Wausau-Mosinee Paper Corporation (Mosinee, WI) - Executive Summary |
|
EXECUTIVE SUMMARY Wausau Mosinee Paper Corporation (WMPC) is committed to operating in a manner that is safe for WMPC workers, the public, and the environment. As part of this commitment, WMPC has established a system to help ensure safe operation of the processes at this facility. One component of this system is a risk management program (RMP) for chlorine that helps manage the risks at WMPC and 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). One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at the WMPC. This document is intended to satisfy the RMPlan requirements of the RMP rule. 1. Accidental Release Prevention and Emergency Response Policies WMPC is committed to the safety of WMPC workers and the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. WMPC implements reasonable controls to prevent foreseeable releases of hazardous substances. WMPC has a dedicated emergency response team to handle emergencies involving chlorine. The team is specially equipped and trained to detect, isolate, and mitigate potential releases. The emergency plan has been coordinated with both the fire dept and the Wausau Emergency Response Team. 2. Facility Description and the Regulated Substance WMPC is an unbleached kraft mill involved in the manufacture of specialty grades of paper. Chlorine is used to treat incoming water prior to being used in the pulp and papermaking process. The maximum quantity of chlorine is this treatment system is approximately 12,000 pounds. 3. The worst-case release scenario and the alternative release scenario The worst-case release scenario is mandated by EPA to be the amount of chlorine in the largest storage vessel, released over a 10-minute time p eriod. The worst case release scenario for this chlorine process is failure of a one ton chlorine container, resulting in a toxic release. No administrative controls or passive mitigation were considered for this release scenario. The distance to the toxic endpoint for chlorine is 2.63 miles. There are public receptors (schools, residences, recreational areas and commercial areas) within this area. There are no environmental receptors within this area. The alternate release scenario (ARS) is defined as a scenario that is more likely to occur than the worst-case release scenario. Several ARS's were considered, based on the Process Hazard Analysis, past incidents in similar installations, and operator experience. The scenario chosen is a leak from valve attached to the one-ton chlorine container. No administrative controls or passive mitigation were considered for this release scenario. The distance to the toxic endpoint for chlorine is 0.50 miles. There are public receptors (r esidences and commercial areas) within this area. There are no environmental receptors within this area. 4. The General Accidental Release Program and Chemical Specific Prevention Steps This facility complies with OSHA's Process Safety Management (PSM) rule and the USEPA's Accidental Release Prevention Rule. The entire chlorine system has been designed and installed according to guidelines provided by The Chlorine Institute. The chlorine system is operated and maintained by trained and experienced operators. 5. The Five-Year Accident History WMPC has not experienced an RMP reportable release or accident involving chlorine in the last five years. 6. The Emergency Response Program The WMPC emergency reponse program is based on and is in compliance with OSHA's HAZWOPER regulation. This program has been discussed with the local fire department and has been coordinated with the Local Emergency Planning Committee (LEPC). The LEPC has prepared a site specific plan for WMPC. 7. Pla nned Changes to Improve Safety WMPC constantly strives to improve the safety of WMPC processes through both the incident investigation program and a program soliciting safety suggestions from employees. In addition, WMPC personnel periodically review the chlorine system, as required by the PSM Rules. The most recent review and other methods for soliciting safety suggestions did not identify the need for any changes to the chlorine system. |