ACCIDENTAL RELEASE AUDIT
INTERNATIONAL PAPER COMPANY
ANDROSCOGGIN MILL
JAY, MAINE
APRIL 20-27, 1988
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY - REGION I
ENVIRONMENTAL SERVICES DIVISION
60 WESTVIEW STREET
LEXINGTON, MASSACHUSETTS
02173
DATE OF REPORT: 6/30/88
REVISED ON: 11/30/88
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TABLE OF CONTENTS
PAGE *
1.0 INTRODUCTION. . . . . .
1.1 Report Organization.
1.2 Site Description
1.3 Background . .
2.0 GOALS AND OBJECTIVES.
2.1 Purpose. . . .
2.2 Methodology. .
3.0 AUDIT TEAM COMPOSITION.
4.0 FACILITY REPRESENTATION
5.0 GENERAL PROCESS DESCRIPTIONS.
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5.1
5.2
5.3
5.4
5.5
5.6
5.7
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Aiiunonia . . . . .
Chlorine . . . .
Chlorine Dioxide
Sodium Hydrosulfite.
Sulfur Dioxide .
References . . .
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Wood Supply. • • . . . . . .
Groundwood • • • . . . . . .
Bleached Kraft Pulp. . . . .
Papermaking. . . . . . . . .
Steam and Power. . . . . . .
Water Supply and Treatment .
Effluent Treatment . . . . .
Maintenance and Technical Services
6.0 HAZARDOUS CHEMICALS AND TOXICOLOGY.
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HAZARDOUS CHEMICAL STORAGE. . .
8.0
RELEASE PREVENTION. . . . . . .
8.1 Engineering Controls . . . . . . .
8.2 Administrative Controls. . . . . .
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8.3 Personal Respiratory Protection. .
8.4 Facility Scrubber Systems. . . . .
8.5 Interlock Conditions . . . . . • •
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8.6 Training . . . . . • • . . . . • .
8.7 Process & Control (P & C) Diagrams
8.8 Hazardc us Materials Unloading. . •
8.9 Power Failure/Backup . . . • . . .
8.10 Valve Fail—safe Conditions . . . •
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TABLE OF CONTENTS
Page Two
PAGE #
9.0 PAST HAZARDOUS MATERIALS INCIDENTS AND RELEASES . . 26
9.1 Sodium Hydrosulfite — 4/18/87. . . . . .
9.2 Arihydrous Ammonia — 11/6/87. . . . . . .
9.3 Chlorine/Chlorine Dioxide — 2/5/88 . . .
9.4 Non—Notification Release Incidents . . .
10.0 EMERGENCY RELEASE EXERCISE. . . . . . . . . . . . . 35
10.1 Observations. . . . . . . . . . . . . . . .
10.2 Recommendations...... .. . ..
11.0 AIR DISPERSIONMODELING. . . . . . . . . . . . . . 37
11.1 Sodium Hydrosulfite/Sulfur Dioxide - 4/18/87.
11.2 Anhydrous Ammonia — 11/6/87 . . . . . .
11.3 Chlorine Dioxide — 2/5/88 . . . . . . .
11.4 Worst Case Scenario - Chlorine Dioxide Tank
11.5 Worst Case Scenario - Anhydrous Ammonia Tank.
11.6 Worst Case Scenario - Chlorine Rail Car
12.0 SUMMARY OF FIELD NOTES. . . . . . . . . . . .
13.0 RECOMMENDATIONS . . . . . . . . . . . . . . .
14 • 0 CONCLUSION. . . . . . . . . . . . . . . . . .
I. PhotographLog. • . . . . . . . . .
II. Air Model — Sulfur Dioxide . . . . •
III. Air Model - Anhydrous Ammonia. . . •
IV. Air Model - Chlorine Dioxide . . • .
V. Worst Case Scenario — Chlorine Dioxide
Storage Tank . . . . . . . . . . .
VI. Worst Case Scenario — Arthydrous Ammonia
Storage Tank . . . . . . . . . . . . .
VII. Worst Case Scenario - Chlorine Rail Car.
VIII. Mill Plot Plan . . . . . . . . . . .
IX. Hazardous Substance Storage. . . . .
X. General Kraft Pulping Schematic. . .
XI. Pulp Process Hazardous Substance Summary
XII. Kraft Pulping Process/Pulping Liquor Terms
and Properties . . . . . . • . . .
XIII. Bleaching Vapor Collection . . . . .
XIV. Environmental Response Team Report •
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APPENDICES
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SECTION ONE
Introduction
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1.0 INTRODUCTION
On April 20-27, 1988, the U.S. Environmental Protection Agency
(EPA) conducted an in-depth Accidental Release Audit of
International Paper Company’s Androscoggin Mill (IP). The
facility is an integrated bleached kraft mill which manufactures
coated and uncoated white and colored papers for magazines and
business applications. It also produces carbonizing tissue and
forms paper.
The purpose of the audit was to investigate the causes of the
releases at this specific facility and the equipment, procedures,
training and management techniques utilized to prevent or
mitigate these releases. The evaluations made were based on a
comparison with available release potential technology and not on
the general practices of the paper industry. The intent of this
audit was to provide IP with information to enhance chemical
safety practices at the facility and reduce the likelihood of
future releases.
The mill utilizes a multitude of chemicals in the manufacturing
process. Many of these chemicals are considered hazardous and
extremely hazardous, and their use can result in serious safety
and environmental consequences unless proper safeguards and
prevention measures are routinely implemented. A firm commitment
to preventing chemical releases, beginning with high-level
corporate management, is a prerequisite to health and safety and
environmental protection at IP. This is especially important
because the facility is located within one mile of businesses and
residences. Schools are located within two miles of the mill.
There are approximately 5,000 people within a five-mile radius of
the facility, and more than 1,000 people are employed at IP. The
mill is located on the banks of the Androscoggin River, a
sensitive environmental area. The populace and environment are
within the impact area of chemical releases.
The audit results demonstrate the lack of adequate performance by
IP management and staff on chemical emergency preparedness and
accident prevention. This report describes numerous accidental
releases at IP which have occurred over the past two years. Some
of these releases posed a direct threat to the surrounding
community and environment. The number of releases and their
frequency of occurrence shows the lack of proper prevention
systems. Field observations document that sufficient corrective
measures have not been implemented to minimize the probability
of future chemical releases. Recommendations to improve safety
are contained in Section 13.0 of this report.
Our observations provide a snapshot of the conditions that
existed at the mill during the audit period, and are not a
substitute for a comprehensive safety evaluation program.
International Paper has informed EPA that safety enhancements
have been made since the audit and that many of the Audit Team’s
recommendations have been followed.
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The audit was conducted under the authority of the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA),
as amended by the Superfund Amendments and Reauthorization Act
(SARA); Clean Air Act (CA.A); Resource Conservation and Recovery
Act (RCRA); and EPA’ s Accidental Release Information Program. It
was fully coordinated with the numerous State and Federal
agencies having jurisdiction over the facility. Comprehensive
information sharing occurred among the various agencies so as not
to duplicate efforts and to maximize utilization of the limited
amount of resources devoted to the audit. The Federal Emergency
Management Agency (FEMA) conducted the alert and notification
portion of the audit; their report is available from the FEMA
Region I office. FEMA is located at the J.W. XcCormik Post
Office Building and Courthouse in Boston, Massachusetts.
International Paper cooperated in the Accidental Release Audit
and provided EPA with all necessary information upon request.
The facility has made significant improvements in preparedness
and prevention systems over the past several months. Many
improvements were being made during, and as a result of, the
State and Federal audits and investigations that have occurred at
IP over the past several months. Although improved safety may
have resulted from the audit process, additional measures are
necessary because of the history of releases at the facility and
the potential for severe environmental and safety consequences,
both at the mill and in the community.
1.1 REPORT ORGANIZATION
The report is organized in sections to allow easy access to any
particular area of interest. The information contained in each
section is described below:
o Section 1 - Introduction
This section also includes an overview of the
characteristics of the area surrounding IP and a background
description.
o Section 2 — Goals and Oblectives
This section identifies the goals of the Audit Team and
includes a discussion of the methodology used for
accumulating information. It is important to note that the
audit is a preliminary survey and is not a substitute for a
comprehensive hazards analysis.
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o Section 3 - Audit Team Composition
This is a listing of the Team members and their specific
areas of expertise and responsibilities during the audit. A
team approach was used to provide checks and balances and to
insure maximum coverage over the specified audit period.
o Section 4 - Facility Rem resentation
This identifies major IP participants and their titles and
functions during the audit. Other I? personnel willingly
participated and provided valuable information to EPA.
o Section 5 - General Process Descriptions
This section provides an overview of the processes utilized
in the production of pulp and paper and other areas of the
process where hazardous materials are used.
o Section 6 — Hazardous Chemicals and Toxicoloav
This is a comprehensive description of hazardous and
extremely hazardous chemicals at the mill, with emphasis on
their properties and dangers. This section can be used to
increase community awareness and training.
o Section 7 — Hazardous Chemical Storage
This is a review of the storage conditions for the chemicals
described in Section 6.0, with particular attention focused
on containment, hazards, and storage systems.
o Section 8 — Release Prevention
This section details various policies, plans, systems, and
equipment in place at the mill and includes observations on
safety—related improvements.
o Section 9 — Past Hazardous Materials Incidents and Releases
This is a complete recounting of three major chemical
releases that have occurred at IP since early 1987 (sodium
hydrosulfite, anhydrous ammonia, and chlorine/chlorine
dioxide). It contains a description of chemical identities,
event sequences, notification, and corrective actions taken
by IP. A discussion of several less severe releases is
also included.
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o Section 10 — Emer encv Release Exercise
During the audit, an Emergency Release Exercise was staged
at the request of the EPA team. A brief description of the
exercise is included, along with observations and
suggestions for improvements.
o Section 11 — Air Disiersion Modelin
This section contains an impact analysis for the three major
releases identified above and a credible worst case analysis
for the chlorine dioxide and anhydrous ammonia tanks and a
chlorine tank car. This analysis was done using a rough
screening model to estimate potential community impacts and
to determine if sophisticated modeling is necessary.
o Section 12 — Summary of Observations
This is a summary of the Team members’ observations during
all phases of the audit, focusing primarily on release
prevention and safety systems.
o Section 13 — Recommendations
The Audit Team’s viewpoints regarding the potential for
future accidental releases at the mill. Specific
recommendations for implementation of additional safety
measures are contained in this section.
o Section 14 — Conclusion
This is an overview of the audit and the Audit Team’s
reaction to the changes implemented and those planned for
the future.
1.2 SITE DESCRIPTION
International Paper Company’s Androscoggin Mill is situated on
the west side of the Androscoggin River in Jay, Maine. The mill
site covers an area of over 600 acres. The terrain surrounding
the mill is a rolling hillside which terminates in a river valley
of the Androscoggin River. The highest point on the mill site is
the landfill, at an elevation of 600 feet; the lowest elevation
is the waste treatment plant at 460 feet. Elevations of release
points and prevailing wind directions are such that accidental
chemical releases have the potential to impact the community
adversely.
Paved and dirt roads provide access to virtually every area on
the mill site. State Routes 4 and 133, in addition to local
routes, provide access through the communities. Additionally,
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the Rumford branch of the Maine Central Railroad runs through the
mill site and local communities. Holding tracks for materials en
route to the mill are located in the center of neighboring
Livermore Falls on the east bank of the Androscoggin River. This
network is used for the transportation of hazardous chemicals as
well as by emergency responders and for evacuations.
Although located in Jay, the mill is 3.5 miles north of Livermore
Falls and 1.5 miles east of the Town of Canton; these communities
also take a keen interest in the activities at the mill because,
depending on atmospheric conditions and the magnitude of a
potential release, these communities could be involved in a
coordinated emergency response or evacuation.
The nearest residence is located 100 yards from the boundary of
the mill, and the nearest business is 1.3 miles from its gate.
The Jay School and Jay High School are situated 1.7 and 1.8 miles
south of the mill, respectively. There are 631 residences and
100 business located within a five-mile radius of the mill. This
situation requires fast, efficient alert and notification
procedures, which do not currently exist satisfactorily in the
tn-town mill area.
1 • 3 BACKGROUND
The Androscoggin Mill operates 24 hours a day, seven days a week.
It is a bleached kraft mill which manufactures white and colored
papers for magazines and business forms and carbonizing tissue
for use in business papers. It is an integrated pulp and paper
facility, providing both pulping and papermaking processes on
site. Raw products used in the production process are
predominately wood, water, and primary process chemicals.
On June 16, 1987, members of the United Paperworkers
International Union and the Brotherhood of Firemen and Oilers
went on strike at the plant; subsequently, management hired
replacement workers to fill the vacancies. The strike situation
was disruptive to the operation of the facility, and it upset the
relationship between the mill, the emergency responders,
planners, and the community.
Within the past several months, compliance inspections have been
conducted at the mill by various Federal, State, and local
agencies such as the U.S. Occupational Safety and Health
Administration (OSHA) and the Maine Department of Environmental
Protection (DEP). Their findings are documented in reports on
file at the individual agencies.
This audit c oes not focus on regulatory compliance. Audit goals
and objectives are identified in the following section.
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SECTION TWO
Goals and Objectives
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2.0 GOALS ND OBJECTIVES
2.1 PURPOSE
The purpose, goals, and objectives of the Accidental Release
Audit were to:
o assess chemical emergency prevention procedures;
o determine the potential for and consequences of off-site
chemical releases;
o conduct a government file review to determine the compliance
status with Federal and State environmental programs and
regulations;
o determine the need for independent media inspections; and
o recommend measures to correct safety hazards.
2 • 2 METHODOLOGY
The Team spent the early part of the audit interviewing various
IP employees. Topics discussed included the following:
o past hazardous materials release incidents;
o IP’s Emergency Response Procedures and Contingency Plans;
o training (new employee, contractor, Hazmat Team, Fire
Brigade, etc.);
o environmental permits and licenses;
o chemical handling and storage;
o alert and notification procedures;
o safety programs (e.g., Respiratory Protection Program);
o maintenance (e.g., upkeep of personal protection equipment,
calibration of monitoring instruments, etc.);
o community relations;
o inspections and drills; and
o other safety—related topics necessary to gain a complete
overview of IP’s potential for chemical releases.
After thoroughly interviewing IP employees, the Audit Team was
given tours of the pulp mill, treatment plants, power plant,
landfill, and other areas where hazardous chemicals are handled.
The locations of past releases were inspected and photographed
(see Appendix I). Equipment, production processes, and methods
were scrutinized for potential safety hazards. Team members
questioned individual employees to obtain perspectives on plant
safety.
An emergency release exercise was conducted which involved the
sounding of emergency alarms and the subsequent evacuation of
area workers. This drill is fully discussed in Section 10.0 of
the report.
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CHAPTER THREE
Audit Team Composition
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3.0 AUDIT TEAM COMPOSITION
The Accidental Release Audit Team was comprised of the following
individuals (all of whom assisted in the preparation of this
report), chosen for their expertise in diversified environmental
and safety disciplines.
