Westvaco Corp. Bleached Board Division - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

Westvaco is a world-class producer of a wide range of innovative products and services.  A forest products company with offices and operations around the world, Westvaco's distinctive products manufactured for customers around the globe include paper, packaging, envelopes and specialty chemicals. 
Westvaco's presence in Virginia began in 1899 when the company launched operation of its papermaking facility in Alleghany County.  Since then, Westvaco has invested extensively in its Alleghany Highlands operations.  Today, nearly 2,000 men and women work at Westvaco's Alleghany Highlands manufacturing and research operations. 
A commitment to excellence in all aspects of its operations defines Westvaco.  The company's Bleached Board Division paper mill is recognized worldwide for its technological sophistication and production of premium coated bleached paperboard.  Paperboard from the Covington mill is used for a variety of consumer packaging and printing applications in 
cluding packaging cartons, aseptic and other liquid packaging, books and greeting cards. 
Westvaco also sets the highest standards for workplace safety.  The company and its employees have worked consistently to build a strong and solid system of work practices and procedures to prevent accidents from happening.  Westvaco remains committed to maintaining the integrity of a workplace safety program that is among the industry's best.   
Westvaco's Bleached Board Division in Covington, VA has two substances that fall under the EPA's Accidental Release Prevention and Risk Management Plan (RMP).  The regulated substances handled at the source in excess of their applicable threshold qualities are chlorine dioxide (CAS No. 10049-04-4) and chlorine (CAS No. 7782-50-5).  There are six covered processes using chlorine and one 
covered process using chlorine dioxide. 
In each process, an accidental release of a potentially hazardous chemical should be prevented through detailed programs that include: 
    Written safe operating procedures, including emergency guidelines, that are reviewed annually; 
    Regular preventive maintenance of critical equipment to prevent mechanical breakdowns; 
    A tank integrity program that ensures safe storage of materials; 
    Processes that are manned and monitored 24 hours a day; 
    Safety systems that include emergency relief systems, remotely-activated isolation valves, and interlocking systems to shut down a process; 
    Scheduled safety audits; 
    Regular process hazard analysis to identify and correct potential safety concerns; 
    Detailed safety reviews completed prior to startup following any changes made to our equipment or processes; and 
    Thorough and regular safety and operational training for employees who work with processes that involve potentially hazardous materials. 

n addition to the above, the chlorine dioxide process has these safety systems in place: 
    All operators undergo extensive operator training and qualification programs; 
    Storage tanks are diked; 
    Chlorine dioxide is manufactured on-site and not transported from off-site; 
    Continuous monitoring systems are in place for the production, storage and distribution of chlorine dioxide within the mill, including extensive leak detection monitors; and 
    Vented gas is captured in a collection system. 
The chlorine process has these additional safety systems in place: 
    All operators undergo extensive operator training and qualification program; 
    Chlorine residuals are checked regularly; 
    If water flow is lost to the system, gas flow is stopped; and 
    Area atmosphere is continuously monitored and alarms will sound if chlorine is detected. 
The worst case release scenario for the site consists of the catastrophic failure of Tank I with the release of 140,000 gallons of chlorine dioxide (ClO 
2) solution (6,359 kilograms of ClO2) into a  diked area.  This worst case release scenario results in ClO2 concentrations that equal or exceed the U. S. EPA designated endpoint concentration out to a distance of 4.1 miles(6.6 kilometers) from Tank I.  The estimated population within this distance from the Covington Mill Tank I is approximately 2,900.  The one environmental receptor within this distance is a state forest.  The public receptors within this distance are public recreation areas, residences, schools, commercial and industrial facilities, office buildings and churches.   
The alternative release scenario for chlorine dioxide consists of the release of 100 gallons of  ClO2 solution (4.5 kilograms of ClO2) as a result of a failed gasket in the valve of a pipeline containing this solution at the Bleached Pulp Mill.  This alternative release scenario results in ClO2 concentrations that equal or exceed the U.S. EPA designated endpoint concentration to distances of 554 feet (169  
meters) from the release point.  This area is entirely within the mill property.  Thus, there is no estimated population to be affected within this distance from the Bleached Pulp Mill.  Likewise, there are no environmental or public receptors within this distance from the release point. 
The alternative release scenario for chlorine consists of the release of 0.4 kilograms of Cl2 from failure of the lead gasket at the Cl2 cylinder valve of one of the Cl2 cylinders at Paper Machine No. 2.  This alternative release scenario results in Cl2 concentrations that equal or exceed the U.S. EPA designated endpoint concentration to a distance of 108 feet (33 meters) from the release point.  This distance extends to Westvaco's boundary at Dunlap Creek; there is no estimated affected population within this distance from Paper Machine No. 2.  Likewise there are no environmental or public receptors within this distance.   
In regard to the five-year accident history, there have been no incidents at  
the Covington Mill over the past five years that resulted in injuries, death, or significant property damage on-site; nor have there been known off-site deaths, injuries, evacuations, shelterings in place, property damage or environmental damage associated with any of the regulated processes. 
The site is also subject to OSHA's Process Safety Management (PSM) regulation 29 CFR 1910.119.  The purpose of this regulation and Westvaco's PSM program is to prevent accidental releases and to minimize the consequence if one should occur.  The location also has an Emergency Response Program in place that includes: 
    Procedures for informing the public and local emergency response agencies about accidental releases; 
    Documentation of proper first-aid and emergency medical treatment to treat accidental human exposure; 
    Procedures for emergency response after an accidental release of a regulated substance; 
    Procedures for the use of emergency response equipment and for its inspection, testing a 
nd maintenance; 
    Training of all employees in relevant procedures, and; 
    Procedures to review and update the emergency action plan as appropriate. 
Ensuring safe operations will continue to be a foremost priority for Westvaco.  In that regard and as part of Process Safety Management, Process Hazard Analyses are completed for each covered process.  The most recent Process Hazard Analysis for chlorine has been completed with all action items completed.  A second Process Hazard Analysis was just recently completed for chlorine dioxide which identified action items to help strengthen and improve the system all of which will be completed by the end of 1999.  Westvaco's safety programs are audited internally on a periodic basis and modified or upgraded as needed to help ensure positive risk elimination and prevention.
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