International Paper - Eastover Mill - Executive Summary |
|
The International Paper - Eastover Mill is committed to operating in a manner that provides for the safety of its employees and neighbors and for the protection of the environment. A key element of this commitment is the safe and proper handling of chemicals. Controls have been implemented to prevent accidental releases of hazardous substances. In the event of an accidental release, mitigation steps are taken to stop, control, contain and clean up the release. The International Paper - Eastover Mill is an integrated pulp and paper manufacturing facility on a 4400-acre site in the southeastern portion of Richland County, South Carolina. Two substances, chlorine and chlorine dioxide, are utilized at the site to bleach pulp. These substances are regulated under 40 CFR Part 68, Chemical Accident Prevention Provisions. The Eastover Mill is committed to continuously improving the safety of its processes. One example of this commitment is the elimination of the use of chlorine for bleachin g. Plans are being executed to eliminate chlorine for this use by April of 2001. Additionally, ongoing activities including training, process hazard analysis and auditing are utilized to identify ways to continuously improve the operation of these processes. As required by the rule, worst case and alternative release scenarios were analyzed. The worst case release scenario is prescribed by the rule. For this site, it would be a 10-minute release of 90 tons of chlorine from a rail car. Alternative releases must be reviewed for both chemicals. For chlorine, the alternative release scenario considered was a transfer hose rupture. This would result in a release of 625 pounds of chlorine in five minutes. Mitigation measures considered in this scenario were excess flow valve, emergency shutdown system and chlorine sensors. Potential off-site receptors for this release scenario are residences. For chlorine dioxide, the alternative release scenario considered was a pipe leak. This would resul t in a release of 220 pounds in twenty minutes. Mitigation measures considered in this scenario were emergency shutdown system and chlorine dioxide sensors. No potential off-site receptors exist for this scenario. The following prevention elements for the chlorine and chlorine dioxide systems are employed at the mill. Process Safety Information: A variety of technical documents that are used to help ensure the safe operation of these systems are maintained. Material Safety Data Sheets document the physical properties of these chemicals. Design standards are utilized to ensure that process safety information is incorporated into the construction and maintenance of these systems. Process Hazard Analysis: Process hazard analysis (PHAs) were conducted on both the chlorine and chlorine dioxide systems. PHAs are structured ways to identify and reduce the hazards of a system. Routine review of these PHAs is performed as well. Operating Procedures: Written operating procedures have been developed and are maintained. These procedures define how tasks related to the process operations should be performed. They are used to train operators and serve as guides for appropriate steps to be taken during both normal operations and process upsets. Maintenance: The chlorine and chlorine dioxide systems are properly maintained. Preventative maintenance is routinely performed on these systems. Work on these systems is limited to employees and contract personnel who have received specific training on the maintenance and hazards of these systems. Compliance Audits: Compliance audits are conducted to ensure compliance with the requirements of the regulations. Incident Investigation: All incidents that could reasonably result in a serious injury to employees, the public or the environment are investigated. All employees are encouraged to report any such incident. The results of the investigations are documented and appropriate actions are implemented. Training: Personnel are trained in the operating procedures to help ensure safe and effective performance of their assigned tasks. The facility has a written emergency response plan to mitigate and minimize the affects of any accidental release. Trained response personnel and equipment are on site 24 hours a day. Training on and drills of the response plan are routinely conducted. The response plan has been communicated to local emergency response officials, who have participated in drills at the facility. As defined by the rule, three accidental releases have occurred in the past five years. No permanent injury resulted from these accidents and information learned as a result of them was used to improve our prevention programs. |