the hazards  
are identified, understood, and controlled to prevent accidents.  The RMP-regulated chemicals at  
the Wauna mill are limited to chlorine dioxide, sulfur dioxide, and ammonia.   
Mill Description 
The Fort James Wauna Mill is located on 1200 acres adjacent to the Columbia River in Clatsop  
County, Oregon.  This site was originally developed in 1909 for a lumber mill operation. The  
Wauna mill began its current business of producing pulp and paper in 1965.  
The Wauna mill is a fully integrated pulp and paper mill that uses the following general  
processes: The Mill produces a variety of paper products.  These products include towel and  
tissue products for retail stores and the commercial market, uncoated printing papers, as well as  
newsprint and other groundwood specialty paper grades. The Wauna mill employs about 1,100  
people from the local area.  
Logs, sawdust, wood chips, and purchased pulp are transported to the mill by barge or by truck.  
Logs are reduced to chips on site. Sawdust and wood chips are stored in piles prior to processing. 
Wauna uses the kraft process as well as a groundwood process to convert wood into pulp.  In the  
groundwood pulping process, pulp is produced by mechanically grinding wood chips in  
machines called refiners.  Groundwood pulp is bleached with sodium hydrosulfite and/or a  
solution of hydrogen peroxide and sodium hydroxide.  
The kraft process uses a sodium hydroxide and sodium sulfide solution under heat and pressure  
to dissolve the lignin component of wood. The dissolved lignin and spent pulping chemicals are  
separated from unbleached pulp by washers and sent to chemical recovery. After washing,  
unbleached pulp goes through a multi-stage bleach plant. The bleaching process uses sodium  
hydroxide, oxygen,  chlorine dioxide, and hydrogen peroxide to remove residual lignin from the  
pulp and 
whiten it to commercial brightness levels. The chlorine dioxide solution is produced on- 
site from sodium chlorate, sulfuric acid, methanol, and water. 
There are five papermachines at the Wauna mill.  Three of the papermachines produce towel and  
tissue grades, one produces white printing papers, and one produces groundwood specialty  
papers and newsprint.  
Bleached pulps derived from different wood species as well as purchased pulp and secondary  
fiber recycled from waste paper are blended to produce a mixture tailor-made for each paper  
grade.  The rolls of paper from the towel and tissue papermachines are converted on-site into  
napkins, towels, bathroom tissue, or facial tissue. Rolls of paper from the communication  
papermachines are wrapped and sold directly to printers and converters.  The mill also operates a  
pulp dryer which produces baled pulp for internal use or sale to outside customers. 
Wastewaters from the mill are collected and pumped to an air activated biological  
facility. The facility includes a primary clarifier, a stabilization basin, an aeration pond, and two  
secondary clarifiers. Primary and secondary sludges are dewatered together and burned, along  
with other wood wastes, in a state-of-the-art fluid bed boiler. The mill operates an on-site landfill  
for solid waste disposal. The treated wastewater is discharged into the Columbia River. 
Most processes operate 24 hours a day, 7 days a week, and 52 weeks a year.   Portions of the  
production equipment are shut down periodically for maintenance or cleaning.  The entire  
facility is generally shut down only once per year  for maintenance. 
Substances and Processes Regulated Under RMP 
The Wauna mill stores three chemicals above the threshold limits of 40 CFR 68.130 (see Table  
ES-1).  A summary of the RMP-regulated processes and substances is given below.   
Chlorine Dioxide Generator and Associated Chlorine Dioxide Storage. An R8 process is used to  
generate chlorine dioxide on- 
site for subsequent use in the kraft bleach plant.  In this process,  
methanol is added to a heated solution of sodium chlorate and sulfuric acid in a reaction vessel  
which is under a vacuum.  The resultant chlorine dioxide gas is absorbed in cold water and then  
stored as a nominal 1% solution.  The actual chlorine dioxide solution strength can range as high  
as 1.1%.   