AUDIT TEAM MEMBER AFFILIATION RESPONSIBILITY
Ray DiNardo EPA, Region I Team Coordinator and
Mechanical Systems
Steven Novick EPA, Region I Technical Assistance
Team (TAT) Manager
Norman Beddows EPA, Region I Health and Safety
Manager
Richard Homer EPA, HQ Headquarters
Coordination
David Salt Maine Dept. of State Coordination
Environmental
Protection
Vickie Santoro EPA, Environ- Safety and Response
mental Response Systems
Team (ERT)
Susan Fields EPA, ERT Control Equipment and
Response
Cosino Caterino TAT Chemical Systems
Ellen Gluey TAT Technical Information
Coordination
Martha Poirier TAT Chemical Information
Coordination
Gerald Wire G. WIRE CO. Paper Process
Consultant
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SECTION FOUR
Facility Representation
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4.0 FACILITY REPRESENTATION
The following members of IP management and staff participated
either on a full—time basis or were available upon request during
the full course of the Audit:
James Thompson — Resident Manager
Ronald Charbonneau — Manager of Operations
Bert Turmel — Manager of Manufacturing
Jo-Anne Bean — Environmental Engineer
Lawrence Pattengil - Environmental Engineer/IP, Atlanta
Robert Funkhouser - Attorney/IP, Memphis
Kenneth Gray — Attorney — Pierce, Atwood, Scribner, Allen,
Smith & Lancaster
Daniel Boxer - Attorney - Pierce, Atwood
Bonnie Urauhart — Hazardous Materials Coordinator
Elizabeth Martin - Pulp Mill Supervisor
Arthur Young — Power Plant Supervisor
Susan Vantilburg - Safety Supervisor
Diane Johnson - Industrial Hygienist
James Benson — Chief, Fire Brigade
Peter Fredericks — Supervisor, Groundwood
David Bailey - Manager, Technical Services, Paper Group/IP,
Purchase, NY
J. P. Drotter - Acting Power Plant Superintendent
Mac Daniels - Training Coordinator/IP, S. Carolina
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SECTION FIVE
General Process Descriptions
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5.0 GENERAL PROCESS DESCRIPTIONS
5.1 WOOD SUPPLY
Roundwood and wood chips are received by truck. Processing
consists of drum debarking, chipping, screening, and storage.
The mill processes hardwoods (birch, beech, maple, and oak), and
softwoods (spruce, fir, hemlock, and pine).
Fire at any large industrial facility can cause chemical
releases. The wood supply represents a potential fire hazard;
however, incidents at IP have been confined or readily
controlled. The wood area uses uncontrolled pneumatic chip
transfer operations, a practice that can contribute to
particulate air pollutants becoming airborne.
5 • 2 GROUNDWOOD (130 TPD)
This process involves five Great Northern grinders and subsequent
bleaching with V-Brite (sodium hydrosulfite) (Na 2 S 2 O 4 ).
The groundwood process itself is wholly mechanical in the
presence of water and represents few potential chemical release
problems. A walk-through of the groundwood area did not identify
any serious chemical hazards. However, the V—Brite storage and
handling has been a problem and the source of several past
incidents. This system is discussed further in Section 9.0 of
this report.
5.3 BLEACHED KRAPT PULP (1300 TPD)
The pulping process consists of two lines, designated as A and B.
Both lines employ similar Kamyr continuous digesters and short-
sequence bleach lines. A single, centralized control room serves
pulping; washing, screening, and cleaning; bleaching; and
chemical preparation. Most controls are 1965-1975 vintage Fisher
instruments. Certain digital logic and display apparatus are
used for informational purposes.
The control room was somewhat crowded, a condition exacerbated by
the presence of many maintenance personnel and visitors. Control
room air is purified and conditioned by two Westvaco units to
protect the digital electronics and peripherals. However, IP has
not determined if the units could purify high concentrations of
contaminated air from an accidental release. This critical
control room is vulnerable to chemical accidents.
Operations personnel were orderly and appeared competent.
Generally, the operation was judged to be reasonably modern. The
Audit Team observed difficulties in maintaining smooth decker
operations and an overflow condition which is indicative of
improper operation or maintenance. There did appear to be a good
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deal of maintenance work underway. Cleanliness and housekeeping
could be improved in the pulp mill. The Team observed black
liquor on stairways, rails, and dripping in some areas each time
the Team toured the mill area. The balance of the pulping
operations will be discussed in the order of inspection.
5.3.1 Pulping
The two single vessel Kamyr digesters appear to be in good
operational condition, and there were no major deficiencies
observed. Review of Process and Control drawings identified
questions about valve powerfail condition with respect to fail-
safe operations. These questions are discussed in subsequent
sections of the report.
5.3.2 Washing, Bcreening, and Cleaning
The washers consist of both conventional drum washers and
diffusion washers. In addition, there are knotters; primary,
secondary, and tertiary screening; centrifugal cleaning; decker
operations; and high—density storage transfer. To the extent
observable, these operations appeared to be in good condition.
However, the general area was somewhat cluttered from pulp and
black liquor spills and maintenance—related paraphernalia. There
were operational problems with the deckers, although this is not
necessarily unusual, especially during a startup. Problems with
deckers have caused occasional pulp spills.
5.3.3 cooking Liquor Processing
Kraft pulping liquors are strong caustic sulfide solutions (NaOH
+ NaSH), expressed as Na 2 0. White liquor is the pulping reaction
reagent, weak black liquor is the liquid resulting from the
pulping operation, and strong black liquor is evaporated and
concentrated weak black liquor. Green liquor is the dissolved
salts from the recovery furnace smelt.
The kraft pulping liquor cycle is a tight system of processes and
operations for the recovery and regeneration of the pulping
chemicals and the generation of heat and power. Acidified kraft
liquors are very dangerous because of hydrogen sulfide off-gas.
Adjunct to the liquor cycle is the lime cycle. White liquor is
regenerated from green liquor by causticizing it with lime (CaO:
Na 2 CO + CaO--— Na 2 0 + CaCO 3 ). The lime is regenerated in the
lime kiln. Gases from various liquor off—gas points are usually
burned in the lime kiln.
All of the liquor cycle operations of this mill are carried out
under the pulp mill group, with the exception of the evaporators
and recovery boilers, which are part of the power group. Weak
liquor-related operations occur mainly within the pulp mill
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control room. The green liquor, recausticizirig, and lime kiln
operations are separate, with a small control room adjacent to
the kilns.
The liquor cycle facilities observed were conventional and of the
type generally found in a kraft mill. This area of a mill often
does riot receive the attention that it should. It is generally a
hazardous area, and all personnel should receive proper and
continuous reinforcement training. For the most part,
cleanliness and housekeeping were not adequate. The lime kiln
area was excessively dusty.
5.3.4 Bleaching
There are two bleach lines, with both upflow arid downflow towers.
International Paper uses a modern, short-sequence bleaching
operation. Tower configurations, mixing, and flow arrangements
appear satisfactory. The Kajanni Cl 2 control system is operated
in a manner so as to prevent excessive Cl 2 addition and gas off.
Digital controls, for the most part, are not used.
There was no odor of Cl , or C10 2 . The Cl 2 and C10 2 washers,
towers, and tanks all had ’ hoods and/or vapor exhaust arrangements
connected to two stage scrubbers. There are separate systems for
the A and B sides. However, the Audit Team is not convinced that
the control system is capable of efficiently controlling chlorine
and chlorine dioxide gas releases (see Section 13.5).
5.3.5 Chemical Preparation
This consists of Cl 2 , NaOH, NaOC1, dO 2 , NaC1O 3 , H 2 S0 4 , NaC1,
and, in the near future, methanol (CH 3 dH) and peroxide (H 2 0 2 ).
Handling, preparation, by—products, emissions, and wastes are
potentially hazardous operations.
Chlorine and C10 2 have been the source of several past incidents,
and both require special care when handling. General pipeline
identification and color coding need improvement, as well as
general cleanliness and housekeeping. Each area is discussed
below.
5.3.5.1 chlorine (Cl 2 )
Liquid chlorine is received from railroad tank cars. The Cl 2
operation involves unloading, vaporizing, pressure and flow
control, and delivery to the point of reaction. There is a
railroad siding for connection of up to four 90—100 ton tank
cars. Equipment includes air and Cl 2 connection hoses; headers
and valving; dry (-40 0 F) padding air apparatus; Cl 2 vaporizors;
gas pressure controls; distribution piping; flow controls and
flow block valving; and barometric loops between dry and wet Cl 2
regions.
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The general arrangement appears satisfactory. However, the Cl
systems are in a high risk area and have been the source o
several recent incidents at this mill.
Not all piping was color coded or properly identified. The
changeover of Cl 2 piping to teflon-lined 316SS is underway, and
there is a regular program for piping maintenance and
replacement. Fail—safe condition of the Cl 2 and C10 2 flow
control valves is correct.
5.3.5.2 caustic (NaOH)
A 50% caustic solution is unloaded by railcar. The caustic
operation includes storage; dilution to 5%; dilute storage; and
distribution to mill operations.
Concern was raised regarding the adequacy of unloading practices
with truckers, spill/dump containment practices, and the lack of
proper decontamination procedures.
5.3.5.3 hypochiorite (NaOC1)
This is produced at IP by the reaction: 2NaOH + Cl 2 --- NaOC]. +
NaC1 + H 2 0. It is the same as common household bleach and
swimming pool “dry chlorine.” No particular problems were found
in this area.
5.3.5.4 sulfuric acid (H 2 80 4 )
This is used at the mill for ClO , production and for other acid
sources. It is received as 93 H 2 S0 4 in tank trucks and is
stored on site.
Concern was raised regarding unloading practices and spill/dump
containment procedures. Unloading and containment are further
discussed in other sections of this report.
5.3.5.5 sodium chlorate (NaC1O 3 )
This is the source raw material for dO 2 manufacture. It is
received as a dry, crystalline solid in railroad hopper cars.
The NaCl0 is unloaded, then dissolved in hot water. The
solution is fed to the SVP dO 2 generator, with H SO 4 and
methanol to produce C10 2 . Special training and precautions need
to accompany handling of chlorate material.
There is concern regarding the extent of training and
precautionary practices relative to disposal of chlorate—soaked
apparel and similar fire hazards. Specific decontamination
procedures for this material need to be developed. The level of
housekeeping and cleanliness in this area should be improved.
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5.3.5.6 methanol (CH 3 OE)
The mill plans to convert its SVP process to employ methanol in
the near future. Methanol is a hazardous material and
requires appropriate design, operation, and training.
5.3.5.7 chlorine dioxide (C]0 2 )
This chemical is produced as a gas in the SVP plant. In the
mixture with Cl 2 , dO, is absorbed in chilled water. The Cl 2 -
laden off-gas is abso bed in caustic-forming, weak hypochiorite.
The ClO, is stored in three fiberglass reinforced plastic (FRP)
tanks, fwo 30,000—gallon tanks, and one 150,000-gallon tank. The
150,000-gallon tank has been the source of a serious incident.
The SVP plant is a hazardous and dangerous operation. The C10 2
storage, spill prevention, routing, and containment require
improvements.
5.3.5.8 peroxide (H 2 0 2 )
Installation of an unload and storage facility is underway.
This process must be reviewed for safety prior to start up.
5.4 PAPERNAKING Fine, writing, and coated/1500 TPD
The mill operates five modern Fourdrinier paper machines,
producing a variety of business and printing paper grades. Two
machines are equipped for clay-coated publication grades. Paper
products are slit, rewound, wrapped, labeled, and warehoused for
shipment. There are no sheeting or converting operations. No
hazardous chemical deficiencies were identified in this area.
5.4.1 Stock Preparation
Raw pulp from the pulp mill is pumped as slurry from high density
storage and refined to produce desired paper properties. Other
materials such as clay, starch, rosen, alum, resins, dyestuff,
and process quality aids are blended in to achieve desired paper
properties.
5.4.2 Papermaking
A continuous paper sheet is formed from the paper stock. Water
is pressed out and removed through drying. Size (a starch—resin
solution) and/or coating (clay/TiO, and other pigments with
starch/resin binder) are applied, followed by additional drying.
The continuous sheet is then calendered to make it smooth and
wound onto a reel, forming a “jumbo” roll. This is removed
periodically, slit into smaller widths, and rewound into smaller
rolls. It is then wrapped and labeled for shipping. The entire
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process, from forming the sheet to winding it onto the jumbo
roll, is performed by the paper machine.
The materials used in this process are not usually considered
extremely hazardous. However, there are biocides/fungicides,
solvents, oils, etc. which are used in machinery care and
maintenance. Their use requires caution.
5.5 STEAM AND POWER
The kraft pulp mill has substantial steam and power needs. The
high demand for chemical recovery by furnace combustion justifies
the need for cogeneration. The heat and power specifications for
this mill are:
Steam: 1.4 million lb./hour at 900 psig and 825°F from two
recovery boilers, two oil—fired power boilers, and one
waste fuel (bark) boiler.
Power: 98 MW, generated by one BP and two condensing
turbogenerators and several small hydrogenerators.
Additional power is purchased from Central Maine Power
Company.
The power plant is operated from a central control room within
the boiler complex. The arrangement was very good, well ordered,
and clean. The controls were arranged in conventional manner, in
accordance with the operating units. The panel—mounted
instruments were of 1965-1975 analog vintage, mostly Fisher. A
Measurex 2001 supervisory boiler control system, which was valued
by the operator because of its dependability, was also in use.
The following deficiencies were observed:
o #1 recovery boiler ESP procedure was not fully automated;
o low water drum level response delay was deficient; and
o hydrogen gas transfer practice was inadequate.
Overall, this plant area, boilers, turbines, evaporators, and
auxiliaries appeared to be in good condition, with excellent
cleanliness and housekeeping.
5.6 WATER SUPPLY AND TREATMENT
Water supply is obtained from the Androscoggin River at
approximately 34-50 MGPD. Treatment methods include alum
flocculation, sand bed filter, and chlorination.
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5.7 EFFLUENT TREATMENT
Ef fluent treatment facilities consist of the following:
o Primary Clarifiers - 2-Dorr Oliver circular rake type;
o Secondary Clarifiers — 2-Dorr Oliver circular rake type;
o Aeration Lagoon — 28 Eimco Aerators; and
o Sludge System — flotation, filter, press, to landfill.
Bioactivity nutrient is provided by anhydrous ammonia. The
anhydrous ammonia has been the cause of a serious incident, and
raises questions about truck unloading and lock—out tag—out
procedures.
5.8 MAINTENANCE AND TECHNICAL SERVICES
5.8.1 Maintenance
The mill employs a full maintenance staff of tradesmen (i.e.,
machinists, mechanics, millwrights, welders, pipefitters,
electricians, instrument technicians, etc.). These are
complemented with routine and preventative staff (i.e., oilers,
analysts, coordinators, and other specialists). They are
organized into three areas, four back shifts (touring
maintenance), and a yard crew. They all report to the Manager of
Operational Services.
5.8.2 Technical
Many areas of process and manufacturing require physical and
chemical testing. This is carried out by operating or testing
personnel, as appropriate. Procedures, materials, and standards
are under the laboratory services supervisor.
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SECTION SIX
Hazardous Chemicals and Toxicology
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6.0 HAZARDOUS CHEMICALS AND TOXICOLOGY
The following chemicals were involved in major releases at IP
since April, 1987. The paragraphs below include information on
physical description, exposure limits, health hazard information,
toxicology, and incompatibilities of these hazardous chemicals.
6.1 AMMONIA (NH 3 )
Ammonia is a colorless gas with a penetrating, pungent,
suffocating odor; it can be a liquid under pressure.
The Permissible Exposure Limit (PEL) is 25 parts per million
(ppm), and the Immediately Dangerous to Life and Health (IDLH)
level is 500 ppm.
Ammonia can affect the body if it is inhaled or if it comes in
contact with eyes or skin. It may also affect the body if it is
swallowed.
Short—term exposure can cause severe irritation to the eyes,
respiratory tract, and skin. It may cause burning and tearing of
the eyes, runny nose, coughing, chest pain, cessation of
respiration, and death. It may cause severe breathing
difficulties, which may be delayed in onset. Exposure of the
eyes to high gas concentrations may produce temporary blindness
and severe eye damage. Exposure of the skin to high
concentrations of the gas or liquid may cause burning and
blistering of the skin. Repeated exposure may cause chronic
irritation of the eyes and upper respiratory tract.
Inhalation of concentrations of 2500 to 6500 ppm causes
difficulty in breathing, bronchial spasm, chest pain, and
pulmonary edema. Consequences can include bronchitis and
pneumonia and/or some residual reduction in pulmonary function.
Tolerance to usually irritating concentrations of ammonia may be
acquired by adaptation.
Ammonia has a characteristic odor detectable at 1 to 5 ppm.
It is incompatible with strong oxidizers, cadium, bleaches, gold,
mercury, silver, and halogens, and is used primarily in waste
treatment as a nutrient.
