Consolidated Papers, Inc. - Water Quality Center - 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 Water Quality Center (WQC) 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 WQC.  This document is intended to satisfy the risk management plan requirements of the RMP rule. 
In April 1967, CPI adopted a corporate environmental policy that guides the continuous improvement of its enviro 
nmental 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 
release 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. 
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 W 
isconsin 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 located in Duluth, Minnesota. 
WQC is a wastewater treatment plant owned and operated by CPI in Wisconsin Rapids, Wisconsin.  This facility treats wastewater generated by the pulp and paper mill operations in the Wisconsin Rapids area.   
Ammonia (with a concentration of 20% or greater) is the only chemical regulated by the RMP rule that is stored or handled at this facility with a concentration greater than or equal to the concentration de minimis level and a total quantity greater than or equal to the threshold quantity.  The aqueo 
us ammonia is stored in a horizontal aboveground tank with a design capacity of 18,000 gallons.  The ammonia solution has a concentration of 29.4% by weight ammonia.  The maximum amount of ammonia in the solution is 39,607 lb.  The tank is surrounded by a dike.  The dike is assumed to contain at least 25% of the tank's capacity.  The dike floor is sloped to a drain.  Aqueous ammonia is a toxic liquid and is used as a nutrient for the wastwater treatment plant micro-organisms. 
Worst-Case Release Scenario 
The worst-case scenario at the WQC is defined as the rupture of the aqueous ammonia storage tank, instantaneously releasing its entire contents directly to the surrounding ground.  The tank stores approximately 134,718 lb (18,000 gallons) of aqueous ammonia.  The aqueous ammonia has a concentration of about 29.4% by weight ammonia, which equates to 39,607 lb of ammonia.  The dike around the tank is able to confine at least 25% of  
the spilled contents.  It is assumed that the ammonia that flows into the dike will not be released into the atmosphere, as the dike floor is sloped to a closed drain system.  The ammonia that overflows the dike (29,705 lb of ammonia in 13,500 gallons of aqueous ammonia or less) is assumed to evaporate into the atmosphere.  This scenario was modeled using a chemical specific evaporation model to calculate the release rate and the SLAB dispersion model to predict the toxic endpoint.  The worst-case release of ammonia is predicted to have no offsite impact on public or environmental receptors. 
Alternative Release Scenario 
Since the worst-case scenario predicted no offsite impact, an alternative case scenario is not required. 
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 exist 
ing facilities to ensure that they meet all legal requirements through the use of safe technologies and operating procedures. 
WQC complies with the prevention and emergency response procedures from all applicable regulations. 
There have been no accidents at the Water Quality Center in the past five years that resulted in any adverse onsite or offsite impacts. 
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. 
WQC has a written emergency response procedure to respond to accidental releases of hazardous substances. 
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.
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