Sulfurous Acid Manufacturing.  Dilute aqueous sulfurous acid is manufactured on-site for use in  
the Kraft and groundwood bleaching processes.  Sulfur dioxide is purchased and stored on-site  
as a liquid in 1,000 gallon storage cylinders.  Sulfur dioxide from these cylinders is added to cold  
water to produce, as needed, a 3% solution of sulfurous acid which is used to decompose small  
amounts of chlorine dioxide or peroxide bleaching chemicals which may remain with the pulp at  
the end of the groundwood or kraft bleaching processes. 
Fluid Bed Boiler NOx Control and Associated Ammonia Storage.   The Fluid Bed Boiler 
Wauna uses ammonia injection as part of its Fluid Bed Boiler (FBB) Selective Non-Catalytic  
Reduction (SNRC) Nitrogen Oxides (NOx) control system which is part of a state-of-the-art  
pollution control equipment package.  Liquid ammonia is purchased and stored on-site in a  
12,000 gallon tank.  From the storage tank, ammonia is added to the mill's fluid bed boiler as  
needed to control emissions. 
Additional Substances Used at Wauna That Are Not Subject to RMP 
In addition to the substances listed in Table ES-1 that are subject to the RMP program,  the  
Wauna mill uses other chemicals that are not regulated under RMP.  The following substances  
are used at the mill, and could conceivably be released to the atmosphere as a result of a major  
accident.  Fort James rigorously maintains all of the equipment at the mill, and considers any  
major accident at these processes to be highly unlikely.  As described in Section ES-7, the  
Wauna mill's emergency response procedures address poten 
tial releases of these chemicals. 
Propane - Small tanks of propane are used at various locations at the mill.  None of the tanks are  
large enough to trigger EPA's RMP requirements.  All of the propane tanks were installed and  
are maintained in accordance with local fire codes. It is extremely unlikely that even a large release  
would affect any public areas or residences. 
Methanol - Liquid methanol is stored in a 10,000 gallon tank for use in generating chorine  
dioxide.  It is unlikely that an accidental spill of even a very large amount of methanol, followed  
by a fire, would result in a fire that would extend to the facility boundary nor impact areas  
beyond the mill boundary. 
Dilute Aqueous Ammonia -  A 35,000 gallon tank of 15% aqueous ammonia is used at the mill's  
waste water treatment facility.  If a very large amount of this dilute ammonia was accidentally  
released, then ammonia gas could conceivably evaporate from the resulting liquid pool.   
However, it is unlikely tha 
t even a large spill would cause ambient concentrations  
high enough to pose even odor impacts beyond the facility boundary. 
EPA's Accidental Release Prevention Program (ARPP) (40 CFR Part 68) requires industries to  
demonstrate that they have implemented an Accident Prevention Program.  This section briefly  
describes the elements of Fort James Corporation's program.  The Wauna mill has fully  
implemented their accident prevention program to 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.  Wauna's  
program is centered around OSHA's Process Safety Management (PSM) program.  The  
Prevention Program consists of 12 elements which help Fort James at Wauna to minimize  
releases of regulated substances.  A description of each of the elements is given below. 
Employee Particip 
Fort James involves employees in the development and implementation of the elements of  
Process Safety Management and the Accident Prevention Program.  Fort James encourages  
employees to participate with the understanding that their participation is a key factor to the  
success of any program.  Fort James is committed to maintaining a safe workplace, and as a  
result all employees are responsible for adhering to the PSM/RMP regulations.  Fort James has  
committed to the following: 
* Including employees in Process Hazard Analyses 
* Consulting employees on the development of PSM/RMP regulation elements 
* Providing employees with access to the information developed through the PSM and RMP  
A description of the Employee Participation Program is provided in the Process Safety  
Management central files. 
Process Safety Information 
Fort James provides company personnel with the necessary information about the process  
equipment to conduct their jobs in a safe manner.  A comp 
lete compilation of Process Safety  
Information (PSI) is made available to those involved in operating and maintaining the  
PSM/RMP regulated processes.  The PSI includes the following: 
* Hazards from chemicals used or produced by the process 
* Information pertaining to the technology of the process 
* Information pertaining to the equipment in the process 
Process Hazard Analysis 
Fort James' Accidental Release Prevention Program is designed to provide appropriate resources  
to make the working environment around regulated substances safe.  Fort James performed a  
Process Hazard Analyses (PHA) on each of the regulated processes in order to identify potential  
hazards.  Fort James will continue to update the hazard analysis at least every five years to assure  
that the PHA remains applicable to any process improvements and changes.  The level of detail  
in the PHA  is intended to be appropriate to the complexity of the process. 
