Interstate Paper, LLC - Executive Summary |
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Executive Summary This risk management plan (RMP) has been prepared for the Interstate Paper LLC (Interstate Paper) facility located in Riceboro, Georgia to fulfill the requirements of Section 112(r)(7) of the Clean Air Act Amendments (CAAA) of 1990 and pursuant to 40 CFR Part 68 (Risk Management Programs for Chemical Accidental Release Prevention). These regulations require stationary sources with listed substances present in a process in quantities greater than the threshold quantity to develop and implement a risk management program that includes a hazard assessment, a prevention program, and an emergency response program. The risk management program must be described in an RMP that is required to be: registered with the US Environmental Protection Agency (EPA); submitted to appropriate local emergency planning agencies; and available to the public. For the Interstate Paper facility in Riceboro, Georgia, chlorine (which is a listed toxic substance) is stored in amounts that ex ceed the threshold quantity of 2500 lb. Based on a review of the RMP regulations and the potential off-site impacts from this chlorine system, Prevention Program 3 requirements were identified to apply to this facility (due to the system's applicability to the OSHA process safety management program requirements). To meet the Prevention Program 3 requirements, this RMP has been prepared in accordance with 40 CFR Subpart G, Parts 68.150 through 68.190, which describe the format to be followed in completing an RMP document. 1.1. Accidental release prevention and emergency response policies The Interstate Paper facility in Riceboro, Georgia is committed to providing a strong health and safety program for its on-site employees as well as a safe environment for the surrounding community. In this regard, the Interstate Paper facility is committed to: Appropriately managing the types and quantities of chemicals stored and handled on-site. As indicated within S ection 1.2, only one chemical (chlorine) is currently stored and handled in a quantity that exceeds the RMP threshold limits. In addition, as noted below in Section 1.2, the storage and handling of this material has been located in the central portion of the facility to limit the off-site impacts due to potential accidental releases. Developing and implementing the programs necessary to store and handle chemicals on-site during typical and/or emergency situations. Examples of the types of supporting chemical handling programs currently in-place at the facility include: an Emergency Response Plan, which includes a complete evacuation of the facility and coordination with off-site emergency services; a Process Safety Management Plan, which provides for typical operating procedures, emergency procedures, routine maintenance, inspections, training, and the like; and a Hazard Communication Program and associated training such that on-site personnel understand t he hazards associated with the chemicals and processes located on-site. In short, the Interstate Paper facility's accidental release prevention and emergency response procedures are based on the goal of storing and handling chemicals (including chlorine) to prevent exposure to employees and the surrounding community. In pursuit of this goal, it is the Interstate Paper facility's policy to adhere to applicable State and Federal regulations. As such, the chlorine system is designed in accordance with applicable regulations and design standards (such as those provided in the ASTM and ANSI Standards). In addition, the day-to-day use of chlorine is based on safe handling procedures and proper training of personnel and the emergency handling of an accidental release of chlorine is covered within the facility's Emergency Response Plan (which includes procedures for notification to the local fire department and the local emergency planning committee [LEPC] in the event of a release to the environment). 1.2. The stationary source and regulated substances handled The Interstate Paper facility located in Riceboro, Georgia is engaged in the production of kraft liner paperboard. Of the chemicals handled on-site in support of these manufacturing operations, only one (chlorine) was identified to be stored and handled on-site in quantities which exceed the thresholds established in 40 CFR Part 68. Chlorine is needed at the Interstate Paper facility for disinfection of the drinking water and process water supplies in accordance with the facility's Safe Drinking Water Permit. This chlorine disinfection is required for: the prevention of diseases and public health concerns which may otherwise be associated with the facility's drinking water supply; and the treatment of the facility's process water supply prior to its introduction into the process equipment. The Safe Drinking Water Permit requires the Interstate Paper facility to chlorinate its water supply on a continual basis year-round. To guarantee that sufficient chlorine is available on-site to provide the required levels of chlorination, the Interstate Paper facility typically stores between five and seven 1-ton cylinders of chlorine on-site at a time. These cylinders are unloaded and stored in the central portion of the facility (away from the property lines). 