Consolidated Papers, Inc. - Biron Division - Executive Summary |
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Consolidated Papers, Inc. (CPI) is committed to operating in a manner that is safe for CPI workers, the public, and the environment. As part of this commitment, CPI has established procedures to help ensure safe operation of the processes at its facilities. CPI's Biron Division (Biron) has developed a risk management program (RMP) that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR Part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule) and helps to manage the risks of the covered substances and processes. One of the requirements of the RMP rule is to submit a risk management plan describing the risk management program at Biron. This document is intended to satisfy the risk management plan requirements of the RMP rule. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES In April 1967, CPI adopted a corporate environmental policy that guides the continuous improvement of its environm ental performance as it strives to prevent pollution and achieve the objective of operating facilities with minimal environmental impact. This policy was updated in November 1996. The corporate environmental policy statement is publicly available on CPI's Internet website. As part of its risk reduction objective, CPI will strive to minimize environmental, health, and safety risks to its employees and the communities in which it operates by employing safe technologies and operating procedures. CPI will be constantly prepared for emergencies. CPI will continually inform its employees and public of its progress in safety and environmental issues. CPI is one of 26 Wisconsin paper companies voluntarily participating in the Wisconsin Paper Council's Pollution Prevention Partnership with the Wisconsin Department of Natural Resources. As part of this membership, CPI produces an annual report that illustrates CPI and the Wisconsin paper industry's commitment to voluntarily reduce the r elease of substances that could have adverse environmental impacts. CPI's Pollution Prevention Partnership Progress Report is available to the public. CPI has also pledged to voluntarily align its corporate Environmental Management System to ISO 14001 international standards and to adhere to the American Forest and Paper Association's Environmental Health and Safety Principles. FACILITY DESCRIPTION AND THE REGULATED SUBSTANCES HANDLED CPI is North America's largest producer of coated printing papers and a major manufacturer of supercalendered printing papers for the printing and publishing industries. In addition, CPI is the leading manufacturer of coated specialty papers used in consumer product packaging and labeling. CPI also produces elemental chlorine-free kraft pulp for its own use from virgin wood fiber and recycled pulp from printed and post-consumer wastepaper. Other products manufactured by CPI include paperboard and paperboard products. CPI is headquartered in Wis consin Rapids, Wisconsin. It owns and operates paper and pulp manufacturing facilities in Biron, Kimberly, Appleton, Niagara, Stevens Point, Whiting, and Wisconsin Rapids, Wisconsin, as well as in Duluth, Minnesota. It also operates wastewater treatment plants in Stevens Point, Niagara, Kimberly, and Wisconsin Rapids, Wisconsin to treat wastewater generated by the pulp and paper manufacturing plants. Wastewater treatment is also done at the facilities in Duluth, Minnesota. Biron is a pulp and paper mill owned and operated by CPI in Wisconsin Rapids, Wisconsin. At this facility, groundwood pulp and thermomechanical pulp are produced and then used to manufacture lightweight groundwood coated printing papers. The coated paper product is used for brochures, advertising inserts, corporate annual reports and brochures, catalogs, magazines, and other printed materials. Sulfur dioxide and chlorine are the chemicals regulated by the RMP rule that are stored or handled at this facility i n total quantities greater than or equal to the threshold quantities. The sulfur dioxide is stored in a horizontal aboveground tank with a design capacity of 9,000 gallons (109,810 lb of sulfur dioxide). Administrative controls limit the quantity of sulfur dioxide stored in the tank to 80% of capacity or 7,200 gallons (87,848 lb). Sulfur dioxide is a toxic gas liquefied by pressure in the storage tank and is used to bleach pulp. Chlorine is stored in eight aboveground cylinder tanks, each with a design capacity of one ton. The total quantity of chlorine stored at this facility is 16,000 lb. The chlorine tanks are used inside a building. Chlorine is a toxic gas liquefied by pressure in the storage tank and is used to treat process water. WORST-CASE RELEASE AND ALTERNATIVE RELEASE SCENARIOS Worst-Case Release Scenarios Two worst-case release scenarios at Biron were analyzed, both involving toxic substances (sulfur dioxide and chlorine.) The worst-case release scenario involvi ng sulfur dioxide is defined as the rupture of the sulfur dioxide storage tank, instantaneously releasing its entire contents directly to the surrounding ground. With the administrative controls that limit the tank storage to 80% of the tank's design capacity, the tank stores approximately 87,848 lb (7,200 gallons) of sulfur dioxide. Prior to unloading a shipment of sulfur dioxide, the Pulp Mill Shift Supervisor verifies that the load can be added to the tank while maintaining less than 80% capacity. The tank truck driver monitors the unloading process under the supervision of the pulp mill shift supervisor until it is concluded. The entire spill is assumed to evaporate into the atmosphere. A drain system around the tank would be able to direct