Plainwell Tissue - Executive Summary
Risk Management Plan |
Plainwell Tissue Mill - Eau Claire, WI
Ms. Kathy Gillespie
1200 Forest Street
Eau Claire, WI 54703
Liesch Environmental Services, Inc.
6000 Gisholt Drive, Suite 203
Madison, WI 53713
July 12, 1999
James J. Fleischmann David Macdonald
Project Manager/Air Services Principal
To the best of the undersigned's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate and complete.
In addition, the undersigned certifies that for the purposes of this initial Risk Management Plan submittal the individuals responsible for operating and maintaining the ammonia storage vessel have the knowledge, skills and abilities to safely carry out their duties and responsibilities. This certification is provided in lieu of specific training and competency testing provisions set for
th in the data elements, as provided in 40 CFR S. 68.54.
Signature Print Name
Accidental Release Prevention Policies
Plainwell Tissue will work to prevent accidental releases of toxic or flammable substances that could result in a safety hazard to the public or to the workers at the mill. Plainwell will work with OSHA, U.S. EPA, and the Local Emergency Planning Committee (LEPC) contacts, including both fire department HAZMAT and the Eau Claire Emergency Government office, to minimize the potential for any accidental release and to help assure that the mill is prepared to respond in the event of an accidental release. The emphasis of this Risk Management Plan is on the regulated substances identified within the federal regulations. However, Plainwell Tissue has procedures in place to help minimize the chance of accidents related to other potentially hazardous substances stored or handled on site.
n accidental release were to occur, it is the policy of Plainwell Tissue to notify the appropriate emergency contacts. The City of Eau Claire has a private company that has a HAZMAT response unit that acts as a primary responder in the event of a release of ammonia. Plainwell Tissue would use their emergency response plan as a guide to direct the company's response. The facility maintains a response plan to cover potential releases of ammonia as required by the RMP rules.
Description of Facility and Regulated Substance(s)
Plainwell Tissue operates a pulp and paper mill on-site producing paper from recycled paper of various types.
Aqueous ammonia is stored on-site in excess of the threshold value of 10,000 lbs., originally included under the Risk Management Plan (RMP) listing rule. Ammonia is used as a nitrogen source for the wastewater treatment plant. The Court of Appeals for the District of Columbia has acted with a "stay of action" regarding propane storage RMP filings, thus
the RMP at this time addresses only the ammonia storage. Plainwell stores a maximum of 18,500 pounds of ammonia.
Plainwell Tissue completed an evaluation and approved the installation of equipment needed to convert from the use of anhydrous ammonia to the use of aqueous ammonia, with installation of equipment needed for the change anticipated by early summer of 1999. This RMP reflects the use of aqueous ammonia. The efforts by Plainwell tissue to make this conversion have resulted in substantial reductions in the number of residents potentially affected by an accidental release of ammonia, and the distance to a toxic endpoint. The modeled distance to the listed 0.14 mg/l endpoint of concern for ammonia now extends to the near proximity of the mill.
Several other substances were reviewed within the Offsite Consequence Analysis report as being exempt from listing within the RMP, either because stored quantities are too small to be included or because the substance stored is not a
highly toxic or flammable substance listed in the RMP rules. The mill maintains appropriate records of these other chemicals to demonstrate the exempt status and to assure that general response actions can be implemented for all chemicals of concern in the event of an accidental release.
Worst-Case Release Scenario Description
The worst-case release scenario modeling included the following:
Substance Scenario Treatment
Ammonia Release to concrete berm Winds at 1.5 m/s, nighttime F stability class
The worst-case scenarios modeled meet the specifications described in the October 1996 Off-site Consequence Analysis Guidance and 40 CFR Part 68 (the RMP rules). Worst-case scenario modeling uses highest air temperatures and associated stored ammonia temperature.
Alternative Release Scenario Description
The Alternative release scenario was selected by evaluating several more typical events and considering the resulting impact with more typical release rates and atmospheric condition
s. The Alternative release scenario was identified using the more conservative of the evaluated scenarios. The Alternative scenarios included the following:
Substance Scenario Treatment
Ammonia Release to concrete berm Winds at 4.56 m/s, daytime D stability class
The alternative case uses typical circumstances using 30-year average conditions for July (the warmest month) from the Eau Claire National Weather Service reporting station.
Results of Off-site Consequence Analysis
The Off-site Consequence Analysis resulted in the following predicted distances to the endpoints and population potentially affected:
Distance to Endpoint (mi.) Residential Population
Ammonia 0.10 813
Ammonia 0.03 29
The estimated residential population potentially affected is derived using procedures described in EPA's Off-site Consequence Analysis Guidance. These procedures conservatively include the entire area in
side of a circle described using the storage vessel at the center and the distance to the endpoint as the radius. Since typical events affect only a relatively narrow sector of this circle, and only a portion of the population would be present at the time, this estimate clearly represents an upper bound for the potentially impacted residential population.
General Accidental Release Program and Prevention Steps
Plainwell Tissue complies with EPA's Accident Prevention Provisions set forth in 40 CFR Part 68 and applicable state and local codes and regulations.
The mill also meets the EPCRA planning requirements for ammonia storage. Related discussion on the prevention initiatives is provided with the data elements in Section 8 of this plan.
Five-year Accident History
No reportable incidents related to ammonia storage have occurred.
Emergency Response Program
In the event of an emergency involving propane or ammonia storage vessels, Plainwell Tissue will notify the Eau Claire
Fire Department HAZMAT team or the Eau Claire LEPC as appropriate. The emergency response plan (prepared for propane releases under 40 CFR Part 68) and the Process Safety Management Plan (prepared for OSHA compliance) will be used for response activity guidance by Plainwell Tissue. Because Plainwell Tissue is not a primary responder to any ammonia release, no formal classroom training for response plans (HAZWOPER, 40-hr, etc.) is required.
Planned Changes to Improve Safety
The RMP includes changes, developed in recent years, which have already been implemented to improve safety at the mill. This includes replacement of storage vessel equipment to allow the mill to replace the use of anhydrous ammonia with aqueous ammonia. With this change, any accidental release of ammonia would cause the ammonia in a water solution to be discharged to a concrete berm forming a pool, and ammonia would only gradually evaporate from this pool. Ammonia releases as previously configured would more rap
idly be released as a gas.
No new changes to the safety plans are anticipated.