WAUNA MILL - Executive Summary
EXECUTIVE SUMMARY |
ES.1 FORT JAMES OPERATING COMPANY'S POLICY ON ACCIDENTAL RELEASE
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.
ES.2 DESCRIPTION OF WAUNA MILL AND REGULATED SUBSTANCES
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
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
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.
ES.3 ACCIDENTAL RELEASE PREVENTION PROGRAM AT THE WAUNA MILL
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.
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.
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
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.
It is the policy of Fort James to investigate any incident which occurs in a process regulated by
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.
ES.4 5-YEAR ACCIDENT HISTORY AT THE WAUNA MILL
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.
ES.5 SUMMARY OF SAFETY FEATURES AT REGULATED PROCESSES
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.
ES.6 MODELING OF OFF-SITE CONSEQUENCES OF HYPOTHETICAL ACCIDENTAL
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-
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
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
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.
ES.7 EMERGENCY RESPONSE PROGRAM AT THE WAUNA MILL
This section briefly describes the mill's existing emergency response program, with em
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
After each drill the response teams evaluate their performance, and make appropriate
adjustments to the emergency response procedures.
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
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.