Standard Operating Procedures 
Fort James provides approp 
riate resources to ensure that those personnel who work with these  
regulated processes have the knowledge necessary to make the working environment in the mill  
safe, and to protect the safety of the surrounding community and the environment.  Fort James  
has developed and implemented written operating procedures which provide clear instructions  
for safely conducting activities involved in each of the PSM/RMP-regulated processes.  The  
procedures are utilized by employees who work in or maintain the process.  The procedures  
address all operational phases, and are reviewed at least annually to ensure they remain up to  
date.  Copies of the Standard Operating Procedures are available in the corresponding control  
rooms.  The PSM Coordinator is responsible for notifying the supervisor of the process area the  
date by which the SOP needs to be re-certified.  The supervisor of the process is responsible for  
ensuring the manual is reviewed and certified annually. 
PSM Training 
Fort Jame 
s provides the appropriate resources to ensure adequate training of personnel involved  
in operating the regulated processes and to ensure that the jobs can be performed safely.  The  
training program includes initial training, refresher training, and training documentation. 
Employees currently involved in operating a regulated process, and employees being transferred  
into a regulated process, are trained in an overview of the process and in the standard operating  
procedures.  This initial training also includes emphasis on the specific safety and health hazards,  
emergency operations including shutdown, and safe work practices applicable to the employee's  
job tasks.  Refresher training is provided at least every three years to employees involved in  
operating a regulated process to assure that the employee understands and adheres to the current  
standard operating procedures of the process. 
Fort James verifies that each employee involved in operating a regulated process has recei 
and understood the required training.  A record is prepared that contains the identity of the  
employee, the date of training, and the means used to verify that the employee understood the  
PSM for Contractors 
Fort James periodically uses contractors to perform work in and around processes that involve  
regulated substances.  To ensure safety, Fort James has a screening process so that Fort James  
hires and uses contractors who have a commitment to safe work practices.  They have also  
developed a contractor safety program to inform and manage contract employees working in the  
PSM/RMP regulated systems, as well as other work in the mill.  
The contractor program includes all activities that have the potential for affecting process safety,  
including the performance of maintenance or repair, equipment installation, renovation,  
demolition, or specialty work on or adjacent to the PSM/RMP regulated processes.  The  
information in the mill-wide Contractor Safety Guidebook 
is presented by the mill contact to  
each contractor who is to work on site.  A form is signed which documents the training of the  
Fort James' contractors and the record is retained by the mill contact and in the purchasing  
Pre-Startup Safety Review 
Fort James has procedures to ensure any new regulated process, or any modification to an  
existing regulated process is as safe as possible before starting the system.  To assist in assuring  
safety, a Pre-Startup Safety Review (PSSR) is performed before regulated substances are  
introduced to the system.  The PSSR verifies the following information: 
* A PHA has been complete, if it is a new process 
* Construction/equipment is in accordance with the design specifications 
* SOPs are complete 
* Training is complete 
The supervisor of the area/construction project leader is responsible for ensuring a PSSR is  
Mechanical Integrity 
Fort James provides appropriate resources to ensure that the equipment used to proc 
ess, store, or  
handle regulated substances is designed, constructed, installed, and maintained to minimize the  
risk of releases of the regulated substances into the workplace or community.  To accomplish this  
goal, a Mechanical Integrity Program has been implemented to ensure the continued integrity of  
the processes.  The Mechanical Integrity Program has been implemented for the systems which  
could potentially result in the release of a hazardous chemical.  The program utilizes increased  
maintenance training, and preventive maintenance in conjunction with regular inspections and  
tests, to ensure equipment is in satisfactory condition. 
Hot Work/ Safe Work 
The objective of the Hot Work Permit is to consistently control non-routine work conducted in  
the process areas.  The Hot Work Permit System is specifically concerned with the permitting of  
hot work operations associated with welding and cutting on or near PSM/RMP regulated process  
areas.  The permits document compliance wi 
th the fire prevention and protection requirements.   
