Consolidated Papers, Inc. - Kraft 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 Kraft Division (Kraft) 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 Kraft. 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. Kraft is a pulp mill owned and operated by CPI in Wisconsin Rapids, Wisconsin. At this facility, kraft pulp is manufactured from virgin fiber using an elemental chlorine-free process. The kraft pulp product is then used at various CPI paper mills for papermaking. The kraft pulp bleaching process in the manufacture of kraft pulp involves chemically treating the wood pulp fibers to reduce or remove lignin and resin. In the late 1980s and early 1990s, CPI took voluntary steps to eliminate the use of elemental ch lorine from its pulp-bleaching process by implementing a multi-million dollar multiphase chlorine-elimination program. In late 1996, CPI eliminated elemental chlorine from their entire kraft (chemical) pulp-bleaching process, thus achieving the commonly referred to position of elemental chlorine-free (ECF). CPI's mechanical pulps were already being bleached using a totally chlorine-free (TCF) process. Chlorine dioxide and chlorine are the chemicals regulated by the RMP rule that are stored or handled at this facility in total quantities greater than or equal to the threshold quantities. Chlorine dioxide is generated onsite as a gas under a slight vacuum and absorbed into water. The chlorine dioxide liquid solution is stored in tanks and is used to bleach pulp. The chlorine dioxide solution is stored in three vertical aboveground tanks with design capacities of 60,000 gallons, 60,000 gallons, and 103,000 gallons. The chlorine dioxide solution has a concentration of 1% by weight o f chlorine dioxide. Thus, the total quantity of chlorine dioxide stored at Kraft is 18,609 lb. The three chlorine dioxide tanks are partially located inside a building. Chlorine is stored in nine aboveground cylinder tanks, each with a design capacity of one ton. The total quantity of chlorine stored at this facility is 18,000 lb. The chlorine cylinders are kept inside a building. Chlorine is a toxic gas liquefied by pressure in the cylinder and is used to treat process water. WORST-CASE RELEASE AND ALTERNATIVE RELEASE SCENARIOS Worst-Case Release Scenarios Two worst-case release scenarios at Kraft were analyzed, both involving toxic substances (chlorine dioxide and chlorine.) The worst-case release scenario involving chlorine dioxide is defined as the rupture of the largest chlorine dioxide storage tank, instantaneously releasing its entire contents directly into the building. The largest chlorine dioxide tank stores 8,595 lb of chlorine dioxide. The building enclosure contains the entire spill and reduces the release rate into the atmosphere. This scenario was modeled using a chemical specific evaporation model to calculate the release rate and the Environmental Protection Agency's (EPA) Offsite Consequence Analysis Guidance document to predict the toxic endpoint. The worst-case release of chlorine dioxide is predicted to have offsite impacts on public and environmental receptors. The worst-case release scenario involving chlorine is defined as the rupture of one of the nine 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 EPA's RMP Off-site 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 chlorine dioxide is reported. The alternative release scenario is defined as an indoor spill due to a leak in the piping connecting the largest chlorine dioxide tank to the process. The amount of the spill is 1,000 gallons of aqueous chlorine dioxide solution. The quantity of chlorine dioxide in the 1,000-gallon aqueous solution spill is 83 lb. The building enclosure contains the entire spill and reduces the release rate into the atmosphere. This scenario was modeled using a chemical specific evaporation model to calculate the release rate and the EPA's Offsite Consequence Analysis Guidance document to predict the toxic endpoint. The alternative release of chlorine dioxide is predicted to have offsite impacts on public and environmental receptors. Since the worst-case release scenario predicted offsite impacts, an alternativ e 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 Atmospheres (ALOHA) model to predict the toxic endpoint. The alternative 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 monito ring existing facilities to ensure that they meet all legal requirements through the use of safe technologies and operating procedures. The Kraft Division 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 Kraft Division in the past five years that resulted in any adverse offsite impacts. On July 13, 1995, bleached stock from process equipment was spilled into the Phase 3 construction site within the Kraft facility. This spill caused respiratory distress and injury to seven non-Kraft Division employees and three Wiscon Rapids police officers who responded to the call. No one offsite was injured. EMERGENCY RESPONSE PROGRAM Kraft's emergency response program includes a written Emergency Response Plan that discusses procedures t o be followed in the case of a general emergency and specific procedures for the handling of chlorine dioxide and chlorine spills to prevent and minimize the effects of an emergency involving these chemicals. Kraft's current Emergency Response Plan works with the Incident Command System. The Incident Command System is designed to provide both public and private sector emergency response personnel with a logical building block system for managing hazardous material emergencies. The system is designed to begin at the point where emergency response personnel recognize that they are in fact, dealing with a hazardous material emergency, even when the exact hazardous material has not be identified. The local fire department is also trained to the Incident Command System and will join with the Kraft team members and co-command on an incident. The Incident Command System identifies a chain of command in response situations. It also identifies specific responsibilities for the various le vels in that chain. Kraft has trained incident commanders, specialists, and technicians. Additionally, 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. Kraft conducts incident investigations for all events, including minor situations that involve chlorine and/or chlorine dioxide. 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. |