Westvaco Corporation - Kraft Division - Executive Summary

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About Westvaco 
Westvaco is a major manufacturer of paper, envelopes, packaging 
and specialty chemicals.  The company employs nearly 13,400 
people and manufactures its products in the United States, Brazil 
and the Czech Republic.  Other holdings include nearly 1.5 
million acres of forest and a real estate development business. 
 
Today, three of Westvaco's corporate divisions -- Forest 
Resources, Kraft and Chemical -- are headquartered in Summerville 
and North Charleston.  Westvaco products manufactured in South 
Carolina are known as market leaders in domestic and export 
markets. Our paper mill in North Charleston manufactures 
unbleached paper used to make decorative laminates for surfaces 
like kitchen countertops and office furniture.  Our high-strength 
paperboard is also used in the manufacture of a variety of 
familiar food containers and drink cartons.  In addition, 
Westvaco's lumber mill produces framing lumber and construction 
timbers. 
 
Efficient use of all resources is a trademark  
of Westvaco 
operations.  Natural by-products of the papermaking process are 
the raw materials for specialty chemical products manufactured by 
Westvaco at its North Charleston Chemical Division facilities. 
These specialty chemical products set market standards around the 
globe.  They are used in the manufacture of a variety of goods 
like rubber and plastics, soaps, asphalt, textile dyes and 
printing inks. 
 
Westvaco emphasizes product and service differentiation.  As part 
of the company=s strategy, we are also unequivocally committed to 
total compliance with environmental, safety and health 
regulations. 
 
Westvaco and Chlorine 
Westvaco uses chlorine in 90-ton rail cars to treat water before 
it is used in the papermaking process, and to control filamentous 
bacteria growth in an industrial waste treatment plant.  Prior to 
use, the chlorine rail cars are staged on a separate track 
referred to as the Haz-Mat track. 
At low concentrations chlorine is commonly used to make solvents, 
disinfectant 
s and chlorine bleach cleaners. 
 
Exposure to chlorine can cause irritation of the eyes, nose and 
throat.  Exposure to extremely high levels can damage the lungs 
and cause a buildup of fluid which can be life-threatening. 
 
Protection of the health and safety of our employees and 
residents of our communities is our highest priority when dealing 
with chlorine safety.  When we handle chlorine, we make every 
effort to safeguard people and the environment.  Multiple 
safeguards are in place to ensure that we handle chlorine safely. 
We also work closely with other members of our industry, local 
officials and the public to maintain stringent safety and 
environmental programs and to minimize risks. 
 
Five-Year Accident History 
Westvaco=s commitment to the safe transportation, storage and 
handling of chlorine has prevented any accidents in the past five 
years of chlorine handling operations. 
 
 
Emergency Response 
Westvaco has plans in place for handling emergencies -- fires and 
natural disasters as 
well as chemical incidents.  First and 
foremost, our goal in any chemical incident is to contain any 
release as quickly as possible and to minimize the impact on the 
facility and its neighbors.  If an incident occurs: 
<    Automatic safety valves close quickly to seal off chlorine 
    supply; 
<    Plant alarms will sound, the emergency communicated to all 
    site personnel over the mill-wide alert system and emergency 
    response teams will be activated; 
<    Westvaco Environmental Services personnel will be alerted, 
    and if necessary, perform computer modeling to estimate area 
    affected by release; and 
<    North Charleston Fire Department will activate local and 
    county response teams if needed. 
 
Training and Preparation 
We train employees on safe handling of chlorine and prepare to 
respond appropriately to incidents should they occur.  This 
training and preparation includes: 
<    Trained and qualified emergency response teams composed of 
    Westvaco employees are 
on-site around the clock take prompt 
    action using the facility's fire truck, ambulance, and hazardous 
    materials unit; 
<    Emergency response systems in place, including plant wide 
    alarms, radios linked to North Charleston Fire Department, and an 
    accessible water supply; 
<    Routine emergency drills conducted in conjunction with the 
    county emergency preparedness office and the Local Emergency 
    Planning Committee (LEPC); and 
<    Action plans and community alert procedures in the event 
    outside assistance is needed or potential for off-site impact 
    exists. 
 