6.2 CHLORINE (C L 2 )
Chlorine is an amber liquid or greenish-yellow gas with an
irritating odor. The PEL for chlorine is 1 ppm; the IDLH level
is 30 ppm.
Chlorine can affect the body if it is inhaled or if it comes in
contact with the skin or eyes.
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Short—term exposure to chlorine may cause burning of the eyes,
nose, and mouth; sneezing; coughing; choking; and chest pain.
Also, severe breathing difficulties may occur which may be
delayed in onset. Pneumonia may result. Severe exposures may be
fatal. In high concentrations, chlorine may irritate the skin
and cause sensations of burning and prickling, inflammation, and
blister formation. Liquid chlorine may cause eye and skin burns
on contact. Repeated or prolonged exposure may cause corrosion
of the teeth, skin irritation, and mucous membrane inflammation.
The odor threshold for chlorine has been reported between 0.02
and 0.2 ppm. Nasal irritation and coughing appear at about 0.5
ppm. Factory fatigue may develop at low concentrations, and some
tolerance is built up in chronic industrial exposures. Chronic
exposure may increase susceptibility to respiratory infections.
Chlorine is incompatible with combustible substances and finely-
divided metals.
Chlorine is used in the pulp mill and in the water treatment
plant.
6.3 CHLORINE DIOXIDE (dO 2 )
Chlorine dioxide is a yellow-green to orange gas or liquid with a
pungent, sharp odor.
The PEL level is 0.1 ppm, and the IDLH level is 10 ppm.
Chlorine dioxide can affect the body if it is inhaled or if it
comes in contact with the eyes or skin. It can also affect the
body if it is swallowed.
Short—term exposure to chlorine dioxide may cause irritation to
the eyes, nose, throat, and lungs. It may produce coughing,
wheezing, and severe breathing difficulties, which may be delayed
in onset.
Repeated exposure to chlorine dioxide may cause chronic
bronchitis. It has an odor threshold of 0.1 ppm and is
incompatible with combustible substances, dust, organic matter
and sulfur.
Chlorine dioxide is used for pulp mill bleaching.
6.4 SODIUM HYDROSULPITE (NA 2 0 4 S 2 ) (V-BRITE)
Sodium hydrosulfite is a white or grayish white powder; it has a
slight characte”-istic odor.
There are no PEL or IDLH levels available. Sodium hydrosulfite
is a strong reducing agent. It may cause irritation to the eyes
and respiratory system. It also may cause chemical burns on
skin.
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Sodium hydrosulfite is incompatible with moisture; contact with
moisture causes a chemical reaction. It is used for groundwood
bleaching. Sulfur dioxide can be a decomposition or combustion
product.
6.5 SULFUR DIOXIDE (SO 2 )
Sulfur dioxide is a colorless liquid or gas with a characteristic
pungent odor.
The PEL is 2 ppm; the IDLH level is 100 ppm.
Sulfur dioxide can affect the body if it is inhaled or if it
comes in contact with eyes or skin.
Exposure to sulfur dioxide may cause aggravation of respiratory
diseases (including asthma, chronic bronchitis, and emphysema),
reduced lung function, irritation of eyes and respiratory tract,
and increased mortality. It may also cause eye and skin burns.
Sulfur dioxide was produced and released during the V-Brite spill
on 4/18/87.
6 • 6 REFERENCES - HAZARDOUS CHEMICALS
Patty’s Industrial Hygiene and Toxicology; 3rd Revised Edition;
Volume One, General Principles; John Wiley and Sons, New York;
1978
Merck Index; Tenth Edition; Merck and Co., Inc.; 1983
Hawley’s Condensed Chemical Dictionary; Eleventh Edition; Van
Nostrand Reinhold, Co., New York; 1987
ACGIH TLV & Biological Exposure Indices for 1987 - 1988; ACGIH;
1987
NIOSH Pocket Guide to Chemical Hazards; DHHS (NIOSH) Publication
No. 85—114; 1987
Occupational Health Guidelines for Chemical Hazards; DHHS (NIOSH)
Publication No. 81—123; 1981
Material Safety Data Sheets (MSDS) (provided by IP)
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CHAPTER SEVEN
Hazardous Chemical Storage
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7 • 0 HAZARDOUS CHEMICAL STORAGE
There are many hazardous substances used and stored at the mill.
They include bulk quantities of anhydrous ammonia; liquid
chlorine; (6—8 gpl.) aqueous chlorine dioxide; 98% sulfuric acid;
phosphoric acid; 50% caustic soda; dry sodium chlorate; alum;
lime; white, green, and black liquors; petroleum fuels; and, in
the near future, methanol and peroxide. These materials are
received in truck or railcar quantities, with the exception of
chlorine dioxide, lime, white, green, and black liquors, all of
which are produced on site. There is also an array of chemicals
and hazardous substances received by truckload or rail and
packaged in drums, barrels, bins, etc. These include sodium
hydrosulfite, biocides, lubricants, solvents and cleaners, and
bottled gases such as chlorine, hydrogen, acetylene, and oxygen.
The bulk materials that are received by truck or railcar tankload
are of f loaded into tanks with the capacity to hold two or more
loads. An exception is chlorine dioxide, which is received and
stored in up to four 90-100 ton rail tanks and consumed directly
from the air-padded cars. Chlorine dioxide is stored at up to
eight gpl. in two 10’ X 25’ (30,000-gallon capacity each) and one
30’ X 30’ (158,000—gallon capacity) FRP tanks. Lime is produced
on site in a kiln and is dry bulk stored in the “reburned lime
bin.” Purchased makeup lime is stored in the “fresh lime bin.”
White, green, and black liquors are stored in a number of tanks
in accordance with process requirements.
Some liquid—containing tanks are surrounded by containinents.
However, the chlorine dioxide tanks do not have spill
containment, a condition which should be corrected. Chlorine
dioxide spills could be contained and controlled while being
routed to acidic sewers. A bermed area should be available for
containment to prevent sewer overflow and runoff. The acidic
sewer could lead to an emergency retention area where the C10 2
would be treated with an appropriate neutralizing agent. Then
the material could be sent through the wastewater treatment
system at a controlled rate.
There is a need for evaluation and risk assessment with respect
to these storage and handling practices, particularly the
chlorine dioxide storage. Smaller chlorine dioxide tanks would
reduce the risk of a very large volume spill and, if designed for
50% level operation and adequate pump ability, they would provide
emergency containment capacity in the event of an accident.
Additionally, the safety of hazardous materials receiving,
internal transport, unloading, and egress practices need to be
evaluated.
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SECTION EIGHT
Release Prevention
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8.0 RELEASE PREVENTION
The following subsections evaluate release prevention procedures
currently in use at IP and discuss what IP has done to reduce the
likelihood of future hazardous material releases.
8 • 1 ENGINEERING CONTROLS
It is apparent that insufficient effort has been undertaken to
utilize qualitative approaches for establishing facility safety
and prevention systems for dealing with major releases that may
impact the community. Techniques exist for preventing major
accidents in industrial facilities. These include: Process
Hazard Analysis (PHA); Hazard and Operability studies (HAZOP);
Failure Modes and Effects Analysis (FMEA); etc. Also, techniques
exist for estimating risks using atmospheric dispersion modeling
(see Section 11.0) and other less sophisticated techniques. The
need for IP to employ these techniques at the Jay facility is
evident. International Paper does not have an acceptable
hazardous assessment program for investigating accidents, near
misses, and process changes.
As an example, the anhydrous ammonia storage tank fill line
(which was involved in an accidental release) was not revalved to
prevent reoccurrence of the release. A possible way to prevent
the problem of accidental ammonia release might be to insert a
check valve in the fill line between the two existing ball
valves. In this case, IP mitigated the release when it occurred
by simply closing the valve, but did little to prevent it from
reoccurring. Prevention studies for past accidents should have
been a top priority.
Another observed problem is how plant modifications are managed.
An example is the change made to the chlorine dioxide storage
tank after the 2/5/88 incident (which involved a 4-inch diameter
valve being broken due to operator error, according to IP
personnel). The expeditious solution to this failure was to
eliminate the valve. This was done without any reliability
engineering analysis. While this change to the tank mitigated
the incident, it could in fact create new problems. To
illustrate the point: if drainage of the chlorine dioxide tank
were to become critical for safety, the only current means would
be to slowly pump it through the physical plant. In this case,
IP failed to take a systems approach to accident prevention.
A formalized hazards analysis program is needed at IP. Major
physical changes to the plant which involve hazardous materials
should not be made before a formal change ‘,rocedure is completed
and the change is authorized by competent engineering and
independent safety personnel, in accordance with good engineering
practice.
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8.2 ADMINISTRATIVE CONTROLS
Written safety plans and procedures are not fully developed; in
fact, many programs (Hazmat Team, fit testing, entrance permits)
had been in place for only a few weeks at the time of the Audit.
Although IP has made extraordinary efforts to develop the
necessary site safety and contingency plans, the plans are not
completed, certified, or tested. Moreover, the plans are not
adequately integrated with the surrounding coimnunities and mutual
aid networks.
In response to our inquiries about the plans, documentation was
produced by IP. However, it was inadequate in many areas. For
example, names of Hazmat Team personnel and routes of emergency
egress were nonexistent.
8.3 PERSONAL RESPIRATORY PROTECTION
Inspection of the respirator storage area in the pulp mill’s
control room disclosed one opened chlorine canister (presumed to
be spent) in the storage rack. Additionally, some disorder in
the storage of air tanks and masks was evident. However, an
extensive array of SCBAs was in proper order. Inspection tags
showed only one previous inspection occurring in early April.
The maintenance program and the respiratory protection program
need improvement.
84 FACILITY SCRUBBER SYSTEMS
Because of time allowed and scope of this investigation,
sufficient data and information were not obtained to conduct an
in-depth evaluation of the facility’s scrubber systems. However,
it is recommended that an in—depth review be conducted because of
the numerous deficiencies observed. In particular, emphasis
should be placed on the chlorine and chlorine dioxide scrubbers
and the scrubbing system for the pulp mill’s control room
atmosphere.
Some general observations were made on the scrubbing systems.
The pulp mill’s control room is the operations center for routine
operations as well as during an emergency. It is located in the
middle of major hazardous materials processing and storage areas.
Although the room receives air that is first cleaned through a
scrubbing system and personal protective equipment is available
as a back—up system, it does not appear that the scrubber would
have the capacity to sufficiently purify a highly-concentrated
atmosphere that may result from ar accidental release. As such,
the system may give the operators a false sense of security
during critical emergency operations, and the emergency would not
be managed from a “safe haven” operations center. The scrubber
utilizes a vapor adsorption system to control chlorine, hydrogen
sulfide, and sulfur dioxide levels.
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The manufacturer of the scrubber inspects it on a quarterly basis
and refills the active material, in accordance with an agreement
with IP. During the most recent inspection, maintenance was
observed to be marginal.
The purpose of the scrubber appears to be to protect electrical
and electronic equipment from corrosion. The room is under
positive pressure, and an air—locking passageway separates the
room from other areas. The probability of an accidental release
reaching the scrubber intake and the ability of the scrubber to
reduce a concentrated atmosphere should be investigated to
determine if a change in the emergency procedures is needed.
Procedures are critical to plant and community safety. During a
review of the bleach plant scrubbers, system leaks and equipment
malfunctions were observed.
The scrubbers have never been tested to determine removal
efficiency and emission levels under current operating and
emergency conditions. The units do not have the operating
controls and gauges necessary to assure safe operation. There is
no reasonable assurance that the units are properly controlling
hazardous gas emissions.
8.5 INTERLOCK CONDITIONS
The mill’s interlock schematic data provided was reviewed, and no
deficiencies were found. However, this review was extremely
cursory.
8.6 TRAINING
Several training programs are currently in place at the mill.
Some were instituted as a result of the influx of new hires
following onset of the strike, and some were reasonably well
established at the time of the audit.
All new hires are presented a four—hour chemical handling course,
while contractors receive an abbreviated version of the same
presentation. Additionally, employees receive department-
specific training which is oriented towards the chemicals
utilized in their work areas.
The following is a listing of additional training courses
provided to new hires, dependent upon their specific need for
such instruction:
o Hearing Conservation;
o Fire Protection;
o Environmental Considerations;
o Forklift Operations (safety);
o Forklift Driving;
o First Medical Response;
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o Cardiopulmonary Resuscitation;
o Back School;
o Rigging and Lifting; and
o Paper Mill Safety.
Some training programs, such as management and skill training,
are provided to IP employees by private contractors. Supervisory
personnel are requested to attend a 17 week safety course which
is offered at a nearby university during non-work hours. The
course is available to hourly workers as well.
A formal training program for the Hazmat Team was being to be
developed and therefore could not be evaluated during the Audit.
The Team believes IP’s training programs are comprehensive and
well planned. However, it is apparent that some deficiencies
currently exist as several of the past chemical releases occurred
due to operator error rather than equipment malfunction.
8.7 PROCESS AND CONTROL (P & C) DIAGRAMS
Several flow and P & C drawings were reviewed. In many cases,
the P & C’s were original plant design drawings and incorrect
with regard to production, consistency, and flow rates. In many
circumstances, the drawings were not representative of present
operations. The mill has changed hazardous material process
lines without proper design and safety documentation.
8 • 8 HAZARDOUS MATERIALS UNLOADING
As outlined previously in this report, the procedure for
receiving truck and rail loads of hazardous materials is
deficient. Specific problem areas are:
o Admittance, escort, and direction of trucker or railroad
switching operations.
o Process checkout of unload set—up and connection, and
authorization for unload by area supervisor.
o Unload and disconnect verification procedures before trucker
leaves, process conditions verification, and authorization
before placing the system on line again.
It is necessary to establish a very complete procedure for check-
in, unload, disconnect, and restart.
8.9 POWER FAILURE/BACKUP
The mill generates its own electricity requirements with three
steam turbogenerators and several small hydrogenerators. It is
interconnected to the utility for about 40% of its total load.
This is distributed through three two-way, manually switched
internal busses. As a part of their emergency backup power
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study, solid state controlled automatic switching of the present
manually—switched two way busses should be reviewed. A mill
power outage could cause chemical releases. Short-term surges can
cause switch gear kickout. Utility system brownout or a major
loss of power could trip this entire system.
There do not seem to be adequate provisions for emergency or
uninterruptable power to alarm sensors or annunciators,
conununications, or other emergency facilities and services. A
priority power distribution plan needs to be implemented, as well
as backup power for critical hazardous materials support systems.
8.10 VALVE PAIL-SAPE CONDITIONS
P&C diagrams were reviewed for valve condition upon utility
failure and follow up discussions were conducted with appropriate
IP supervisors. Although the particular diagrams used are not
reliable for a comprehensive assessment, they serve as an
indicator of safe conditions and a basis for value fail—safe
discussions. The review documented diagrams that were not
current and some critical valve fail conditions could not be
adequately explained. A detailed review of valve fail-safe and
interlock conditions is beyond the scope of this audit. However,
preliminary observations by the audit team justify the need for a
more comprehensive evaluation.
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SECTION NINE
Past Hazardous Materials Incidents and Releases
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9,0 PAST HAZARDOUS MATERIALS INCIDENTS AND RELEASES
Since April, 1987, three serious hazardous substance releases
have occurred at the I? facility. All but one of the instances
involved injuries. No fatalities occurred. At least two of the
releases had the potential for escalating into major disasters
for IP and the community. Below is a discussion of the three
major releases and an overview of several less serious incidents
which have occurred within the past two years.
9.1 SODIUM HYDROSULPITE - 4/18/87
On April 18, 1987, a release of 100 lbs. of sulfur dioxide gas,
at a concentration of up to 200 ppm, occurred. Sulfur dioxide
gas was produced as the result of sodium hydrosulfite reacting
with water.
9.1.1 Chemical Description - Sulfur Dioxide
Sulfur dioxide is a colorless, non—flammable gas with a strong,
suffocating odor which is intensely irritating to eyes and
respiratory tract. See Section 6.5.