Additional safe work practices such as lockout/tagout, confined space entry, and control over  
entrance have also been implemented to increase facility safety. 
Management of Change 
Fort James manages all changes to processes regulated by PSM or RMP to ensure the processes  
are operated and maintained as safely as possible.  To assist in accomplishing this goal, a  
Management of Change Program has been implemented.  Management of Change examines any  
type of change which is planned for the process, and the basis of the change.  The Management  
of Change Program is designed to evaluate, approve and administer changes to PSM/RMP  
regulated processes to assure any changes implemented enhance the operation and safety of the  
system. The PSM Coordinator is responsible for ensuring all MOC forms are complete. 
Incident Investigation 
It is the policy of Fort James to investigate any incident which occurs in a process regulated by  
PSM or 
RMP, which could have or did result in a catastrophic release of a hazardous chemical in  
the workplace.  The Incident Investigation policy, procedures, and records of the Incident  
Investigations are available in the PSM Central Files. 
PSM/RMP Compliance Audits 
Compliance audits are utilized to evaluate the effectiveness of the PSM/RMP programs which  
have been implemented at Fort James.  The compliance audit is intended to identify any  
deficiencies or weaknesses in Fort James's policies, programs, or procedures, and take action to  
correct the deficiencies.  A compliance audit is performed at least every three years to verify that  
the systems required by the PSM and RMP Regulations are in place and have been implemented. 
Fort James has demonstrated a good record of accident prevention.  There has been one RMP- 
reportable accidental release at the Wauna mill during the past five years.  This incident involved  
a significant releas 
e of sulfur dioxide from a storage tank.  The emergency procedures at the  
Wauna Mill resulted in an effective response such that the release was quickly controlled and  
contained, and no off-site impacts occurred. 
The processes at the mill have been designed to minimize the potential for accidental releases.   
Section 7 of the Risk Management Plan includes checklists that itemize the monitoring methods  
and mitigations at each RMP-regulated process.  Table ES-2 briefly summarizes the key safety  
features for each of the processes regulated under the ARPP.  
This section describes the offsite consequence modeling to predict the downwind distance to the  
toxic endpoint concentrations as defined by EPA's ARPP regulations.  Modeling was done using  
both the EPA's RMP*Comp model as well as SLAB, which is a more sophisticated mathematical  
model used in in 
dustry.  The calculated distance for the Administrative Worst-Case Release was  
greater from the EPA model than from SLAB.  The result from the EPA model was chosen for  
reporting purposes as it represents the greatest potential impact, and therefore is the most  
conservative result for emergency planning purposes.   
 ES6.1  Administrative Worst-Case Release for Toxic Compound (Chlorine Dioxide) 
The administrative worst-case release (WCS) at the Wauna mill is a hypothetical release of the  
entire contents of the largest storage tank containing 54,500 gallons of 1.1% aqueous chlorine  
dioxide solution. In accordance with the RMP regulations, the entire contents of the tank (54,500  
gallons of dilute aqueous solution containing 5,000 lbs. of ClO2) was assumed to spill onto the  
ground in 10 minutes, resulting in the evaporation of a gas cloud in 10 minutes.  Fort James  
Corporation is unaware of any feasible event that could cause such a spill, and the modeling of  
this release is inc 
luded in this Risk Management Plan only for administrative completeness.   
The worst-case distance to the toxic endpoint concentration for chlorine dioxide (1.02 ppmv) was  
modeled using both the SLAB dispersion model and the EPA model RMP*Comp.  The  
mandated meteorological conditions for the WCS are 1.5 mps wind speed and F stability.  The  
surface roughness was assumed to be 0.5 meters,  based on the regional land use consisting of  
dense coniferous forest with some grassland and open water.  The SLAB model  
calculated an endpoint of 12.6 miles. Whereas the EPA model calculated the  
endpoint to be 14 miles. As listed in the checklists under Section 2.12 of this RMP, the Landview  
II database indicates a population of approximately 11,000 residents within the 14 mile radius.   