1.3. The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distances for each scenario Worst-case scenario - The worst-case release scenario is a highly unlikely event, whose parameters are defined by the USEPA. The worst-case scenario is defined by the USEPA to be the result of a failure of the largest single vessel, which would result in the release of the greatest amount chlorine that could be held in a single storage tank (which is equal to 2000 lb based on the facility's administrative controls). For this scenario, it is assumed that the entire contents of the storage tank are released as a vapor and that the endpoint of concern occurs at a concentration of 0.0087 mg/L. The distance to the 0.0087 mg/L toxic endpoint for the worst-case scenario is calculated to result in a radius of impact of 2.14 mi. A portion of this impact (a calculated 11.79 mi2 area of the total 14.39 mi2 area) is identified to extend beyond the Interstate Paper property. This 11.79 mi2 of impact is identified to potentially affect one industrial facility, several residential properties, and several recreation areas located around the Interstate Paper property. No hospitals, schools, prison/ correction facilities, parks, or public arenas were identified to be located within the zone of impact. Alternative scenario -Any accidental release with an off-site consequence is also a highly unlikely event. In fact, this facility has been in operation for approximately thirty years without such a release. With that said, alternative release scenarios should represent an event that is much more likely to occur than a worst-case release scenario. However, it should also be noted that USEPA reporting elements require that an off-site impact be identified (if available) for the alternative release scenario. In order to obtain off-site impacts from large facilities (such as the 1663-acre property owned by Interstate Paper), unlikely alternative release scenarios need to be evaluated. The following alternative release scenarios were evaluated for the Interstate Paper facility: transfer hose releases due to splits or sudden hose uncouplings; process piping releases from failures at flanges, joints, welds, or valves; and process vessel releases due to cracks, seal failure, or drain. Of the above-referenced alternative scenarios, it was identified that neither the transfer hose releases or the process piping releases would produce an off-site impact. The only off-site impact was obtained by assuming the failure of a fusible plug (a 0.75-inch hole) on a one-ton cylinder and a choke (sonic) flow condition. Although this situation is not considered very likely to occur, it would create an alternative release scenario with an off-site impact (with a radius of impact of 1.53 mi). A portion of this impact (a calculated 4.75 mi2 area of the total 7.35 mi2 area) is identified to extend beyond the Interstate Paper property. This 4.75 mi2 of impact is identified to potentially affect several residential properties and recreational areas located around the Interstate Paper property. No hospitals, schools, prison/correction facilities, commercial or industrial properties, parks, or public arenas were identified to be located within the zone of impact. 1.4. The general accidental release prevention program and the specific prevention steps In keeping with the Interstate Paper facility's commitment to health and safety, the chlorine system complies with USEPA's RMP regulations and othe r applicable regulations. The system was designed and constructed in accordance with applicable ASTM and ANSI Standards. Safety information, including a Material Safety Data Sheet (MSDS) for chlorine, maximum inventory, and equipment specifications and codes are maintained. Personnel responsible for operating and maintaining the chlorine system have been thoroughly trained and tested competent in the hazards of the system, how to avoid or correct unsafe conditions, and in the written operating, inspection, and maintenance procedures. The procedures were developed in accordance with chlorine industry standards and 40 CFR 68. Refresher training, including hands-on demonstration training and classroom computer-based training, is provided at least every three years. Administrative controls are in-place to limit the capacity of each of the chlorine cylinders to 2000 lb. As an additional administrative control, the chlorine residual levels in the treated water are required to be reco rded every 2 hr for reporting to the Georgia Department of Natural Resources - Environmental Protection Division (GDNR-EPD) in compliance with the facility's Safe Drinking Water Permit. As such, the chlorine system is checked regularly throughout the operating day. In addition, written maintenance procedures have been developed for chlorine storage and use. Maintenance checks occur daily or monthly, as required. 1.5. Five-year accident history The chlorine system at the Interstate Paper facility has been in operation since the late-1960s/early-1970s, with several upgrades performed on the system during that time period. No accidental releases are known to have been associated with the operation of this chlorine system during its years of its operation. As such, there are no records indicating any on-site or off-site deaths, injuries, evacuations, sheltering in-place, property damage, or environmental damage during the past five years of the chlorine system's operation. 1.6. The emergency response program The facility has developed and implemented a written Emergency Response Plan, which requires an evacuation of the facility and coordination with the local fire department and LEPC in the unlikely event of a release of chlorine. The Interstate Paper facility has coordinated with several of the local fire departments (including the Hinesville Fire Department, the Riceboro Fire Department, and the Midway Fire Department) as well as the Liberty Hinesville Emergency Management Agency with respect to emergency chlorine situations. Based on information obtained from the Hinesville Fire Department, the responders and firemen in their department have completed the required HAZMAT training courses offered by the State of Georgia with respect to potential chlorine releases. 1.7. Planned changes to improve safety The chlorine system was constructed and is operated in accordance with the ASTM Standards, ANSI Standards, and other applicable chlorine industry st andards. The chlorine system was last modified and upgraded to these standards in the early-1990s. No additional construction or modification to the chlorine system is planned at this time. Risk Management Plan Certification The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate, and complete. Eugene C. Millard, Vice President and General Manager Signature: Date: |