International Paper - Mobile Mill - Executive Summary

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International Paper's Mobile Mill is committed to operating in a manner that is safe for Mobile mill employees, the public, and the environment.  As part of this commitment, the Mobile mill 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) that helps manage the risks at the Mobile mill 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). 
The risk management program at the Mobile mill consists of three elements: 
A hazard assessment to help understand the potential off-site consequences of hypothetical accidental releases, and any incidents that have occurred during the last five years associated with the use of substances regulated by the RMP rule. 
A prevention program to help maintain and safely operate the processes containing 
a r 
egulated substance (covered processes). 
An emergency response program to help respond to accidental releases of regulated substances from covered processes. 
Although the risk management program at the Mobile mill helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety program at the Mobile mill.  In fact, Mobile mill has a comprehensive safety program in place establishing many levels of safeguards against release of a hazardous substance that could result in property damage. 
Accidental Release Prevention and Emergency Response Policies 
International Paper is committed to the safety of employees and the public, and the preservation of the environment, through the prevention of accidental releases of hazardous substances.  The Mobile mill implements reasonable controls to prevent foreseeable releases of hazardous substances.  These controls include training programs for personnel; programs to help ensure safety in 
the design, installation, operation, and maintenance of processes at the Mobile mill, and programs to evaluate the hazards at the Mobile mill. 
International Paper limits the use of hazardous substances.  Before using a hazardous substance at the Mobile mill, less hazardous alternatives are considered.  When a hazardous substance is used, the Mobile mill considers the potential for this substance to adversely affect  workers, the public, and the environment and takes steps to prevent any such effects. 
International Paper prevents releases of the hazardous substances used at the facility.  When a hazardous substance is used at the Mobile mill, the equipment is carefully designed, built, and operated to reduce the likelihood of an accidental release.  Industry and government standards are closely adhered to in the design, construction, and operation of the equipment. 
International Paper limits damage from a release, if such a release occurs.   
In the event of an accidental release, t 
he Mobile mill controls and contains the release in a manner that will be safe for workers and will help prevent injury to the public or the environment.  The Mobile mill provides response training to the Mobile mill personnel, designates an emergency response coordinator to oversee response activities, and coordinates response efforts with the local fire department and Emergency Management Agency. In addition, the Mobile mill works with the local fire department and with the local Emergency Management Agency (EMA) in the process of pre-emergency planning in the event that a release were to occur. 
In order to effectively implement these policies, the Mobile mill established a management system headed by the Environmental Health & Safety Manager to oversee safety-related activities. 
International Paper's Mobile Mill and the  Risk Management Program Regulated Substance 
International Paper's- Mobile Mill is an integrated pulp and paper mill primarily involved in the manufacture of blea 
ched pulp and related finished paper products. As part of this manufacturing process, the Mobile Mill handles one regulated toxic substance, chlorine dioxide, in sufficient quantity to be covered by the RMP rule. The Mobile Mill generates and stores up to 30,000 pounds of chlorine dioxide in a  12 gram/liter (1.2 % by weight) aqueous solution. The use of chlorine dioxide at the Mobile Mill constitutes a Program 3 process under EPA RMP.  
Off-site Consequence Analysis 
International Paper's - Mobile Mill performed an offsite consequence analysis to estimate the potential release of chlorine dioxide and its potential to affect the public or the environment. For an RMP  Program 3 process, the offsite consequence analysis consists of evaluating both a worst-case release scenario and an alternative release scenario.  
The release scenarios were selected to help the Mobile County Emergency Planning Committee (MCEPC), Emergency Management Agency (EMA), and the International Paper - Mobile Mil 
l better prepare for community emergency response should the unforseen situation arise.  
The following information summarizes the offsite consequence analysis performed by the Mobile Mill: 
The worst-case release scenario for chlorine dioxide is a rupture of the 225,000 gallon chlorine dioxide solution (1.2 wt%) storage tank. The release is assumed to occur within 10-minutes. The tank contents would initially be contained in a confined area of dikes, curbs, sewers or sumps. This passive containment would contain approximately 36% of the spill. The remainder of the spill would overflow these areas and form a pool in an area around the tank. Chlorine dioxide evaporates from the aqueous solution and forms a vapor cloud. The potential dispersion of the vapor cloud has been evaluated with an atmospheric dispersion model. Such a scenario could potentially impact various public receptors.  
The alternative release scenario for chlorine dioxide is a flange leak in a process line that carries  
aqueous chlorine dioxide from the storage tanks to the bleach plant. The release is assumed to occur near the bleach plant towers at a rate of 50 gallons per minute (gpm) for a period of 10-minutes. The spill would form a pool of chlorine dioxide solution that would evaporate. 
The impact of the vapor cloud from the release does not affect residential population outside of the mill property boundaries. The vapor cloud potentially affects an adjacent industrial public receptor. 
RMP 3 Accidental Release Program Prevention Program 
In addition to Mobile mill's programs for accidental release prevention and emergency response, the regulated process is covered by an additional twelve elements from the facility's OSHA process safety management (PSM) program. The Mobile mill's PSM program addresses the following 12 elements: 
1. Process Safety Information 
2. Process Hazard Analysis 
3. Operating Procedures 
4. Employee Training 
5. Mechanical Integrity (equipment maintenance) 
6. Management of P 
rocess Changes 
7. Process Pre-startup Review 
8. Program Compliance Auditing 
9. Incident Investigation 
10. Employee Participation 
11. Hot Work Permits (welding and burning permits) 
12. Contractor Management 
Five Year Accident History 
There have been no incidents at the Mobile mill that meet the criteria of an accident under RMP within the previous five years. 
Planned Changes to Improve Safety 
The use of chlorine was eliminated in 1996 ahead of the requirement of submitting an RMPlan resulting in reduced risk from handling chlorine at the Mobile mill.
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