Potential environmental receptors are the Lewis and Clark National Wildlife Refuge, Julia Butler  
Hansen Wildlife Refuge, Beaver Creek Fish Hatchery, and Elkomin Fish Hatchery.  The  
Columbia River is used for 
both recreational activities and commercial traffic.  Oregon State  
Highway 30 is a primary traffic route between Longview, WA and Astoria, OR. 
The estimated population of 11,000 residents that might be affected by such a hypothetical release  
is conservatively high .  Even if an entire storage tank were somehow to be released during the  
worst-case atmospheric conditions, the steep terrain in the region would probably prevent the  
resulting chlorine dioxide cloud from migrating anywhere other than along the river valley.   
Under F stability conditions, light winds would not be able to transport the dense chlorine  
dioxide cloud to a height of more than about 400 feet above the release.  As a result, receptors  
situated at elevations  more than about 400 feet higher than the Wauna mill would probably not  
be impacted under EPA's stipulated worst case weather conditions.  It is reasonable to assume  
that only the low-lying areas along the Columbia River could be impacted.  Also, a gas 
will not disperse in a full circle, but only in the direction of the wind.  Therefore not everyone  
within the calculated zone would be at risk for any given release.   
 ES6.2  Wind Speed and Surface Roughness Used to Model Alternate Release Scenarios 
EPA's guidance for offsite consequence modeling suggests that "typical" meteorological data  
from a local meteorological station should be used to define the wind speed and atmospheric  
stability for the modeling of alternate release scenarios.   The guidance suggests that a wind  
speed of 3.0 meters per second should be considered for the Alternate Release scenarios,  unless  
the facility has data to support a different wind speed.  For the ARPP, Fort James reviewed PSD- 
quality meteorological data that were collected at the Wauna mill  in 1992-1993, and determined  
that a wind speed of 3.0 meters/second is a reasonable worst condition estimate.  
The downwind dispersion of a hypothetical dense-gas plume also depends on the as 
surface roughness. For the RMP*Comp model, a choice of Urban versus Rural surroundings  
needed to be made.  The surface roughness around the Wauna facility varies considerably  
depending on the land use, vegetation,  and topography.  The local land use in the area  
immediately north of the mill consists of open water and grassland along the Columbia River.  
However, the regional land use within a 5-mile radius of the Wauna mill consists mainly of  
dense coniferous forest and large hills which would create significant resistance to the movement  
of a gas cloud. Due to the proximity to the open water, a rural setting was chosen for the  
calculations and represents the worse conditions for a release. 
Based on these assessments of wind speed and surface roughness,  Fort James conducted the  
dispersion modeling using the following assumed conditions: 
Reasonable Conservative Conditions 
Wind speed = 3.0 meters per second 
Atmospheric stability = D 
Topography:  Rural Surroundings 
6.3  Alternate Release Scenario:  Chlorine Dioxide Aqueous Solution 
Chlorine dioxide (ClO2) is used as a bleaching agent.  It is manufactured at the Wauna mill, and  
is stored as a dilute aqueous solution in large, above-ground storage tanks.  The Alternate  
Release Scenario release event for the chlorine dioxide storage system assumes that a truck  
accident shears off a 4-inch valve at the largest ClO2 storage tank, and it takes 30 minutes to  
plug the broken valve.  The tank has a capacity of 54,500 gallons, and stores chilled aqueous  
ClO2 solution at a typical temperature of 40 deg. F and a typical storage concentration of 1%.   
Based on equations from EPA's Offsite Consequence Modeling Guidance, the calculated liquid  
flow rate from the 4-inch pipe is 1,200 gpm.  A total of 36,000 gallons of dilute solution,  
containing  3,300 pounds of ClO2, would be spilled from the tank during the hypothetical 30- 
minute accident. 
The ClO2 storage tanks are located in an area that is well des 
igned to mitigate a large release.   
Much of the  liquid that might be spilled would be captured by the containment curb that  
surrounds the tanks.  Spilled liquid contained in that area would quickly drain into the mill's  
process sewer.  Any spilled ClO2 solution that fell outside the containment curb would quickly  
flow into nearby sewer drains into the process sewer within seconds or minutes after the release.   