9.1.2 Chemical Description - Sodium Hydrosulfite
Sodium hydrosulfite (V-Brite) is a white or grayish-white powder
with a slight characteristic odor. See Section 6.4.
9.1.3 Event Description
At 0700 hours on the above date, V-Brite contained in a steel
one—ton tote bin began burning, emitting sulfur dioxide vapor.
The fire began as a result of the V—Brite’s reaction with water.
At the time of the accident, IP did not have the V—Brite tote
bins contained in an enclosed area. However, they have since
erected one structure for storage of the bins and one for
dispension of the chemical (see Photograph Log - Appendix II).
At the time of the incident, the wind was traveling in a
southwesterly direction at 4 m.p.h. The humidity was 95%, and
the temperature was 42°F. There was no precipitation.
Upon discovery of the fire, IP’s Fire Brigade was notified, and
the area was immediately evacuated, although two injuries to
personnel were reported. The containers were transported to an
open, non—populated area to allow discharge to the waste
treatment plant. The release concluded at approximately 1300
hrs,, six hours after it had begun. International Paper believes
that no smoke or gas migrated off site, as it rapidly dissipated
to the upper atmosphere. As a precautionary measure, however,
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one nearby residence was evacuated. The site boundary was
approximately 500 yards from the source.
9 • 1 • 4 Notification
International Paper authorities eventually notified the following
Federal, State, and local agencies of the V-Brite incident:
o National Response Center;
o ME DEP/Bureau of Oil and Hazardous Materials Control;
o Jay Police Dept; and
o Jay Fire Department
The Jay Fire Chief notified the National Response Center shortly
after occurrence of the incident. However, IP representatives
did not contact Federal or State agencies until May 14, almost
one month after the actual release. Uncontrolled releases should
be reported to the proper authorities immediately to assure
proper alert and notification and response actions.
9.1.5 Release Prevention Practices
Groundwood Department personnel and others had received training
in handling V-Brite and how to respond in the event of an
emergency, including use of personal protective equipment. It is
company policy not to transport V—Brite containers in wet
weather.
International Paper’s report in response to the EPA’S Release
Prevention Questionnaire states that personnel had not recently
participated in dry run exercises and that, in fact, the
containers had been transported in wet weather from time to time.
9.1.6 Resulting Corrective Actions Implemented
International Paper instituted the following actions to prevent
further V-Brite accidents:
1) completely enclosed and weatherized buildings where V-Brite
is stored and used;
2) constructed two buildings: one for storage and one for
dispensing the material;
3) provided personnel further training in emergency procedures
and general handling of V-Brite, including the use of
personal protection equipment;
4) began actively enforcing the policy concerning transport of
V-Brite during wet weather; and
5) started conducting field training exercises.
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9 • 1 • 7 Recommendations
The Audit Team concluded that IP’s efforts to contain the release
were adequate but that additional precautionary measures should
be implemented to prevent future releases. These include:
1) Activate a thermocouple in the unload system to detect a
reaction and an emergency condition.
2) Monitor the temperature and humidity in unload room.
3) Exhaust to a dilution stack or scrubber rather than to work
and travel areas.
4) Upgrade accident investigation and follow-up procedures.
5) Implement regular field simulations, with community
participation.
6) Finalize, certify, implement, and test contingency plans.
Items 4-6 apply to all emergency situations. The V-Brite
accident is the first example of IP’s failure to implement
satisfactory prevention measures.
9 • 2 ANIIYDROUS AMMONIA - 11/6/87
At 1430 hrs. on the above date, 3,700 lbs. of 100% anhydrous
ammonia were released from a storage tank at IP’s waste treatment
plant area; the release lasted approximately ten minutes.
9.2.1 Chemical Description - Anhydrous Ammonia
Anhydrous ammonia is a colorless gas with a very pungent odor.
Inhalation of concentrated vapor causes edema of respiratory
tract, spasm of the glottis, and asphyxia. Treatment must be
prompt to prevent death. See Section 6.1.
9.2.2 Event Description
Due to operator error (the lock-out tag-out procedures were not
properly followed because the tag was removed prematurely after
loading), 3,700 lbs. of anhydrous ammonia were inadvertently
discharged from a fill pipe in the nutrient feed line. The
operator of the fill pipe inhaled ammonia gas and immediately
fled the area. Persons who might have been affected by the spill
were evacuated. The operator was examined by company health
officials and released. Within several minutes, the mill’s
maintenance pipers, after donning SCBA’s, closed the unloading
valve, thereby stopping the leak.
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At the time of the release, the wind direction was northerly at
20 m.p.h. The humidity was 30%, and the temperature was 25°F.
There was no precipitation.
The ammonia rapidly volatilized, aided by the wind. Because it
volatilized rapidly, IP believes that it is unlikely that any
significant amount migrated from the facility. Other than the
exposures to the operator, no other ill health effects are known.
Because the spill posed no significant health risks after it
volatilized, no further precautions were contemplated by IP.
9 • 2 • 3 Notification
In the late afternoon on the day of the release, IP environmental
officials notified the National Response Center (which in turn
notified the U.S. EPA, Region I) and the ME DEP Bureau of
Hazardous Materials Control. International Paper attempted to
notify the Jay Town Manager who was not available at the time.
On 11/9/87, three days after the incident occurred, the Jay Town
Manager was made aware of the incident. As a result, IP and the
Town of Jay have instituted measures whereby town officials can
be reached 24 hours a day. This incident is an example of a
communication breakdown in the IP notification procedures
9.2.4 Release Prevention Practices
International Paper reinforced company policy to:
1) require all persons handling ammonia to wear masks;
2) place tags on valves stating whether the valves are open or
shut;
3) inspect lines before opening;
4) make available ammonia detection tubes; and
5) review procedures for isolating and purging systems with
employees.
Additionally, all personnel working in and around the ammonia
tank have undertaken hazardous chemical awareness training.
9.2.5 Resulting Corrective Actions Implemented
No operational or mechanical changes were instituted as a result
of this incident. The Audit Team determined that IP had not
properly investigated this accident and was not knowledgeable
about piping and unload procedures at the ammonia unloading
station. Once again, IP effectively terminated the release but
failed to initiate long—term prevention measures.
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9 • 2 • 6 Recommendations
Had proper lock—out procedure been followed, this ammonia release
would not have occurred. In addition, the Team believes that
mechanical changes are needed to prevent further occurrences.
Recommended changes include:
o improve supervision during unloading;
o develop, implement, and follow a written unloading
procedure;
o thoroughly familiarize all related personnel with
ammonia handling procedures;
o determine if the process line should be separated from
unload line;
o install backf low check valve in inlet line;
o color code and label all valves;
o have proper extinguishing material readily available; and
o determine if a vacuum break should be installed to prevent
suck back.
The Audit Team found the ammonia unload operation to be poorly
operated and proper maintenance procedures were not followed.
9.3 CHLORINE/CHLORINE DIOXIDE - 2/5/88
At exactly 1107 hrs. on February 5, 1988, a release of 112,000
gallons of chlorine and chlorine dioxide (0.6% solution in water)
occurred at the IP facility. Below is a detailed description of
the incident, which was by far the most potentially destructive
of the three major releases.
9.3.1 Chemical Description - Chlorine
Chlorine is a greenish-yellow diatomic gas with a suffocating
odor. It is dangerous to inhale and is a powerful irritant. Can
cause fatal pulmonary edema. See Section 6.2.
9.3.2 Chemical Description - Chlorine Dioxide
Chlorine dioxide is a strongly oxidizing, green gas, at room
temperature. Its odor is unpleasant and similar to that of
chlorine and reminiscent of that of nitric acid. It may be
highly irritating to skin and mucous membranes of the respiratory
tract. It may cause pulmonary edema. See Section 6.3.
9.3.3 Event Description
The above-mentioned chlorine/chlorine dioxide leak began at 1107
hrs. on 2/5/88 and was contained by 1500 hrs. on the same day.
The wind was moving in a northwesterly direction at 15 m.p.h.,
the humidity was 25%, the temperature was 15°F, and there was no
precipitation.
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Workers cutting and removing an unrelated pipe overhead
accidentally dropped it and severed a four-inch diameter by 36”
FR? drain nozzle, valved at the discharge end, from which the
liquid immediately began escaping. A vapor cloud formed and
began dispersing arid traveling downwind. It was observed by a
Jay police officer stationed at an IP gate, who notified town
responders of the incident. The leak was eventually secured by
inserting a bladder into the broken pipe, inflating it, and
terminating the flow.
Following the accident, there was an evacuation of mill workers
to the office area. An evacuation of approximately 4,000 area
residents, including school children, commenced. Officials
monitored downwind of the site, at the Jay Town Center, and at
the perimeter of the mill; no readings were detected. However,
the detection and sampling methods were not sophisticated or
highly accurate. Officials cordoned off the mill area, allowing
no one to enter or exit until the tank had been completely
emptied. This occurred at 1500 hrs. Most of the product was
diverted to the waste treatment plant via the sewer system and
was not volatilized to the atmosphere.
9 • 3 • 4 Notification
Shortly following the accident, IP authorities notified the
following Federal, State, and local agencies:
o National Response Center, which then alerted the U.S. EPA,
Region I;
o ME DEP (Bureau of Oil and Hazardous Materials Control and
the Air Bureau), which then contacted the Maine Emergency
Management Agency (MEMA), the Maine State Police, and the
Governor’ s office;
o Town of Jay Fire and Police departments, and;
o the Jay Town Manager.
9.3.5 Release Prevention Practices
Because this incident occurred due to error of maintenance
personnel, IP stated that it was to a large extent unavoidable
and points out that their hazardous materials training was
adequate to prevent large—scale consequences.
9.3.6 Resulting Corrective Actions Implemented
International Paper began a program to identify the potential
for other accidents of this type, removed the drain line on the
tank, and installed protective shields around similar valves.
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9,3 • 7 Recommendations
Based on the serious nature of this event and our field
observations, the Audit Team determined that IP failed to
properly evaluate and implement the best corrective and
preventative measures,
At a minimum, IP should consider the following:
1) A total redesign of storage tank configuration and
construction.
2) An upgrade of the product transfer systems and pumps to
create a more efficient, less complex and safer system.
3) A bermed area around the sewer to prevent overflow and
spreading of the material and allow time for implementation
of control measures,
4) Dump valve as close as possible to the tank, blind flanged,
discharge to an acidic sewer, and then a neutralizing area.
5) An emergency retention area where the dO 2 could be treated
with an appropriate neutralizing agent.
6) Increased training for maintenance personnel.
7) An upgrade of post—accident corrective measures to assure
fail-safe operations.
The Audit Team believes that IP’s solution to the incident did
not address long—term prevention requirements. Eliminating the
valve may not have solved the problem. International Paper
should investigate a complete system modification which would
include tank capacity and outage, materials, transfer, and
safety.
9.4 NON-NOTIFICATION RELEASE INCIDENTS
International Paper authorities were required by law to notify
Federal, State, and local agencies of the above—mentioned
releases because they all exceed the Federally—mandated
Reportable Quantities for the specific materials involved. Below
is a brief discussion of additional releases which have occurred
in the past two years but were not extensively discussed during
the Audit because they had minimal environmental and community
impact.
9.4.1 Sodium Hydrosulfite — 4/13/87
A Virginia Chemical truck backed into the receiving area to
deliver nine 1—ton tote bins. Fumes were detected when the
trailer door was opened, and it was reported by an employee to
the Safety Department. An in—house trained tester for chemical
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gases (“sniffer”) responded, arid a Material Safety Data Sheet
(MSDS) was obtained. After checking for gas concentrations and
researching the MSDS information, the leaky container was
transported to the waste treatment facility for disposal. The
remaining shipment was forwarded to its designated storage area.
No injuries occurred.
9.4.2 Chlorine — 5/5/87 and 5/6/87
On the night of May 4, the pulp mill shut down for a total mill
outage. At 1130 hrs. on May 5, liquid chlorine began to leak at
flanges on top of the east and middle vaporizers. The pulp mill
area was evacuated by personnel donned in protective gear as the
alarms could not be sounded due to the power outage. The leak
was isolated by closing the valve at the chlorine tank car. At
1130 hrs. on May 6, when the system was turned on, the chlorine
expanded as it heated, rupturing the line to the hypo barometric
loop. The area was again evacuated, utilizing the alarm system.
Eight injuries were reported.
9.4.3 Chlorine — 5/22/87
International Paper reported to Federal and State officials that
a corroded line caused a one—gallon release of chlorine. The
building was evacuated, and one injury was reported.
9.4.4 Sodium Hydrosulfite - 11/14/87
For unknown reasons (possibly due to reaction with moisture), V—
Brite began smoldering in a tote bin. The vessel was removed to
an isolated area of the mill and hosed down with water. The
immediate area was evacuated, although sulfur dioxide was not
present in measurable levels. No injuries were reported.
9.4.5 Hydrogen Sulfide — 1/28/88
A local television station reported a leak of an unknown quantity
of hydrogen sulfide to the ME DEP and the EPA. The release
occurred because acid slurry overflowed into a dissolving tank,
reacting with black liquor to create hydrogen sulfide gas. Once
the problem was detected from the control room, the dissolving
tank was emptied. Quench was added to the generator tank to
prevent an adverse reaction, and materials from the generator
tank were emptied into a dump tank. Eight contractor personnel
were treated at the local hospital for hydrogen sulfide exposure.
9.4.6 Chlorine — 2/14/88
A 5-10 gallon discharge of chlorine was reported to the ME DEP
and the EPA by an IP representative. The interlock system
designed to shut off the chlorine flow to the pulp flow from the
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primary mixer failed, allowing chlorine to flow back through the
pulp and exit into the work area through a pulp sampling line
over the primary mixer. Seven injuries were reported.
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SECTION TEN
Emergency Release Exercise
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10.0 EMERGENCY RELEASE EXERCISE
At the request of the Audit Team, an Emergency Drill was
conducted on 4/25/88 in the pulp mill. The drill consisted of
simulating a chlorine release, causing activation of the alarm
system and evacuation of the mill. A Sweep Team, donned in self-
contained breathing apparatus (SCBA), proceeded through the
building searching for remaining personnel after the evacuation
and then terminated the “leak.” Art “All Clear” notice was
announced, and personnel returned to the Mill.
10 • 1 OBSERVATIONS:
o The commander did not have adequate control of the
evacuation and spill termination procedures.
O The communication was poor between the Sweep Team, the
control room, and the release area. Because the Sweep Team
was outfitted in SCBAs, they were unable to communicate via
telephone. Also, high noise levels throughout the mill made
communication even more difficult.
o The message over the public address system could not be
heard in all areas. In other areas, it was heard but could
not be understood.
o The Sweep Team was not thorough and did not inspect all mill
areas for remaining employees.
o Some evacuees exited the area without donning respirators.
o Employees were not accounted for after evacuation.
o The Sweep Team served as an Emergency Response Team,
although they were not qualified as such.
o Some warning beacons malfunctioned.
o The Sweep Team did not don personal protective clothing.
o “All Clear” was sounded without sufficient evidence and
monitoring.
10 • 2 RECOMMENDATIONS
o The pulp mill should have more drills, and further analysis
of the drills should take place. These exercises should be
integrated with the community.
o The public address system should be extended to include all
vulnerable areas. Additionally, visible beacons should be
used to alert personnel in high noise level areas.
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o Masks with radio communication ability should be utilized by
the Sweep Team in order to keep in contact with the control
room and the spill area.
o One designated person per shift should be in charge of
emergency situations.
o The Sweep Team should don Level A protective clothing. This
would protect the Team, allow them to evacuate the building,
and possibly terminate a spill without damage to themselves.
o The Sweep Team should be given emergency response training.
o The mill should involve the Jay Fire Department and
community responders and planners in annual drills and
simulations.