the spilt tank contents to the process sewer within 10 minutes. However, for this worst-case scenario, the entire tank contents are assumed to evaporate into the atmosphere within 10 minutes. This scenario was modeled using the Dense Gas Dispersion (DEGADIS) model to predict the toxic endpoint. The worst-case release of sulfur dioxide is predicted to have offsite impacts on public receptors. The worst-case release scenario involving chlorine is defined as the rupture of one of the eight chlorine storage tanks, instantaneously releasing its entire contents into the building. The building enclosure contains the entire spill and reduces the release rate into the atmosphere. The release rate from the building is based on the Environmental Protection Agency's (EPA) RMP Offsite Consequence Analysis Guidance document. This scenario was modeled using the Dense Gas Dispersion (DEGADIS) model to predict the toxic endpoint. The worst-case release of chlorine is predicted to have offsite impacts on public receptors. Alternative Release Scenarios Since the worst-case release scenario predicted offsite impacts, an alternative release scenario involving sulfur dioxide is reported. The alternative release scenario is defined as a failure of the tubing connecting the sulfur dioxide tank to the process equipment. Approximately 57,144 lb of sulfur dioxide are released. The Areal Locations of Hazardous Atmospheres (ALOHA) model was used to predict the toxic endpoint. The worst-case release of sulfur dioxide is predicted to have offsite impacts on public receptors. Since the worst-case release scenario predicted offsite impacts, an alternative release scenario involving chlorine is reported. The alternative release scenario is defined as an indoor release of chlorine due to the failure of the tubing connecting the chlorine tank to the water chlorination process. The total quantity of chlorine released into the building is 88.6 lb. The building enclosure contains the entire spill and reduces the release rate into the atmosphere. The release rate from the building is based on the EPA's RMP Off-site Consequence Analysis Guidance document. This scenario was modeled using the Areal Locations of Hazardous A tmospheres (ALOHA) model to predict the toxic endpoint. The worst-case release of chlorine is predicted to have no offsite impact on public or environmental receptors. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS As part of its corporate environmental policy, CPI will continue to protect the environment and the health and well-being of fellow employees and communities by monitoring existing facilities to ensure that they meet all legal requirements through the use of safe technologies and operating procedures. Biron complies with the prevention and emergency response procedures from all applicable regulations including certain applicable sections of RCRA and the Occupational Safety and Health Administration (OSHA) Emergency Action Plans (29 CFR 1910.38). FIVE-YEAR ACCIDENT HISTORY There have been no accidents at the Biron Division in the past five years that resulted in any adverse onsite or offsite impacts. EMERGENCY RESPONSE PROGRAM Biron's emergency response program includes a written Emergency Response Plan that discusses procedures to be followed in the case of a general emergency and specific procedures for the handling of sulfur dioxide and chlorine spills to prevent and minimize the effects of an emergency involving these chemicals. CPI has a Corporate Spill Reporting Policy that addresses the notification requirements in the event of an accidental release. The Corporate Spill Reporting Policy also identifies contacts and notification responsibilities. Biron has an internal response procedure to address all chemical spills. The basic responsibility for the employee is to first protect human safety. The employee protects themself and other personnel working in the affected area. The employee is then responsible for notifying his or her supervisor who will coordinate the appropriate response. If the situation requires HAZMAT response, the pulp mill shift supervisor will initiate a HAZMAT response and e stablish an incident command. The only exception is in the case of fire and/or explosion, in which case the incident command will be transferred to the Biron Fire Department when they are present. Biron has specific response plans for chlorine and sulfur dioxide. In the response, the responsible shift supervisor will communicate with the division environmental staff to ensure proper agency notifications are given as outlined in the Corporate Spill Reporting Policy. Specialized training in handling chlorine cylinder leaks and sulfur dioxide releases is part of the regular training for HAZMAT teams. In the case of chlorine, vendor emergency response is available for support from Vulcan Chemical and Hydrite Chemical. HAZMAT response includes coordination with the Wood County Sheriff Department and the Biron Fire Department. Biron personnel maintain onsite incident command except as previously noted. The division has mutual aid agreements with the HAZMAT response team from Plover, Wisconsin for additional onsite support. Wood County Emergency Government Agency would be called upon in the case of community involvement and would aid in coordinating local emergency response organizations in the affected area. PLANNED CHANGES FOR SAFETY IMPROVEMENTS This facility will undergo regular scheduled maintenance and update to meet any new or revised applicable regulation and industry standard to continue to operate safely. Biron is currently evaluating trials to replace or reduce the usage of chlorine gas. The potential elimination of sulfur dioxide is being evaluated. |