The mill's process wastewater contains routine organic and inorganic compounds that constitute  
Chemical Oxygen Demand (COD).  COD in the wastewater would quickly react with spilled  
ClO2, and would therefore reduce the potential for the ClO2 to volatilize to the atmosphere. 
As part of this ARPP emission estimate, Fort James staff conducted laboratory tests to confirm  
that the ClO2 in the spilled solution would react quickly with COD in the process  wastewater  
stream.  The tests confirmed the ClO2 was depleted within seconds after mixing with  
wastewater.  Therefore, the 
WATER8 modeling assumed that ClO2 that entered the process  
sewer would immediately be depleted by the available COD in the wastewater.  Only the amount  
of ClO2 that exceeded the mass of available COD would have the potential to volatilize to the  
The ClO2 emission rates from each of the following volatilization points were calculated using  
EPA's WATER8 model: 
* Spill from broken pipe fitting onto the ground. 
* Overland flow to sewer drains. 
* Volatilization within the 2,500 foot long sewer. 
* Bar screen and pump station. 
* Primary clarifier. 
The WATER8 model predicted that only a small fraction of the ClO2 in the spilled solution  
would volatilize in the sewer, pump station, and wastewater plant. Only about half of the ClO2  
that spills from the storage tank was modeled to volatilize, while the remainder was modeled to  
deplete by reaction with compounds in the wastewater plant.  WATER8 calculated that a total of  
1,650 pounds of ClO2 would volatilize to the atmosphe 
re during the 30-minute spill and the 10- 
minute period it would take for the spilled solution to flow into the sewer. 
Based on the preceding information, the SLAB dispersion model was used to estimate the  
downwind distance to EPA's toxic endpoint concentration of 1.0 ppm for ClO2.  The distance  
calculated by this model is 1.5 miles.   
This scenario was also modeled using the EPA RMP*Comp model.  In EPA's model, it is  
assumed that all of the ClO2 is in a gaseous vapor rather than a water solution, and all of this  
material is disbursed into the air.   Therefore the results of the calculations using a total of 3,300  
lbs. of ClO2 released over a 30 minute period shows a larger estimated downwind distance to  
EPA's toxic endpoint concentration than that calculated using SLAB.  This model estimates an  
impact distance of 2.2 miles. The modeled distance to the 1.0 ppm toxic endpoint extends north  
to the lightly populated area on Puget Island, Washington and eastward to the town of We 
OR.  The calculated distance for the Alternate Release for Chlorine Dioxide was greater  
from the EPA model than from SLAB.  The result from the EPA model was chosen for reporting purposes  
as it represents the greatest potential impact, and therefore is the most conservative result  
for emergency planning purposes.   
The Wauna mill has always maintained a rigorous emergency response program to work with  
emergency staff at nearby communities in the unlikely event of a major chemical release.   
Section ES-7 describes how Fort James has updated their existing program to satisfy the  
requirements of EPA's ARPP. 
 ES6.4  Alternate Release Scenario:  Anhydrous Sulfur Dioxide 
Anhydrous sulfur dioxide (SO2) is used in both the kraft and groundwood bleaching processes at  
the mill.  The SO2 is stored in four 1,000-gallon tanks at ambient. Fort James maintains written  
procedures that limit the capacity of each tank to 800 gallons.  The hypothetical alternate release  
scenario for  
sulfur dioxide assumes that the truck driver delivering bulk SO2 to the tanks  
deviates from the written procedures and accidentally drives away without disconnecting the fill  
hose, and breaks the 1-inch fill line on one of the tanks. It is assumed that SO2 sensors located at  
the tanks would alert the mill's operating crew who would investigate and call the mill's emergency  
responders, and it would take 10 minutes to respond and plug the  
broken fitting. 
The liquid fill line on each of the SO2 tanks is equipped with an in-tank flow restrictor that  
would limit the flow rate to 45 gallons per minute, which corresponds to an accidental release  
rate of 554 lbs/minute. The SO2 emissions from the tank would have a very low temperature  
equal to  the SO2 boiling point (14 degrees F).  The cold SO2 would form a dense gas cloud. 