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SECTION ELEVEN
Air Dispersion Modeling
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11.0 AIR DISPERSION MODELING
Included in this chapter are air dispersion estimates for the
three major air releases which occurred at IP’s facility. In
addition, there are several air dispersion estimates for credible
worst case scenarios included. A description of the conditions
and assumptions are included before each estimate.
Two different air dispersion models were utilized. One model was
used to estimate concentrations of air pollutants from continuous
emissions. These models are based on a binomial continuous plume
dispersion equation providing an estimate of ground—level
pollutant concentrations. The models are pre—screening models
used to estimate concentrations and determine if sophisticated
modeling is necessary. The overall results are not accurate
representations of actual concentrations and gross overestimates
are likely.
The model is based on the following assumptions:
o Continuous emissions from the source or emission is equal to
or greater than travel times to the downwind position under
consideration so that diffusion in the direction of
transport may be neglected.
o The material diffused is a stable gas or aerosol (less than
20 microns diameter) which remains suspended in the air over
long periods of time.
o None of the material emitted is removed from the plume as it
moves downwind, and there is complete reflection at the
ground.
o The mean wind direction specifies the x—axis, and a mean
wind speed is representative of the diffusing layer chosen.
o The plume constituents are distributed normally in both the
crosswind and vertical directions.
o The dispersion parameters represent sampling periods of
about ten minutes. Thus, the parameters are conservative
for releases significantly greater than ten minutes and may
underestimate dispersion at sampling times less than ten
minutes.
The second model was used to estimate concentrations of air
pollutants from instantaneous puff air releases. This model is
based on Gaussian equations. An instantaneous air release is
defined as a short—term release on the order of seconds, such as
in an explosion or a release from a process vent. The model is
based on the following assumptions: the atmosphere is at a
steady state; and pollutants are neutrally buoyant and non-
reactive. This model is also used for pre—screening evaluations.
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When reviewing the following air dispersion models, the scale
should be closely observed. Due to the limits of the paper’s
dimensions, it was necessary to change the scales for different
models. Also, for the instantaneous puff release models, it
should be noted that the contours are not a plume. It is
important to realize that each specific time and corresponding
travel distance on the plot depict the cross-section through the
center of the plume at that time.
Three different plots are used for each model. One plot displays
numbers from one through five, corresponding to the lowest and
highest concentrations in the plume. The last two models display
asterisks (*) over the area where the plume concentration exceeds
a specified value.
In this report, Threshold Limit Values (TLVs) and Immediately
Dangerous to Life and Health (IDLH) values were specified.
Threshold Limit Values refer to airborne concentrations of
substances and represent conditions under which it is believed
that nearly all workers may be repeatedly exposed day after day
without adverse effect. These values are established by the
American Conference of Governmental Industrial Hygienists
(ACGIH). Immediately Dangerous to Life and Health values,
defined by the Standards Completion Program, represent a maximum
concentration from which, in the event of respirator failure, one
could escape within 30 minutes without experiencing any escape-
impairing or irreversible health effects. The effects of the
various chemicals can be seen in Chapter 6 of this report.
It should be remembered that these models are estimates and are
far from exact. Also, for the credible worst case scenarios, the
models display the downwind concentration. The probability of
such a release occurring is not included as part of this report
and should be taken into consideration when judging the effects
of a release. To judge the downwind effects, the parameters
described in Section 1.2 (Site Description) should be considered.
11.1 RELEASE OP SULPUR DIOXIDE AT A SODIUM HYDROSULPITE FIRE ON
4/18/87
On April 18, 1987, at 0700 hrs., a fire started in a sodium
hydrosulfite storage area after moisture came in contact with the
sodium hydrosulfite. As a result, sulfur dioxide was released.
The release was stopped at 1300 hrs. and, as a result,
approximately 100 pounds of sulfur dioxide were released to the
atmosphere. The wind was coming from the southwest at 4 miles
per hour, the temperature was 42 0 F, and no precipitation
occurred.
The TLV for sulfur dioxide is 2 ppm and the IDLH is 100 ppm. The
two computer models in Appendix II show significant airborne
concentrations of sulfur dioxide occur within ten feet of the
fire. The TLV level is exceeded 100 feet downwind of the fire.
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11.2 RELEASE FROM AIIHYDROUS AMMONIA STORAGE TASK ON 11/6/87
On November 6, 1987, at 1430 hrs., anhydrous ammonia began
exiting an unloading line from a storage tank. The valve was
mistakenly left open and was shut at 14:40 hours. During that
time, 3,700 pounds of anhydrous ammonia were released to the
atmosphere. The wind was coming from the north at 20 miles per
hour, the temperature was 25°F, and there was no precipitation.
The TLV for inmonia is 25 ppm and the IDLH is 500 ppm.
The two computer models in Appendix III show the following:
significant concentrations occur over one mile downwind; the TLV
level is exceeded over one mile downwind; and the IDLH level is
exceeded 900 feet downwind of the source.
When reviewing these models, it should be noted that ammonia has
a vapor density of 0.6 and would have a tendency to rise in the
atmosphere. Since the release occurred at an elevated area, the
ground level concentrations for these models have a much greater
probability for error.
11.3 RELEASE FROM CHLORINE DIOXIDE STORAGE TANK ON 2/5/88
On February 5, 1988, at 11:07 hrs., a fiberglass drain valve to a
storage tank of chlorine dioxide in solution was accidentally
severed by a falling pipe. The release was stopped at 13:00 hrs.
on the same day by inserting an inflatable bladder into the
broken pipe. During that time, 123,799 gallons of solution were
released at a rate of 1,032 gallons per minute. The quantity
released was 70% of the tank’s total capacity. The solution
flowed approximately 30 feet to a drain in the ground which led
to the facility’s wastewater treatment plant. The concentrations
of chlorine dioxide and chlorine in the solution were 5.4 grams
per liter and 1.9 grams per liter, respectively. The total
quantity of chlorine dioxide and chlorine released was 5,579
pounds and 1,962 pounds, respectively. The exact amount of
material released to the atmosphere as a gas is unknown. The
company estimates it to be 440 pounds of chlorine dioxide and 156
pounds of chlorine. Air dispersion models were developed using
these estimates. Also, air dispersion models were developed
using the assumption that 80% of the material was released to the
atmosphere. This is a high estimate given the situation, but is
done so because the exact amount released to the atmosphere can
never be known. This estimate results in 4,463 pounds of
chlorine dioxide and 1,570 pounds of chlorine released to the
atmosphere. The wind was coming from the northwest at 15 miles
per hour, the temperature was 15°F, and there was no
precipitation.
The first two sets of modelE in Appendix IV refer to those
quantities released to the atmosphere that were estimated by I?.
The TLV5 for chlorine dioxide and chlorine are 0.1 ppm and 1 ppm,
respectively. The IDLH values for chlorine dioxide and chlorine
are 10 ppm and 30 ppm, respectively.
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As can be seen in the first two sets of models in Appendix IV,
significant concentrations of chlorine dioxide occur over one—
half mile downwind of the source. The IDLH level is exceeded at
250 feet from the source, and the TLV level is exceeded
approximately one mile downwind. The concentrations of chlorine
are much smaller than those of the chlorine dioxide. While the
TLV level is exceeded at 650 feet downwind, the IDLH level is
limited to within 45 feet of the source.
The second two sets of models also in Appendix IV were based on
the estimate that 80% of the material was released to the
atmosphere. As can be seen, high concentrations of chlorine
dioxide occur beyond one—half mile downwind of the source. The
IDLH level is exceeded one-quarter mile away, and the TLV level
is exceeded over 4 miles downwind. Once again, the
concentrations of chlorine in the atmosphere are not as
significant as those of chlorine dioxide; however, they are still
higher than should be allowed one-quarter of a mile downwind.
The IDLH level was not exceeded beyond 300 feet downwind.
11.4 CREDIBLE WORST CASE SCENARIO FOR THE CHLORINE DIOXIDE
STORAGE ThNK
The two sets of models in Appendix V are air dispersion models
for a potential release from the chlorine dioxide storage tank
from which a release occurred on 2/5/88. Since the chlorine
dioxide and chlorine are in solution, an instantaneous release is
improbable, so a continuous model was used with the assumption
that all of the gases were released to the atmosphere within one—
half hour. Also, it is assumed that the solution is exposed to
the atmosphere for at least one-half hour. Although there is a
drainage system surrounding the tank, it is assumed that a major
rupture in the tank would produce a sufficient flow so that the
drainage system could not contain the release.
Since this scenario is to approximate a worst case, the total
capacity of the tank (176,856 gallons) is used. This results in
the release of 7,970 pounds of chlorine dioxide and 2,804 pounds
of chlorine. The wind speed was chosen as 15 miles per hour.
This also was the wind speed on the 2/5/88 release and would have
a greater downwind effect than a lesser speed. The temperature
was chosen as 77°F to assist in the evaporation and warming of
the solution. The atmospheric mixing height used is a default of
5,000 feet.
The first set of models in Appendix V display the chlorine
dioxide concentrations in the atmosphere. Immediately Dangerous
to Life and Health atmospheres would occur over three—quarters of
a mile away. The TLV level would be exceeded as far away as 18
miles downwind. While the levels of chlorine in the atmosphere
are not as significant as those of the chlorine dioxide, they are
still dangerous levels. The TLV level is exceeded over one and
three—quarter miles away, and the IDLH level is exceeded one-
fifth of a mile downwind of the source.
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11.5 CREDIBLE WORST CASE SCENARIO FOR THE ANHYDROUB AMMONIA
STORAGE TANK
The set of models in Appendix VI are air dispersion models for a
potential release from the anhydrous ammonia storage tank from
which a release occurred on 11/6/87. For this scenario, it is
assumed that the entire contents of the tank are released at
once. This would occur if the tank were to collapse, a major
rupture in the tank occurred, or there was an explosion near the
tank. It is assumed that if the structure containing the tank is
not destroyed, its ventilation would allow for the rapid escape
of the gas. The instantaneous puff release model is used. The
storage tank has a 12,000-gallon capacity, which would result in
a potential release of 68,112 pounds of anhydrous ammonia.
Weather conditions are assumed to be the same as the previous
model. It should be noted that the vapor density of arthydrous
ammonia is 0.6 and it would have a tendency to rise in the
atmosphere. This model does not account for the density of the
gas.
The first model in Appendix VI depicts the locations where the
concentration will exceed the TLV level. As can be seen in a
little over an hour and a half, the TLV level will have been
exceeded 23 miles downwind. The second model displays those
areas where the IDLH level will be exceeded. Within one-half
hour, the IDLH concentration will have reached over six and one—
half miles downwind of the source. The last two models display
the concentrations of ammonia in the atmosphere with time one
mile and six miles downwind of the source. As can be seen, the
further downwind the plume is located, the greater it will be
dispersed. Thus, the concentrations will be lower but the
duration over a distinct point will occur longer.
11.6 CREDIBLE WORST CASE SCENARIO FOR A CHLORINE RAIL CAR
The models in Appendix VII are air dispersion models for a
potential release from a chlorine rail car. Currently, there are
four rail cars kept on site at one time. Only one car is emptied
at a time. These dispersion models depict the release from one
90—ton rail car. Weather conditions are the same as in the
previous models.
The first set of models displays a continuous release in which
the entire contents of the car are released in one hour. This
would result from a release of 255 gallons per minute, such as a
broken pipe or valve. As can be seen from the first plot, high
concentrations of chlorine will occur as far as seven miles away.
The TLV level would be exceeded 19 miles downwind of the source,
and the IDLH level would be exceeded almost two miles downwind of
the qource.
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The second and third sets of models are instantaneous puff
release models. In this type of scenario, the entire contents of
the rail car would be released at once. This would result from
an explosion or a major rupture of the rail car. The first set
of plots assumes the same weather conditions as used previously.
The second set of plots assumes more stable weather conditions
and a wind speed of only one mile per hour.
In the second set of models, the IDLH level is exceeded 18 miles
downwind, but the duration over each distinct location is short.
In the third set, where there are more stable conditions, the
IDLH level is exceeded only five miles downwind but the duration
is much longer. Thus, under the more stable weather conditions
fewer people would be affected but much more seriously. In each
set of plots is included a display of the ambient concentrations
with time one-half mile downwind, one mile downwind, and at the
downwind edge of the IDLH plot for comparative purposes.
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SECTION TWELVE
Summary of Observations
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12.0 SUMMARY OP OBSERVATIONS
A summary of the Audit Team’s observations throughout the Mill
are included here, with recommendations for possible improvements
contained in the following, concluding chapter.
12.1 PULP MILL/BLEACH PLANT
1) A Kraft Pulp Mill Entrance Permit program was begun in
February or March for all employees, contractors, and
visitors to the pulp mill. The effectiveness of this
program is unknown at this time because of its recent
implementation. Mechanisms for enforcement did not appear
to be in place and safety rules, procedures, and routes of
escape were unclear.
2) The digesters and boilers are cleaned once a year and every
three years with a hydrochloric acid/nitric acid wash. The
boilers are cleaned once a year and every four years with a
nitric acid wash.
3) Air pollution control equipment for chlorine and chlorine
dioxide does not appear to be adequate to control emissions.
4) During certain times, such as startup and shutdown, chilled
water is substituted for 35 Filtrate (a caustic), resulting
in inadequate gas scrubbing for routine or accidental
releases in the chlorine and chlorine dioxide scrubbers.
Plugging, gas channeling, and maintenance problems are
likely to occur due to fiber buildup from 35 Filtrate.
5) No efficiency or stack testing was conducted to assure that
gas is not emitted to the environment under routine or
accidental loads. No limiting operating parameters have
been established. No monitoring devices have been installed
to assure proper operation or that the control systems are
in operation.
6) Housekeeping in this area was generally satisfactory,
although excessive amounts of weak black liquor were
observed encircling the B Plant chlorine dioxide storage
tank. Excess liquid could potentially float the tank,
resulting in catastrophic consequences.
7) One primary chlorine dioxide scrubber is not operating, and
system leaks in the fan and duct work were apparent.
Excessive moisture and condensate are leaking from the
system. Additionally, excessive bypass input lines were
noted.
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12.2 POWER PLANT
The Power Plant has recently instituted a Utilities Entrance
Program whereby all employees, contractors, and other visitors to
the plant must have on file a Utilities Entrance Permit before
being allowed entrance to the premises. It was difficult to
gauge the effectiveness of this program as it was implemented
less than a month prior to the Audit.
1) No leak detection procedure is used during installation of
hydrogen gas cylinders.
2) There do not appear to be sufficient mechanisms in place for
contingencies in the event of an emergency power failure.
The Audit Team is not convinced that all necessary emergency
warning, lighting, and critical valves and equipment are
adequately protected.
12.3 SAPETY
1) The Safety Department is headed by a certified Safety
Engineer. The Safety Department Manager reports to the
Human Resources Manager.
2) There is one Industrial Hygienist who is in the process of
becoming certified. The facility is visited semi-annually
by a team of six Industrial Hygienists of whom one is
certified.
3) Safety issues are routinely discussed at a daily staff
meeting attended by department managers. At the meetings,
new safety programs are developed and existing ones are
assessed for their effectiveness and, if necessary,
redesigned.
4) Safety training, under the guidance of a staff member
appointed as Safety Trainer, is a newly-instituted program
that has yet to be fully integrated into Mill operations.
5) A 17-week Safety course is offered, during non-working
hours, for supervisory, management, and hourly personnel.
12 • 4 ALARMS/MONITORING
1) The areas of the mill where a chemical release might occur
do not have established criteria for general sounding of
chlorine, chlorine dioxide, and hydrogen sulfide alarms.
Currently, hydrogen sulfide is detected by an automatic
alarm; however, chlorine and chlorine dioxide alarms are
sounded manually by control room staff. As such, sounding
of the alarms is discretionary.
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2) The emergency alarm lighting system has recently been
revised. The flashing of yellow lights indicates that a
toxic gas has been released, and a red light is operated
during evacuation.
3) Because ammonia has very strong warning properties, no
monitoring system is in place for its detection.
