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  
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 
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 
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 
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 
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 
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 
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