Accidental Release Prevention 
Designing for Safety 
Westvaco maintains wide-ranging systems to reduce the likelihood 
of incidents, including: 
<    Safe chlorine containment in a rail car with steel inner 
    core, an insulation layer to maintain temperature and a 
    protective steel outer cover; 
<    Solid steel barriers that prevent other transportation 
    equipment from damaging rail cars; 
 
<    Special hose connections to prevent an improper link to rail 
    car during chlorine transfer; 
<    Transfer of chlorine under vacuum to assure safe and 
    complete clearance of lines; 
<    Elevated transfer lines to protect them from ground traffic; 
<    Valves that close if chlorine is released suddenly; 
<    Monitoring equipment linked to alarm systems with automatic 
    chlorine shutoff valves; 
<    A Haz-Mat track for temporary storage remotely located 
    inside the mill, 
    and 
<    Twenty-four hour monitored surveillance systems for rail 
    cars and track. 
 
 
Assuring Safe Operations 
We audit our safe handling procedures and maintain our equipment 
to assure consistent safe operation of the chlorine handling 
system.  These activities include: 
 
<    Adherence to written operating procedures with checklists 
    which must be followed for all operations; 
<    Complete and detailed safety reviews prior to any changes to 
    the operation or equipment; 
<    Routine in 
spection of all instruments and control devices to 
    assure optimal efficiency and effectiveness; 
<    Preventative maintenance to assure equipment is safe, 
    reliable and efficient; 
<    Safety and Environmental audits to assure compliance with 
    all regulations and Westvaco=s stringent corporate standards for 
    safe handling. 
 
Planned Safety Improvements 
Westvaco maintains a proactive approach to safety, and 
continuously monitors developments in chlorine handling safety. 
New mitigation and control technologies are thoroughly reviewed 
for effectiveness and applicability to our process. 
 
Managing Risks 
As part of our commitment to comply with the laws and regulations 
of local, state and federal agencies, Westvaco has developed a 
risk management plan under the guidelines established by the 
Environmental Protection Agency (EPA).  Under these guidelines, 
facilities that handle specific quantities of regulated chemicals 
must submit plans that show the consequences of certain ch 
emical 
releases and outline the measures taken to reduce the risk and 
minimize the effects of these releases. 
 
Worst-Case Scenario 
Even though the possibility of this kind of hypothetical scenario 
occurring is extremely remote, the EPA defines a worst-case 
scenario as what might happen if all of the chlorine in 
Westvaco's largest holding container was released and every 
safety system failed. 
 
Chlorine used in the papermaking process and the wastewater 
treatment plant (WWTP) at Westvaco is handled similar to the way 
WWTP=s handle their chlorine.  Therefore, the EPA RMP guidance 
for WWTP=s was used to estimate a potential plume length of 14 
miles for this scenario.  The worst case scenarios for all three 
(3) covered processes is identical. Because of the length of the 
chlorine plume this scenario has the potential for an off-site 
impact. 
 
The worst case scenario assumes: 
<    Complete failure of a full 90-ton (180,000 pounds) rail car 
    containing chlorine liquid and gas, with full co 
ntents released 
    to the atmosphere in 10 minutes; 
<    Complete failure of all safety systems; 
<    No action taken to stop release or minimize effects; and 
<    Failure occurs during meteorological conditions of 3.4 mph 
    wind speed and stable atmospheric conditions (770F and 50% 
    relative humidity). 
 
Alternate Scenario 
The plan also includes a more-likely scenario in which we 
approximate the effects of a hypothetical release of chlorine in 
which the safety systems work. 
 
Again, the EPA RMP guidance for WWTP=s was used to estimate a 
potential plume length of  0.2 miles for this scenario.  The 
alternate scenarios for the papermaking process and the WWTP are 
identical.  Because of the length of the chlorine plume this 
scenario has the potential for an off-site impact. 
 
The more-likely scenario assumes: 
<    Failure of a one-inch steel braided transfer hose, resulting 
    in the immediate release of 137 pounds of chlorine gas; 
<    Automatic safety valve closes, preventing fu 
rther discharge; 
    and 
<    Release takes place during a 6.7 mph wind speed and stable 
    atmospheric conditions (770F and 50% relative humidity). 
 
The chlorine rail cars on the Haz-Mat track are not in use, 
therefore the potential for a release is very low.  After a 
thorough review, a realistic alternate scenario for the Haz-Mat 
track that exceeded the effects of the previous scenario could 
not be developed.
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