12.5 EQUIPMENT DESIGN
1) The facility appears to be undergoing a major reconstruction
phase. Changes are planned in piping, chemical storage, and
in actual processes. It is very important that these
changes are addressed in all contingency plans and response
procedures and that proper personnel, such as the local Fire
Chief and Fire Brigade, be notified. Should an accident
occur, the substance in question may be misidentified.
Mitigation procedures previously used may no longer be valid
if a key valve or drain has been removed or changed.
2) When design changes costing $75,000 or more are needed,
corporate engineering approval is required. A design change
is initially initiated via a work order by a department
foreman or supervisor. Less expensive changes, even those
associated with hazardous substances, are sometimes given
cursory reviews.
12.6 COMMUNICATION
Throughout the facility, there appears to be a lack of
communication and awareness of procedures between the various
departments and with the community. Although it is under-
standable that this situation may be present due to the change in
personnel and labor problems, it is a general feeling by the
Audit Team that considerable improvement is needed in this area.
12 • 7 HAZMAT TEAM
1) At the time of the Audit, a Hazmat Team was being formed.
However, it is not expected to be operational for several
months. Implementation of this important program is past
due.
2) Training for the Hazmat Team has yet to be fully developed,
although it is in the planning stages.
3) The IP Fire Brigade and Jay Fire Department have very little
hazmat expertise. The functional relationship and
efficiency between the Brigade and the Town needs
improvement.
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12.8 FIRE BRIGADE
The IP Fire Brigade is composed of three full-time employees (a
fire inspector and two assistants) and a maintenance back shift
(7 or 8 employees) for each of the four shifts. Observations
about IP’s internal firefighting capabilities are as follows:
1) Equipment maintenance and inspections are routinely
performed; however, it was learned that the foam stored on
site was beyond its shelf life.
2) Much of the firefighting equipment and supplies are old,
although two new puinpers and protective clothing are on
order.
3) Neither the Jay Fire Chief nor the IP Fire Brigade Chief
conduct regularly—scheduled inspections of the mill.
4) Communication between first responders and the Mill Brigade
is poor.
5) Fire drills are conducted on a regular basis, although it is
unclear whether or not records are kept. The community has
not been involved in these drills.
6) The facility’s Fire Brigade equipment is stored in a fire
barn near a gas cylinder storage area. The company also has
intentions of storing their hazardous materials unit at this
location. In the event of a leaking gas cylinder or
explosion, the equipment to mitigate the hazards would be
destroyed or inaccessible. Either of these events are
possible since both hydrogen and hydrogen sulfide are stored
here.
In addition, there is a railroad line which goes by this area.
Although this rail is used mainly for non-hazardous materials,
such as clay, on occasion hazardous material rail cars are
located here during switching operations. Should an accidental
release occur during such a transfer, the necessary equipment to
mitigate the release would be inaccessible. Although IP has
stated its intentions of transferring the fire barn to a new
location, this observation is brought forth so that the same
situation will not be overlooked when choosing a new location.
12 • 9 HAZARD COMMUNICATIONS PROGRAM
OSHA requires all employers who manufacture, distribute, import,
or use hazardous chemicals to implement a Hazard Communications
Program to inform e ”iployees of the dangers of the chemicals they
are handling.
1) At IP, all new employees receive a 4—hour course which
encompasses: hazardous chemical inventory; container
46
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labels/warnings; Material Safety Data Sheets (MSDS); and
chemical exposure control.
2) An abbreviated Hazard Communications course, which consisted
primarily of a videotape, was provided to the Audit Team.
The program appears to be well organized and informative.
3) Outside contractors must also be trained in hazardous
materials handling and are presented an abbreviated version
of the Hazard Communications course before entering the
facility.
This program is currently being reviewed by OSHA.
12.10 RESPIRATORY PROTECTION
1) All employees, contractors, and visitors to areas where
chlorine and chlorine dioxide are handled must carry a 5-
minute escape pack, and be familiar with its use, in the
event of a release. All mill operators, and some
maintenance personnel, have been trained in the use of Scott
Air Packs (SCBA5).
2) There are no formal procedures for decontamination of
personal protective equipment, although employees are
expected to care for all equipment they use. Additionally,
employees are requested to replace the cartridges on their
face masks weekly.
3) Scott Air Packs are inspected by certified fire inspectors.
However, tags on the SCBA cases indicate that they had been
inspected only once at the time of the Audit.
4) Documentation that the Fit Testing program is being properly
implemented was unavailable for review by the audit team.
12.11 CHEMICAL HANDLING
The supervision provided to employees and vendors handling and
delivering chemicals was found to be inadequate.
12.12 AIR MODELING
1) In 1985, IP developed an air model-—utilizing flat terrain
technology—-which was incorporated into a field simulation.
However, there is no evidence that modeling was ever used
f3r impact analysis. The community hazards impact analysis
at IP is insufficient.
2) Air dispersion estimates have been included in this report.
The appropriateness of the models used are not sufficient
for the impact studies that are necessary for proper
47
-------
planning. The results show that more sophisticated modeling
is required.
12 • 13 RELEASE MANAGEMENT
Because the mill is located adjacent to the Androscoggin River,
there is a risk of hazardous chemicals entering the river (which
is a navigable waterway of the U.S. and therefore under Federal
jurisdiction) in the event of a liquid release. IP has made
provisions to prevent this from occurring. The audit team did
not assess the adequacy of these provisions.
12.14 COMMUNITY RELATIONS
Although a paging system has recently been activated between IP
and community responders, there remain many communication
problems that need to be resolved.
12.15 HAZARDOUS WASTE
International Paper is a RCRA waste generator. Hazardous wastes
are stored in aboveground containers and shipped to RCRA-approved
facilities. The Team collected numerous complaints from previous
employees alleging past illegal hazardous waste disposal in
landfills owned by IP. There is a need to investigate existing
landfill sites to determine if any waste was improperly dumped.
48
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SECTION ThIRTEEN
Reconunendations
-------
13 • 0 RECOMMENDATIONS
13.1 ACCIDENT INVESTIGATIONS AND FOLLOW UP
Accident investigation procedures are inadequate. International
Paper does not adequately investigate potential and actual
chemical releases using checklists, codes, standards, or formal
techniques. Their existing accident investigation techniques
fail to adequately assess system reliability, state-of-the-art
technology, and the magnitude and probability of the accident
reoccurring. Appropriate investigation and follow up was not
initiated for major releases that involved significant worker
safety issues and major community impact. The documentation of
several accidents which occurred at the mill over the past two
years was incomplete.
Accident investigation techniques at IP must be improved to
reassure the public that appropriate changes to defective
equipment, training, and policy are implemented and that long-
term safety considerations are paramount in the accident
investigation process.
13 • 2 CHLORINE DIOXIDE STORAGE AND TRANSFER DESIGN CHANGES
On February 5, 1988, IP released approximately 100,000 gallons of
chlorine dioxide from a storage tank over a two—hour period. The
release occurred when maintenance workers cut an overhead steel
support without having first properly secured their work area.
This caused the pipe to fall and sheer an FRP dump nozzle on a
158,616-gallon chlorine dioxide storage tank. The gas plume
reportedly migrated beyond property lines within minutes after
the release. Chlorine dioxide is a highly unstable, toxic health
hazard which can spontaneously, and under certain conditions,
react explosively with air. See Section 9.3.3 for further
details.
The long—term prevention technique used by IP was to permanently
block of f the broken valve. International Paper failed to
provide adequate assurance that the chlorine dioxide storage and
transfer system is likely to continue operating in a failsafe
mode. The mill did not determine how the valve removal impacted
overall system safety. This important design change was
completed without the necessary hazard assessment. The changed
design does not allow for efficient product transfer in the event
of a process upset or emergency.
It is necessary that IP reevaluate the chosen prevention strategy
and determine the need to implement further failsafe design to
the chlorine dioxide storage and transfer operation. The study
and design changes should, at a minimum, consider the following:
o smaller tanks with more total capacity for emergency
pulidown and balance;
49
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o backup pumping capacity;
o close fit, protected valves, discharge blanked;
o dump procedures and secondary containment; and
o floating roof and vapor control.
13.3 AMMONIA STORAGE AND TRANSFER DESIGN CHANGES
On November 6, 1987, IP released 3,700 pounds of anyhydrous
ammonia in approximately ten minutes. Ammonia gas is flammable,
toxic, and can be explosive. It is considered an extremely
hazardous substance. The release was caused when personnel
failed to follow a proper lock—out tag—out procedure prior to
recommissioning the ammonia transfer system (see Section 9.2.2).
International Paper did not provide the Audit Team adequate
documentation to assure that reoccurrence of the event is not
likely. The arrangement of pipes and valves could not be
adequately explained by IP. Supervision of the unloading
operation, lock—out tag—out procedures, pipe and valve
identification, and safety equipment remained deficient at the
time of the audit.
International Paper must assess measures and implement design
changes to prevent a similar incident from occurring. The
assessment should, at a minimum, include the following:
o improved lock—out tag—out procedures;
o improved unload supervision;
o proper written unload procedures;
o process and load line separation;
o backflow check valve installation;
o labelling and color coding;
o overfill protection; and
o provisions for fire extinguishing.
13.4 V-BRITE HANDLING
On April 18, 1987, IP released approximately 100 pounds of sulfur
dioxide (so 2 ) over a six—hour period. This release occurred as a
result of a fire in a sodium hydrosulfite (V—Brite) tote bin
(see Section 9.1.3). V—Brite is used by the mill as a bleaching
agent. The product is relatively stable provided it does not
contact moisture. A small amount of water in the tote bin, along
with the presence of oxygen, can cause flammable and explosive
50
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decomposition and the release of SO 2 gas. Sulfur dioxide gas is
immediately dangerous to life and health at concentrations of 100
parts per million (ppm). Vapors may cause burns, dizziness, and
suffocation.
International Paper implemented major design changes to prevent
future V-Brite accidents. These included the weatherizing and
enclosing of the V-Brite storage and dispensing areas. However,
the mill failed to complete an acceptable safety review and final
certification for the new design.
International Paper must initiate a post-modification safety
review which should, at a minimum, address the need for the
following:
o activation of a reaction detector thermocouple in the bin
discharge system;
o temperature and humidity monitoring;
o relocation of the emergency exhaust vent (vent should not
exhaust into a traffic area);
o improvement of training programs and warnings for V—Brite
powder and SO 2 gas; and
o implementation of additional measures to keep the V-Brite
dry during transport from storage and dispensing areas.
13.5 CHLORINE AND CHLORINE DIOXIDE SCRUBBING SYSTEMS
Hazardous chlorine and chlorine dioxide gases from process and
upset conditions throughout the mill are scrubbed by a primary
and secondary packed, countercurrent spray tower. The units are
located in series, with primary and secondary units for both the
A and B plants. The scrubbing medium is caustic from the washer
35 Filtrate tank.
International Paper did not provide sufficient evidence to
demonstrate the effectiveness and efficiency of the scrubbers in
removing hazardous chlorine and chlorine dioxide emissions.
Operational deficiencies observed during the audit are listed
below:
o Water is substituted for washer 35 Filtrate on occasion
(e.g., during startup and shutdown), resulting in inadequate
gas scrubbing on routine and upset emissions.
o Plugging, gas channeling, and maintenance problems are
likely due to fiber buildup from the washer 35 Filtrate.
51
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o No stack emissions tests or efficiency test information was
available to certify acceptable gas emissions under normal
and accidental loads.
o No limiting operating parameters have been established as
set points for proper removal efficiency.
o No parameter monitoring gauges have been installed to assure
and record proper operation. The system should be equipped
with the proper instrumentation, for example, flow,
pressure, pH, oxidation reduction potential (ORP),
temperature, etc. A recorder should be available to monitor
off—specification parameters and bypass conditions.
o The A plant primary scrubber was not in operation during the
audit.
o Excessive moisture, condensate, and system leaks were
observed (e.g., from duct work).
o Numerous bypass lines were observed entering the system.
o The drain sections of the B plant primary and secondary
scrubbers were improperly vented to the atmosphere.
o The efficiency of the scrubbing medium needs improvement.
International Paper should carry out comprehensive scrubber
design evaluations and stack testing to determine the extent of
modifications or design changes necessary to assure that chlorine
and chlorine dioxide gas releases from the scrubber stacks are
within acceptable levels.
13 • 6 ENVIRONMENTAL COMPLIANCE
The Audit Team conducted a review of government files to
determine IP’s environmental compliance status. Results of this
review indicate that the mill is operating with air and water
licenses and permits that require revision and renewal. There
have been numerous wastewater violations and treatment plant
bypasses. Past environmental problems were identified,
including contaminated groundwater wells MW78 and BB and
hazardous waste storage and disposal problems. The Team
collected complaints from previous employees, alleging past
illegal hazardous waste disposal in landfills owned by IP .
These compliance issues should be pursued by multi—media
government enforcement teams. Enforcement of delegated programs
is the primary responsib&lity of the State of Maine. The EPA
provides enforcement assistance to the State upon request.
52
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13 • 7 HAZARDS ANALYSIS
Although initial steps have been taken to identify plant hazards,
the size, complexity, and off—site ramifications require more
sophisticated hazards analysis capabilities at IP. These
capabilities did not exist at the time of the audit. Improved
methods of analysis must be available for certain hazardous
material lines at the research and development stage and
conceptual and detailed design, as well as operational, phases.
Methods include checklists, independent safety audits, “what if”
analysis, failure modes, effects and criticality analysis, and
hazard and operability studies. For example, a comprehensive
hazards/risk analysis should be conducted prior to any
implementation of changes to the chlorine dioxide storage and
transfer lines.
13.8 DISPERSION MODELING
Dispersion modeling has not been conducted satisfactorily to
determine potential community impact from releases. This type of
analysis is necessary given EPA’s preliminary dispersion
calculations conducted in conjunction with the audit and the
nature of operations at IP. Properly selected and calibrated
modeling must be completed using accepted methods and techniques.
Release geometry, heavier—than—air gases, terrain and phase
change effects, and downwash should be considered.
13 • 9 FIRE BRIGADE AND HAZARDOUS MATERIALS RESPONSE
The Fire Brigade does not have the necessary expertise, training,
and equipment to effectively deal with hazardous chemical
releases. Although significant improvements have been
accomplished in these areas, IP must continue efforts to build
capabilities in accordance with an acceptable timetable. Mutual
Aid capabilities need improvement as well. Inspections and
drills must be conducted in conjunction with Mutual Aid
responders on a regularly—scheduled basis. Hazardous materials
controls, such as foam, are not available at the Brigade, and
more emphasis should be placed on personal protective equipment
and monitoring instrumentation for Brigade and Hazmat Team
members.
13.10 CONTINGENCY PLANS
Contingency plans are not sufficient to prepare the mill and the
community for a hazardous materials emergency. Although
significant advances have been accomplished by IP over the past
several months, the existing contingency plans must be completed,
coordinated, certified by company and community officials,
tested, and maintained.
53
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13.11 ALERT ND NOTIFICATION
Alert and notification procedures within the mill are deficient.
Procedures and equipment must be upgraded to ensure that
notification is provided to affected parties for all stages of
alerts. Deficiencies observed included failure of personnel to
hear signals and malfunctioning beacons. Additionally, critical
area alarms are manually actuated and subject to human error.
There are no set criteria for determining when the alarms should
be sounded.
Alert and notification for the community is inadequate. For
example, the community was not notified of an ammonia release
which occurred on 4/9/88. The community fire department is not
automatically placed on standby or even notified, depending upon
the release situation. Community relations, Mutual Aid
notification, and response need major improvements. Additional
observations and conclusions can be found in the FEMA report.
13 • 12 HAZARDOUS MATERIALS UNLOADING OPERATIONS
Hazardous materials unloading operations need improvement.
Surveillance, supervision, and security need upgrading. Leak
detection procedures should be routinely used for hydrogen gas
hookup in the power plant. Bulk chlorine derailers and valves
should be locked when not in use. The use of unload supervision,
escorts, written procedures, and checklists should be implemented
for dangerous unloading operations.