The RMP*Comp dispersion model was used to calculate the distance to the 3.0 ppm toxic  
endpoint concentration for SO2. This model predicts a distance to the toxi 
c endpoint of 1.1  
miles. The modeled  distance to the 3.0 ppm toxic endpoint extends northward to the lightly  
populated shore of Puget Island. 
 ES6.5  Alternate Release Scenario:  Anhydrous Ammonia 
Anhydrous ammonia is stored in a 12,000-gallon storage tank at ambient temperature, for use in  
controlling NOx emissions from the mill's fluid bed boiler.  The tank is inside a concrete  
containment dike, and it is located where it has no significant exposure to  damage by ammonia  
delivery trucks or other plant vehicles. The storage tank is equipped with area sensors to detect  
ammonia releases, and is equipped with an emergency water scrubber to automatically mitigate  
any minor releases emitted from pressure relief valves.  The emergency scrubber is designed to  
deluge any ammonia releases with cold water.   If the emergency scrubber is activated during a  
release, it would discharge the diluted ammonia solution downward into the containment dike. 
The hypothetical alternative rele 
ase scenario for anhydrous ammonia assumes a combination of  
two simultaneous accidental events: 
* First, it is assumed that a delivery truck driver deviates from the mill's written procedures and  
accidentally overfills the ammonia tank, causing a temporary over-pressurization and activating  
one of the pressure relief valves on the tank.  The pressure relief valve would divert the ammonia  
to the emergency water scrubber. 
* Second, it is assumed that the water flow to the emergency water scrubber fails to activate,  
resulting in the release of pure ammonia gas downward into the concrete containment dike  
surrounding the tank.  It is assumed that it would take 10 minutes for the mill's emergency  
responders to arrive at the tank with a fire truck to deluge the malfunctioning scrubber and  
reduce the ammonia release to a small fraction of its original, uncontrolled rate. 
For purposes of modeling the maximum ambient impacts, it was assumed that all of the ammonia  
gas that is acciden 
tally discharged from the malfunctioning scrubber is emitted  into the  
atmosphere during the initial 10-minute period.  The calculated ammonia release rate is 300  
lbs/minute.  The ammonia would be released from the tank as a gas at its boiling point  
temperature (-29 degrees F).  Ammonia is lighter than air, so the emitted ammonia would  
quickly rise as it blew downwind and warmed up. The SLAB dispersion model predicts that the  
ammonia cloud would quickly rise to a height of about  200 feet. 
The EPA's RMP*Comp dispersion model was used to calculate the distance to the 200 ppm toxic  
endpoint concentration for ammonia. The  modeled distance to the toxic endpoint concentration  
is  0.3 miles.  The modeled 0.3 mile distance does not extend to any local towns, and the  
LANDVIEW database did not indicate any residents within the 0.3 mile circle.   
This section briefly describes the mill's existing emergency response program,  with em 
phasis on  
how it addresses accidental releases of the chemicals regulated under the ARPP. 
 ES7.1  General Structure of Wauna's Emergency Response Program 
The mill's Emergency Response Program uses the following written procedures and  
* Wauna Mill Emergency Response Program.  This document is the general guideline for action  
to minimize impacts to employees, facilities, and the off-site public.  The thrust of this general  
plan is to pre-define the general methods for responsibility, authority, and communication.   
* Clockroom Emergency Procedures, Fort James Operating Company, Wauna Mill.  These are  
itemized checklists, call-down lists and decision diagrams to be used by the clockroom operator  
to coordinate initial notifications and communication during the early stages of an emergency  
* Training Records - The mill's training records for the hazardous materials response staff are  
maintained on computer and in written files at the Fire Station.  Tra 
ining records for the federal  
OPA-90 responders is kept in written files at the mill's Fire Hall and at the Environmental  
 ES7.2  In-Mill Response to Accidental Releases of  ARPP-Regulated Chemicals 
The mill maintains its own emergency response team that coordinates with off-site responders  
from the local communities.   The mill's written emergency response procedures itemize the  
organizational structure, emergency response equipment, mitigation measures, and  
communication procedures to be used.  The mill maintains written procedures in the use and  
maintenance of equipment to be used to contain and mitigate accidental releases. 
