Wausau-Mosinee Paper Corporation (Brokaw, WI) - Executive Summary |
EXECUTIVE SUMMARY Wausau Papers is committed to operating in a manner that is safe for Wausau Paper workers, the public, and the environment. As part of this commitment, Wausau Papers 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 Wausau Papers 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 Wausau Papers. This document is intended to satisfy the RMPlan requirements of the RMP rule. 1. Accidental Release Prevention and Emergency Response Policies Wausau Papers is committed to the safety of Wausau Papers workers and the public, and to the preservation of t he environment, through the prevention of accidental releases of hazardous substances. Wausau Papers implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of a significant accidental release, Wausau Papers evacuates workers and contacts the local fire department to control and contain the release and to prevent and/or reduce the consequences of the release. The emergency plan has been coordinated with both the fire dept and the Marathon County Local Emergency Planning Committee. 2. Facility Description and the Regulated Substance Wausau Papers is a sulfite mill involved in the manufacture of printing and writing grades of paper. Chlorine is used in two processes: bleaching of the pulp and treatment of wastewater. The maximum quantity of chlorine is approximately 720,000 pounds in the pulp bleaching system and approximately 24,000 pounds in the wastewater treatment system. 3. The worst-case release scenario and the alternative rele ase 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 period. The worst case release scenario for this chlorine process is failure of a 90-ton chlorine rail car 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 14.0 miles. There are public receptors (schools, residences, recreational areas and commercial areas) and 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 an uncoupled chlorine transer line. No administrative controls or passive mitigation were considered for this release scenario. The distance to the toxic endpoint for chlorine is 0.30 miles. There are public receptors (residences 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. Both chlorine systems have been designed and installed according to guidelines provided by The Chlorine Institute. The chlorine systems are operated and maintained by trained and experienced operators. 5. The Five-Year Accident History Wausau Papers has not experienced an RMP reportable release or accident involving chlorine in the last five years. 6. The Emergency Response Program Wausau Papers has established a written Integrated Contingency Plan that complies with the RMP rule and with other federal contingency plan requirements. This program has been discus sed with the local fire department and has been coordinated with the Marathon County Local Emergency Planning Committee (LEPC). The LEPC has prepared a site specific plan for Wausau Papers. 7. Planned Changes to Improve Safety Wausau Papers constantly strives to improve the safety of Wausau Papers processes through both the incident investigation program and a program soliciting safety suggestions from employees. In addition, Wausau Papers 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. Wausau Papers is planning to eliminate chlorine from the pulp bleaching process and this change is scheduled to be implemented by April 15, 2001. This change will result in the removal of the 90-ton chlorine railcars from the Wausau Papers site. |