13.13 TRAINING
International Paper has been training their employees in on—the--
job safety for many years, but a formal, written training program
is still in the early stages of development. Some training
courses have not been completely developed, and employee training
records appear to be sporadic. A more complete written training
program and recordkeeping procedure should be provided to ensure
that all employees receive the required training.
Some of the training materials requested by the Audit Team were
not reviewed because they were not immediately available at the
time of the audit. These include employee training records,
course content lists, and refresher training information. The
information that was provided included: a general training
manual; a safety practices guide; the International Paper Safety
Policy Manual, the Pulp Mill Safety Manual; and other general
training documents.
13,14 DECONTAMINATION
No formal program for decontamination procedures or training was
in place at the time of the audit. It is recommended that IP
institute a comprehensive, mill-wide program, to include the
54
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following: planning, training, implementation, and establishment
of designated decontamination zones.
13.15 ACCOUETABILITY FOR CONTRACTORS
Training and safety must be improved for contractors and outside
visitors during both routine and emergency situations.
International Paper should assume more responsibility to protect
these groups and must enforce standards similar to those required
of IP personnel.
13.16 REACTIONS TO SIMULATED EMERGENCIES
The emergency drill conducted at the request of the Audit Team
identified deficiencies in the following areas: command and
coordination; communication; notification; and response.
Simulations involving community planners and responders are not
conducted. Regular drills are necessary to improve safety
implementation and coordination consistent with the provisions of
SARA Title III.
13.17 MONITORS AND ALARMS
The one chlorine monitor currently in operation in the pulp area
does not provide adequate monitoring coverage. International
Paper is presently installing sixteen sensors throughout the
area. However, they will all operate with the same central
alarm. This system will require testing and evaluation once
installation is complete. Area sensors should be activated
automatically rather than from the control room. International
Paper needs to develop a system for inspecting, maintaining, and
calibrating the detectors. A backup alarm or other provisions
should be considered to reduce the possibility of central alarm
failure. The expanded network installation schedule should be
“fast tracked” to provide increased release detection and safety.
13.18 EMERGENCY BACKUP POWER
Adequate provisions have not been made for emergency,
uninterruptible power on hazardous materials alarms, sensors, and
other emergency services. International Paper has significant
flexibility in obtaining power through three manually-switched
two—way busses. Wood, oil, and hydroelectric capabilities, as
well as the mill’s ability to purchase from the power grid, are
available. However, area power outages have caused water
treatment plant bypasses and chemical releases to the
environment. International Paper should initiate a study to
identify improvements in power shedding and utility reliability.
Emergency standby power should be available for the alarm and
notification system. As a part of their emergency backup power
study, IP should review solid state controlled automatic
switching of their present manually-switched two way busses.
55
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13.19 PAIL-SAFE INTERLOCKS AND VALVING
A cursory review of critical interlocks and valves identified
possible deficiencies in both A and B bleach plants. Drawings
and follow up discussions indicated that upon power failure,
several valves may fail to an unsafe position. Many of the
diagrams presented to the Audit Team were outdated or inadequate
for conducting an accurate interlock and valve safety review.
Because of the issues raised, we recommend that IP conduct a
comprehensive interlock and valve safety study. Modifications
should be initiated, where necessary.
13 • 20 OPERATION AND MAINTENANCE PROCEDURES
The Preventative Maintenance program for equipment used in
hazardous materials lines should be upgraded to include routine
replacement of critical parts based on the history of failure
rather than waiting for the equipment to fail while in service.
This program will require time to implement because IP has only
recently begun to keep accurate records on corrosion allowance,
release valve checks, and other critical maintenance items.
13.21 METEOROLOGICAL MONITORING
Realtime meteorological monitoring data from the 100—meter tower
is not currently available at the mill’s emergency response
command post. This information would be critical in the event of
a serious emergency release. International Paper should
prioritize this project and bring the system on line as soon as
possible.
56
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SECTION FOURTEEN
Conclusion
-------
14.0 CONCLUSION
The primary purpose of the Accidental Release Audit was to
identify imminent or potential hazards to the community and the
environment and to recommend corrective measures. As a result of
recent multi—media agency inspections, IP has improved risk
management procedures and has demonstrated an effort to improve
release prevention and safety. However, several potentially
serious safety problems were identified within the plant and its
environs. International Paper should evaluate the outlined
recommendations in this report as a means to substantially reduce
the risk of occupational and community—related injuries which may
occur as the result of a chemical accident or release.
The most significant problems were found in the following areas:
o accident investigation and follow up;
o hazardous materials storage and containment;
o chemical handling and unloading;
o scrubber systems;
o environmental compliance;
o hazards analysis and dispersion modeling;
o fire and hazardous materials response;
o contingency planning;
o alert and notification;
o training;
o decontamination;
o contractor safety;
o emergency drills;
o monitors and alarms;
o emergency backup power;
o failsafe interlocks and valving;
o maintenance procedures; and
o meteorological monitoring.
This listing is not all-inclusive. International Paper should
consider conducting a comprehensive internal audit to identify
additional safety problems and place a high priority on
rectifying all hazards that could impact the community.
Safety is the ongoing responsibility of Federal, State, and local
government, the community, and the mill. The EPA will continue
to monitor planning, Community Right to Know, and release
prevention policies in Jay, Maine, through its Region I SARA
Title III program office located in Lexington, Massachusetts.
57
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APPENDICES
-------
APPENDIX I
Photograph Log
58
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Film Roll: 1
LOG SHEET
PHOTOGRAPHY
Frame Site Name: International Paper
Number: 1 Site Location: Jay, Maine
— Amplifying
Information:
Scene: New V-brite
storage facility.
Photo By: E. Gilley
Date/Time: 4/21/88 13:30 his
Sky Conditions: Clear
Camera: Olympus Infinity
Setting:_Automatic
Film Type: ASA 200
Witnesses: M.Poirier
R.DiNardo
Frame Site Name: International Paper Amplifying
Number: 2 Site Location: Jay, Maine Information:
Scene:__Blue Chlorine
Dioxide storage tank from
which 2/5/88 release
occurred.
Photo By: E. Gilley
Date/Time: 4/21/88 13:40 hrs
Sky Conditions: Clear
Camera: Olympus Infinity
Setting: Automatic
Film Type: ASA 200
Witnesses: M.Poirier
R . DiNardo
-------
Film Roll: 1
LOG SHEET
PHOTOGRAPHY
Frame Site Name: International Paper Amplifying
Number: 3 Site Location: Jay, Maine Information:
Scene: Ammonia storage
tank in waste water treatment
area where spill occurred
on 11,/6/87.
Photo By: E. Gilley
Date/Time: 4/21/88 14:10 hrs
Sky Conditions: Clear
Camera: Olympus Infinity
Setting:_Automatic
Film Type: ASA 200
Witnesses: M Poirier
R.DiNardo
____________________ ___ Amplifying
— Information:
Scene: Front of
International Paper
Photo By: C.Caterino
Date/Time: 4/26/88 13:00 hrs
Sky Conditions: Clear
Camera: Olympus Infinity
Setting: Automatic
Film Type: ASA 200
Witnesses: M.Poirier
R DiNardo
Frame Site Name: International Paper
Number: 4 Site Location: Jay, Maine
-------
APPENDIX II
Air Model - Release of Sulfur Dioxide
at a Sodium Hydrosulfite Fire
4/18/87
59
-------
GF:OUND LEVEL CONCENTRATION FLUME FROM POINT SOURCE AIR RELEASE
90 FT SOURCE 90 FT
+ + + 0 + + +
111222334455555554433222111
11111111111222222222222222222211111111ii1
1111 l111111111111111111111111l111111l11111111
111111 1.11 llllllllllllllllllllli.ll1lllllll
1llll1ll1l1l1l1l11l1l1lll
GRID INCREMENTS———:> Y= 3 FEET AND X= 50 FEET
COMMENTS
COMPOUND
STABILITY CLASS
EFFECTIVE SOURCE HEIGHT FT
EMISSION RATE. LB/HR
AVERAGE WIND SPEED MPH
AMBIENT TEMPERATURE. DEG F
ATMOSPHERIC PRESSURE. MM HG
4/18/97 RELEASE
SULFUR DIOXIDE
:A
(_)
16.670
4 .
42 . ooo
7 t)
(FEET)
50
100
150
200
250
300
LEGEND
1
-
.4922702
TO
1.181448
PPM
2
-
1.181448
TO
3.938161
PPM
3
-
3.938161
TO
5.907242
PPM
4
-
5..907242
TO
7.876323
PPM
5 -
7.876323
TO
9.845402
FPM
59A
-------
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
9 FT SOURCE
(FEET) ÷ + + o + + +
111ll2223334445555555554443332 j . j 1
111111111111 11111122222222222222222222222221111 1 11111111111 1 1
ll lll l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l lU l l l l l l l l ll l li.i ll li l liii
i 111111111111111i 11111l11i11i.1111111111iiiiiliiiiiii1iiiiiiii
i 1111111l111111111111i.1111111111l11111111l11i i11i11ii1iiiiiii
1ll1l1111111111111111111111111111111111111111111111i1111i ilii
11111111 .t liii 111111111111111.1111111
1 - 13.32983 TO
2 — 31.. 9916 TO
- 106.6387 TO
4 - 159.958 TO
5 - 213.2773 TO
GRID INCREMENTS———:: Y .3 FEET AND X= 5 FEET
COMMENTS 4/18/87 RELEASE
COMPOUND : SULFUR DIOXIDE
STABILITY CLASS
EFFECTIVE SOURCE HEIGHTS FT 0.000
EMISSION RATE. LB/HR 16.670
AVERAGE WI ND SPEED MPH 4.000
AMBIENT TEMPERATURE DES F 42.000
ATMOSPHER IC PRESSURE • NM HG 760.000
5
10
15
20
30
35
4.:
45
LEGEND
9 FT
31.9916 PPM
106.6387 PPM
159.958 PPM
21.3.2773 PPM
266.5967 PFt1
59 B
-------
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
LEGEND
* - CONCENTRATION OVER — 2 PPM
GRID INCREMENTS———:> Y= 3 FEET AND X= 50 FEET
COMMENTS
COMPOUND
STABILITY CLASS
4/18/87 RELEASE
SULFUR DIOXIDE
:A
EFFECTIVE SOURCE HEIGHT, FT
EMISSION RATE, LB/HR
AVERAGE WIND SPEED, MPH
AMBIENT TEMPERATURE, DEG F
ATMOSPHERIC PRESSURE. MM HG
(_)
16.670
4 000
42 .000
760 . 000
(FEET)
50
1 (K)
150
90 FT SOURCE 90 FT
+ + + 0 + -f +
59C
-------
APPENDIX III
Air Model - Release From
Anhydrous Ammonia Storage Tank
11/6/87
60
-------
(FEET)
5000
1 Cx00
15000
200C)O
25000
30000
35000
40000
1 — 1.503879
2 — 3.60931
3 — 12.03103
4 - 18.04655
— 24.06207
TO
TO
TO
TO
TO
SOURCE
24542
112222211
111111111
11111111111
111111111
111111111
11111
GRID INCREMENTS———:> ‘1= 300 FEET AND X= 5000 FEET
COMMENTS
COMPOUND
STABILITY CLASS
EFFECTIVE SOURCE HEIGHT!
EMISSION RATE, LB/HR
AVERAGE t JIND SFEED. MPH
AMBIENT TEMPERATURE. DEG F
AThOSPHER IC PRESSURE. MM HG
11/6/87 RELEASE
AMMONIA
FT 0.000
22200 . 000
: 20 . 000
: 25 . 0(}0
760 .
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
9000 FT 9000 FT
+ + + 0 + + +
LEGEND
3.60931 F•F•M
12. 03103 PPM
18.04655 PPM
24 . 06207 PPM
30.07758 PPM
60A
-------
(FEET)
50C)
1000
1500
20 (x)
25( x)
3(_)(_fl_)
35c)()
1—
4-.-
5—
64.98525
155.9646
519.882
779.823
1039.764
TO
TO
TO
TO
TO
SOURCE
1245421
11122222111
11111111111
11111111111
11111111111
11111
GRID INCREMENTS———:: Y= 30 FEET AND X= 500 FEET
COMMENTS
COMFOUND
STABILITY CLASS
EFFECTIVE SOURCE HEIGHTS
EMISSION RATEq LB/HR
AVERAGE WIND SPEED MPH
MB lENT TEMPERATURE DES
ATMOSPHERIC PRESSURE MM
11/6/87 RELEASE
AMMONIA
FT C) . 000
22200 . 000
2o
F : 25.000
HG : 760 . OC x:)
- GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
900 FT 900 FT
+ + + C) + + +
LEGEND
155.9646 PPM
519.882 PPM
779.823 PPM
1039.764 PPM
1299.705 PPM
60B
-------
(FEET)
5 0()
1 C}C)0
1 0C)
200()
2 50C)
350C)
40’)C)
4500
55()()
6000
SOURCE
** ** * * ******* **
* - CONCENTRATION OVER -
25 F’PM
GRID INCREMENTS ———::: y= 30 FEET AND X= 500 FEET
COMMENTS
COMPOUND
STABILITY CLASS
EFFECTIVE SOURCE HEIGHT.
EMISSION RATE. LB/HR
AVERAGE WIND SPEED. MPH
AMBIENT TEMPERATURE. DEG F
ATMOSPHERIC FREGSURE MM HG
11/6/87 RELEASE
AMMONIA
:D
FT : C). 000
222:x)
(_) (_) _) ()
25 . O C X)
: 760 . 000
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
900 FT 900 FT
+ + + C) + + +
LEGEND
60C
-------
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
90 FT SOURCE 90 FT
(FEET) + + + 0 + + ÷
50
100
150
200 ****** *********************
250
300
350
400 ***** *** *** **************************
450 * * * * * * * * * * * * ** * * * * ** * * ** * * * * * ** * * * * * * * *
500 ********* *** ********************** *****
550 ***************************************
600
650
700
750
800 *****************************
850
900
950
LEGEND
* - CONCENTRATION OVER — 500 PPM
GRID INCREMENTS———> ‘/= 3 FEET AND X= 50 FEET
COMMENTS 11/6/87 RELEASE
COMPOUND AMMONIA
STABILITY CLASS
EFFECTIVE SOURCE HEIGHT, FT 0.000
EMISSION RATE. LB/HR :22200.000
AVERAGE WIND SPEED, MPH : 20.000
AMBIENT TEMPERATURE. DEG F : 25.000
ATMOSPHERIC PRESSURE, MM HG : 760.000
600
-------
APPENDIX IV
Air Model - Release Fro n
Chlorine Dioxide Storage Tank
2/5/88
61
-------
(FEET)
500
1000
1500
200 ’)
25C)0
3 00()
350t.
I
4—
• 2254029
• 540967
1 . 803223
2. 704835
3.606447
TO
TO
TO
TO
TO
SOURCE
1245421
11122222111
11111111111
11111111111
11111111111
11111
GRID INCREMENTS-——:: ‘1= O FEET AND X= 500 FEET
COMMENTS
COMFOUND
STABILITY CLASS
2/5/88 RELEASE
CHLORINE DIOXIDE
:D
EFFECTIVE SOURCE HEIGHT,
EMISSION RATE. LB/HR
A )ERAi ;E WIND SPEED, MPH
AMBIENT TEMFERATURE DEG
ATNOSFHEF:IC FRESSLIRE, MM
(_) • _) c_) ‘_>
234
15.000
1 s .
760 . oc: 0
GROUND LEVEL CONCENTRATION FLUME FROM POINT SOURCE AIR RELEASE
900 FT 900 FT
+ + + C) + + +
LEGEND
• 540967 PPM
1.803223 PPM
2.704835 PPM
3.606447 PPM
4.508058 PFM
FT
F
HG
61A
-------
GROUND LEVEL CONCENTRATION FtUME FROM POINT SOURCE AIR RELEASE
90 FT SOURCE 9Ci FT
+ + + 0 + +
123555321
11l22233 2221i1
1111122222222211111
111111111111111111111
11111111111111111111111
1l1111111l1l1I111l1l111
1lll1l1l11l1111111ll1l1
1-1111l1li11ll1l111111
11111111111111111
111111111
GRID INCREMENTS———> Y= 3 FEET AND X 50 FEET
COMMENTS
COMPOUND
TA ILITV CLASS
EFFECTIVE SOURCE HEIGHT.
