International Paper-Franklin, Virginia - Executive Summary |
|
EXECUTIVE SUMMARY The International Paper Mill at Franklin, Virginia 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. The mill implements controls to prevent accidents or releases of hazardous substances. In the event of an accidental release, mitigation steps are taken to contain, control, and stop the release. The mill is an integrated pulp and paper manufacturing facility located on 1,371 acres of property in the southwestern corner of Isle of Wight County, Virginia. Two substances, chlorine and chlorine dioxide, are utilized at the site to bleach pulp. These substances are regulated under 40CFR Part 68, Chemical Accident Prevention Provisions. International Paper is committed to continuously improve the safety of its processes. One example of this commitment is the elimination of the use of elemental chl orine for bleaching, and plans are being implemented to achieve this goal by April 2001. Additionally, ongoing activities, including training, process hazard analysis, and auditing, are used to identify ways to continually improve the operation of these processes. As required by the Risk Management Planning rule, worst case and alternative release scenarios were analyzed. The worst case release scenario is prescribed by the rule. For this site, it is a ten minute release of ninety tons of chlorine from a railcar. Alternative releases must be reviewed for both chlorine and chlorine dioxide. For chlorine, the alternative release scenario (much more realistic than the worst case scenario) is a transfer hose rupture, which would result in the release of 1,250 pounds of chlorine in 5 minutes. Mitigation measures considered in this scenario were the Chlorine Unloading Building, the 200 foot stack through which chlorine releases in this building vent, chlorine sensors, and emergency sh utdown systems. The Chlorine Unloading Building was built in 1988 for the specific purpose of minimizing risk to the community and employees. It is a totally enclosed building with state-of-the-art sensors and alarms to monitor for and protect against any chlorine release. The alternative release scenario for chlorine dioxide is a gasket leak at a pump discharge. This would result in a release of 220 pounds of chlorine dioxide in 20 minutes. Mitigation measures considered in this scenario were emergency shutdown systems. Each of these release scenarios has potential off-site consequences. For the alternative release scenarios, off-site receptors include residences, churches, commercial areas, and a recreation area. For the much less realistic worst-case scenario, off-site receptors also include schools, commercial areas, a hospital, and an airport. The following prevention elements for the chlorine and chlorine dioxide systems are employed at the mill: 1. Design standards. Design standards are utilized to insure that process safety information is incorporated into the construction and maintenance of these systems. 2. Operating procedures. Written operating procedures have been developed and are maintained. These procedures define how tasks related to the process operation should be performed. They are used to train operators and serve as guides for appropriate steps to be taken both during normal operations and process upsets. 3. Maintenance. The chlorine and chlorine dioxide systems are properly maintained. Preventive maintenence is routinely performed on these systems. Maintenance on these systems is limited to employees and contract personnel who have received specific training on the maintenance of the systems. 4. Training. Personnel are trained in the operating procedures to help insure safe and effective performance of our assigned tasks. 5. Process Hazard Analyses (PHA's). PHA's were conducted on both the chlorine and chlorine dioxide systems. PHA's are structured ways to identify and reduce the hazards of a system. Routine review of these PHA's is performed as well. 6. Contractor management. The mill has a program which establishes criteria for contractors in order to work at the site. 7. Compliance audits. Compliance audits are conducted to insure compliance with requirements of the regulation. 8. Prestart-up review. Prior to modification of affected systems a pre-start-up safety review is conducted to insure the integrity of the system is maintained. 9. Hot work permit. For work outside of designated safe areas, a permit system has been implemented to insure that proper safeguards are taken to minimize the risk of a fire. 10. Management of Change. A Management of Change procedure is in place to insure that operating, maintenance, and safety information is kept up to date. 11. Process safety information. The mill maintains a variety of technical documents that are used to help insu re the safe operation of these systems. 12. Material Safety Data Sheets (MSDS). MSDS's document the physical properties of these chemicals. 13. 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 facility has a written emergency response plan to mitigate and minimize the effects 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, 5 accidental releases have occurred in the past five years. There have been no releases as defined by the rule in the past two and a half years. During the five year accident history there have been no off-site health or environ mental damage reports. |