 ES7.3  Notification of Local Communities and Off-Site Emergency Responders 
The Wauna mill maintains procedures to immediately contact key emergency response staff in  
local communities in both Oregon and Washington in the event of a large release.   In addition,  
the Wauna mill maintains a loudspeaker system for the mill and closest neig 
hbors of the mill.   
This loudspeaker system can automatically be activated by the mill's emergency response  
coordinator to provide immediate verbal information to the local residents.   
 ES7.4  Documentation of First Aid and Medical Treatment for ARPP-Regulated Chemicals 
The mill's emergency response documents include a compilation of written materials on the  
health impacts and first aid procedures for each of the ARPP-regulated substances.  Information  
packets have been distributed to the emergency response staff in the local communities in both  
Oregon and Washington.  
 ES7.5  Training and Emergency Response Drills 
The mill maintains training procedures to ensure that the on-site emergency staff are trained in  
the management structure, response procedures, emergency equipment, and communication  
methods that are used in the event of a release.  The mill conducts periodic training of on-site  
staff, and maintains written records to document the most recent training.   
mill conducts the following drills: 
* On-site spill drills to simulate an actual release.  During these drills the emergency response  
teams communicate with the on-site emergency response coordinator, assemble all required  
mitigation equipment, simulate the release containment, simulate first aid procedures, and  
conduct all required communication. 
* Communication drills to quickly contact the local communities that would be impacted by a  
simulated release. 
After each drill the response teams evaluate their performance, and make appropriate  
adjustments to the emergency response procedures. 
Table ES-1 
Summary of Substances and Processes Regulated Under the ARPP Program 
Fort James, Wauna Mill 
Substances Subject to ARPP: 
RMP-Regulated Chemical   RMP-Regulated Mill Process               RMP Program 
Sulfur Dioxide           Sulfurous Acid Manufacture, includes        Program 3 
                                 storage of anhydrous sulfur dioxide. 
Anhydrous Ammonia    Fluid bed 
boiler NOx control system,       Program 3 
                                     includes storage of anhydrous ammonia 
Chlorine Dioxide            R-8 reactor system; includes                   Program 3 
Aqueous Solution         storage of dilute, aqueous chlorine  
                                    dioxide solution. 
Substances NOT Regulated Under ARPP    Mill Process 
Propane                                                        Small propane tanks at several locations. 
Methanol                                                        ClO2 Manufacture 
Dilute Aqueous Ammonia (15% strength)     Waste water treatment plant nutrient 
Summary of Safety Features at RMP-Regulated Mill Processes 
1. RMP-Regulated Chemical: Chlorine Dioxide  
RMP-Regulated Mill Process: R-8 reactor and storage, including two 54,500 gallon storage tanks and two 38,500 gallon storage tanks for  
nominal 1% aqueous solution 
Status of PSM Process Hazard Analysis: Complete 
Safety Features to 
Mitigate Accidental Releases 
    Release Detection:   Process area monitors  
    Release Containment or Control:   Containment curb around the ClO2 storage tanks. 
2. RMP-Regulated Chemical: Sulfur Dioxide 
RMP-Regulated Mill Process: Sulfurous Acid Manufacture, includes four 10,000 pound tanks of  
anhydrous sulfur dioxide 
Status of PSM Process Hazard Analysis: Complete 
Safety Features to Mitigate Accidental Releases 
    Release Detection:   Process area monitors  
    Release Containment or Control:   Excess flow control valves on discharge 
                                                           pipes from the storage tanks. 
3. RMP-Regulated Chemical: Anhydrous Ammonia  
RMP-Regulated Mill Process: Fluid bed boiler NOx control system, includes 12,000 gallon tank  
of anhydrous ammonia 
Status of PSM Process Hazard Analysis: Complete 
Safety Features to Mitigate Accidental Releases 
    Release Detection:   1. Excess flow detection  
  2. Pressure relief valves 
                                     3. Process area monitors 
    Release Containment or Control:    1. Containment dike around storage tank. 
                                                            2. Emergency scrubber to control releases 
                                                                from pressure relief valves.
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