EMISSION RATE. LB/HR
AVERAGE WIND SPEED • MPH
AMBIENT TEMPERATURE. DEG
ATMOSF’HER I C PRESSURE • MM
2/5/88 RELEASE
CHLORINE DIOXIDE
C) ( )C )
234 . 000
1 s . 000
1 s . 000
7 C . t) O)
(FEET)
50
100
150
200
250
300
350
400
4 so
550
LEGEND
1
—
4.28311
TO
10.27946
FFM
2
—
10.27946
TO
34.26488
PPM
3
—
34.26488
TO
51.39732
PPM
4
-
51.39732
TO
68.52976
PPM
5
-
8. 2976
TO
85.66219
PPM
FT
F
HG
61B
-------
(FEET)
500
1000
1500
2000
25(10
3000
3500
4C) :)()
4 5(:)()
** * * *** * ** **
GRID INCREMENTS— —-> Y 30 FEET AND X 500 FEET
COMMENTS
COMPOUND
STABILITY CLASS
2/5/88 RELEASE
CHLORINE DIOXIDE
:D
EFFECTIVE SOURCE HEIGHTS FT
EMISSION RATE. LB/HR
AVER IGE W t ND SPEED • MPH
ME;IENT TEMFERP TIJPE. DEG F
ATM0SFHER1 : FF:ESSL)RE, MM HG
C_ I
234 — ( (x)
i_ s
15 ( 00
760. 00( 1
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
900 FT SOURCE 90(1 FT
+ + + 0 + + +
LEGEND
* - CONCENTRATION OVER —
• 1 PPM
61C
-------
* ** * * * *** *
GRID INCREMENTS———:> Y= 7 FEET AND X= 50 FEET
COMMENTS
COMPOUND
STABILITY CLASS
EFFECTIVE SOURCE HEIGHT FT
EMISSION RATE., LB/HR
AVERAGE WIND SPEED MFH
AMBIENT TEMPERATURE, DEG F
ATMOSPHERIC PRESSURE MM HG
2/5/88 RELEASE
CHLORINE DIOXIDE
0. 000
234 . C)O0
15. c)00
15.OC)()
760. c)00
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
90 FT SOURCE 90 FT
0 + + +
(FEET)
Sc)
100
150
200
250
LEGEND
* - CONCENTRATION OVER — 10 PPM
61D
-------
SOURCE
+ — + — + —C)— + — + — +
1245421
11122222111
11111111111
11111111111
11111111111
11111
7. 7o4953E—02
.1849189 TO
.6163963 TO
.9245944 TO
1.232793 TO
TO .1849189 PPM
.6163963 PPM
.9245944 PPM
1.232793 PPM
1 . 540991 PPM
GRIO INCREMENTS———> Y= 30 FEET AND X 500 FEET
COMMENTS
COMPOUND
STABILITY CLASS
EFFECTIVE SOURCE HEIGHT FT
EMISSION RATE. LB/HR
AVERAGE WIND SPEED. MPH
AI9E IENT TEMPERATURE. DEG F
ATMOSPHERIC FRESSURE. MM HG
2/5/88 RELEASE
CHLORINE
:D
0 . ()00
83 . 000
15.000
1 5 . 000
7 () .
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
900 FT
(FEET)
500
100 o
1500
200c)
2500
3000
3500
LEGEND
900 FT
4—
5—
61E
-------
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
50
100
150
200
250
300
350
400
45 :)
0C’
550
TO
TO
TO
TO
To
3.513832
11.71277
17.56916
23.42555
29.28193
FF’M
PPM
PPM
FPM
PFM
SOURCE
123555321
111222333222111
1111122222222211111
li l l l l l l l l l l l l li ll l li
11111111111111111111111
l li l l l li l l l l l l l l li.11111
11111111111111111111111
111111111111111111111
11111111111111111
111111111
GRID INCREMENTS——-> Y= 3 FEET AND X= 50 FEET
COMMENTS
COMPOUND
STABILITi CLASS
2/5/88 RELEASE
CHLORINE
EFFECTIVE SOURCE HEIGHT. FT
EMISSION RATE. LB/HR
AVERAGE WIND SFEED, MPH
AMBIENT TEMPERATURE. DEG F
ATMOSPHERIC PRESSURE. MM HG
0 . 00C)
83 .
15 . O C X)
1 s . ooo
76() — O )C)
(FEET)
90 FT 90 FT
+ ÷ + 0 + + 1-
LEGEND
1 — 1.464097
2 - 3. 513832
3 — 11.71277
4 — 17.56916
5 — 2.42555
61F
-------
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
90 FT SOURCE 90 F1
(FEET) + + + 0 + + +
50
100
150
200
250
4 cx:)
35C)
400
450
500
600
650
700
LEGEND
* - CONCENTRATION OVER — 1 PPM
GRID INCREMENTS———:: Y= 3 FEET AND X= 50 FEET
COMMENTS 2/5/88 RELEASE
COMPOUND CHLORINE
STABILITY CLASS
EFFECTIVE SOURCE HEIGHT. FT 0.000
EMISSION RATE. LB/HR 83.000
AVERAGE WI ND SPEED • MPH 15. 000
AMB I ENT TEMPERATURE DEG F 15.000
ATMOSPHERIC PRESSURE, MM HG ThO. 00 0
6 1G
-------
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
SOURCE
(FEET) + + + 0 + + +
* 4* 4*4* 4 4* 4*4* 4
* 4* * * ** * * * *4* ******* * 4*
*44* 4 4* * * * 4* 4*4 4* *4* *4*
4* 4* *44* * 4* *4* * * *4* *4
*4*4*4*4 ** * * 4 * ** 4* *
4*4*4*44*4*4*
GRID INCREMENTS———> Y= .3 FEET AND X 5 FEET
COMMENTS
COMPOUND
STABILITY CLASS
2/5/SB RELEASE
CHLORINE
EFFECTIVE SOURCE HEIGHTS FT
EMISSION RATE, LB/HR
AVERAGE WIND SPEED, MPH
AMBIENT TEMPERATURE. DES F
ATMOSPHERIC PRESSURE, MM HG
0 . 000
83 . c: )D0
15 000
15.000
7o0 . CCC
9 FT
9 FT
5
10
15
20
25
30
35
40
45
LEGEND
* - CONCENTRATION OVER — 30 PPM
6Th
-------
900 FT SOURCE 900 FT
+ + + 0 + + +
1245421
11122222111
11111111111
11111111111
11111111111
11111
GRID INcREMENTs —-::: Y 30 FEET AND X= 500 FEET
COMMENTS
COMPOUND
STABILITY CLASS
EFFECTIVE SOURCE HEIGHT. FT
EMISSION RATE, LB/HR
AVERAGE WTND SPEED. MF’H
AIIB: [ ENT TEMFERATIJRE. DEG F
ATMOSFHERIC FF ESSUF:E . MM HG
2/5/88 RELEASE
CHLORINE DIOXIDE
• (_X_fl)
2374 . 000
1 5 . )O0
I 5 . 000
76 :’ . 000
G OF EEEöF TRATION PLUME FROM POINT SOURCE AIR RELEASE - - -
(FEET)
500
1000
t 500
2000
2500
3500
LEGEND
1
-
2.28678
TO
5.488271
PPM
2
—
5.488271
TO
18.29424
PPM
3
-
18.29424
TO
27.44136
PPM
4
-
27.44136
TO
36.58848
PPM
5
-
3o.58848
TO
45.7356
FFtl
611
-------
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
(FEET)
Sc)
1 c
150
200
250
300
350
400
450
5_)C)
550
SOURCE
123555321
111222333222111
1111122222222211111
11111111111 1111111111
11111111111111111111111
11111111111111111111111
l l ll l l ll l ll l l l lli liii l l
11111111 111111i11i 11i
11111111111111111
11111 1111
GRID INCREMENTS-——:: Y= 3 FEET AND X= 50 FEET
COMMENTS
COMPOUND
STABILIT’i CLASS
EFFECTIVE SOURCE HEIGHT. FT
EMISSION RATES LB/HR
AVERAGE WIND SPEEDS MPH
AMBIENT TEMPERATURE DES F
TMC9FHERIC PRESSURE. MM HG
2/5/88 RELEASE
CHLORINE DIOXIDE
a . O Oc)
2374 . 000
15. OOC)
15.
74()
90 FT 90 FT
+ + + 0 ÷ + ÷
LEGEND
1
—
4..45343
TO
104.2882
PPM
2
—
104.2982
TO
347.6274
PPM
T
-
47 6 74
TO
1 441
PPM
4
-
521.4412
10
495.2548
PPM
5
-
695.2548
TO
869.0696
PPM
61J
-------
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
1800 FT SOURCE 1800 FT
(FEET) + + + 0 ÷ + +
1000
2000
3000
4000
5000
6000
7000
8000
Q 0 0 0
10000
11000
12000
13000
14000
15000
16000
17000
18000
19000
20000 *******t* ***** *************
21000
22000
23000
24000
LEGEND
:4 — CONCENTRATION OVER — . 1 PPM
GRID INCREMENTS———> ‘1= 60 FEET AND X 1000 FEET
COMMENTS 2/5/88 RELEASE
COMPOUND CHLORINE DIOXIDE
STABILITY CLASS D
EFFECTIVE SOURCE HEIGHT, FT 0.000
EMISSION RATE, LB/HR 2374.000
AVERAGE WIND SPEED, MPH 15.000
AMBIENT TEMPERATUREI DEG F 15.000
ATMOSPHERIC PRESSURE, MM HG 760.000
61K
-------
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
90 FT SOURCE 90 FT
(FEET) + ÷ + 0 + + +
50
100
150
200
250
300
350
400 * * * * * * * * * * * * * * * * * * * * * S * * * * * * * * * * S * * * * * * * * * * * *
450 * 5* 5 5* 5 ************** ****** **************** ****
500 5 * 5 .5 55 * 5 * :5 * * S * S .5 5 * * * * S S * .5 * * .5 * * * S * 5 * S * S * * * * * * * * * * *
550
600
850 ************************ *****************************
700 *******************************************************
750
900 *5* ************ *5*55*5*5* ******************************
650
900 ***** *****S************* *****************************
950
1000 * * * * * ** * * * * * St *5* 5* ** * * * * * * * * 5 *5* * * * * * * * *5* * 5*5 * *
1050
1100
1150
1200 5*5*5*5*5*5* *5*5 ***************
1250
1300
LEGEND
* — CONCENTRAT ION OVER - - 10 PPM
GRID INCREMENTS — ——::. Y 3 FEET AND X 50 FEET
COMMENTS 2/5/39 RELEASE
COMPOUND CHLORINE DIOXIDE
STABILITY CLASS
EFFECTIVE SOURCE HEIGHT, FT 0.000
EMISSION RATE, LB/HR 2374.000
AVERAGE WIND SPEED • MPH 15.000
AMBIENT TEMPERATURE. DEE F 15.000
ATMOSPHERIC PRESSURE. MM HG 760.000
61L
-------
900 FT SOURCE 900 FT
+ + ————————— + 0 + + +
1 4 4 1
11122222111
11111111111
11111111111
11111111111
11111
ORID INC EMENTS—- —> ‘1= 30 FEET AND X 500 FEET
COMMENTS
COMPOUND
STABILITY CLASS
2/5/88 RELEASE
CHLORINE
:0
EFFECTIVE SOLiRCE HEIGHT, FT
EMISSION F iE. LEI/HR
AVERAi E ND SPEED, MfH
4M fENi 1aMFEFATUF E. DEG F
ATMU FH F: I C —RESSLIRE MM HO
C) U( )()
1 5 -
1 5 .
7 ’ .
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
(FEET)
S(X)
1 0O(’
i sc:x:
2OC t)
2500
3oCx
3500
LEGEND
1
—
.7751369
TO
1.860329
PPM
2 —
1.860329
TO
6.201095
PPM
3
—
6.201095
10
9.301643
PPM
4
-
.3O 43
TO
12.40219
FPM
s
-•
12.40219
10
15.50274
PPM
61M
-------
90 FT SOURCE 90 F1
+ + + 0 + + +
123555321
111222333222111
1111122222222211111
l l ll l l lli-i1i1111i-il11
11111111111111111111111
11111111111111111111ll1
li.l l l l l l l l li.11111111 111
1 :1 11 1 1 1111 1 11 1 ii 11 1 1 i
11111111111111111
111111111
l 4 .7291c, TO 35.34999 PPM
5.34999 TO 117.8333 PPM
117.8333 TO 17o.75 PF’M
17a.75 TO 235.6 6 PPM
235. 6 6 TO 294.5833 PPM
GRID INCREMENTS———> v= 3 FEET AND X= 50 FEET
COMMENTS
COMPOUND
5TAL3ILIi CLASS
EFFECTIVE SOURCE HEIGHT. FT
EMISSION RATES LB/HR
AVEF GE WIND SPEED. MPH
AMBIENT TEMPERATURE. DEG F
TMiJSFHERIC PF:ESSURE. MM HG
2/5/88 RELEASE
CHLORINE
:D
• CCx_)
835 . 000
1 5 .
1 5 . 000
760 .
GROUND LEVEL CONCENTRATION FLUME FROM POINT SOURCE AIR RELEASE
(FEET)
50
1 c:)c;
150
200
250
300
350
45(
LEGEND
1—
4—
61N
-------
900 FT SOURCE 9C)O i
+ + + 0 + + +
COMMENTS
COMPOUND
STABILITY CLASS
EFFECTIVE SOURCE HEIGHT FT
EMISSION RATE. LB/HR
AVERAGE WIND SPEED. MPH
AMBIENT rEMPERATURE. DEG F
ATMOSPHERIC PRESSURE MM HG
2/5/83 RELEASE
: CHLORINE
:D
335. 000
15 000
1 5. 000
760. 000
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
(FEET)
500
1 0()c)
1 5(:) :)
2o:o
2 5C)0
oo
LEGEND
* - CONCENTRATION OVER — 1 PPM
GRID INCREMENTS———> Y= 30 FEET AND X= 500 FEET
610
-------
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
9C) FT SOURCE
+ + + () + + +
** ** * * ** ****** *
* ** * *** * * *
COMMENTS
COMPOUND
STABILITY CLASS
EFFECTIVE SOURCE HEIGHT. FT
E 1ISSION RA1’E LB/HR
AVERAGE WINI) SPEED, MPH
r- MB LENT TEMPERATURE, DEG F
ATMOSPHERIC PRESSURE. MM HG
: 2/5/98 RELEASE
CHLORINE
:0
• 000
335. 000
1. 5 ()O()
.1 5 • 000
(FEET)
1
150
200
250
:.oo
3 5C)
LEGEND
90 FT
* - CONCENTRATION OVER — 30 PPM
GRID INCREMENTS———> V 3 FEET AND X 50 FEET
61P
-------
APPENDIX V
Credible Worst Case Scenario
Chlorine Dioxide Storage Tank
62
-------
(FEET)
500()
1
1
2C) OC)()
25 )C)0
30000
35000
SOURCE
24542
112222211
111111111
11111111111
111111111
111111111
11111
1 — 4017669
2 - 9642406
3 — 3. 214136
4 — 4.82123
5 — 6.425271
TO .9642406
TO 3.214136
TO 4.8212(:)
TO 6.428271
TO S.u35338
GRID INCREMENTS— ——::: Y 300 FEET AND X SOoO FEET
COMMENTS
COMPOUND
STABILITY CLASS
EFFECTIVE SOURCE HEIGHT
EMISSION F:ATE, LB/HR
VEF GE t l1ND SPEED. MPH
AMBIENT TEMPERATURE. DEG F
rMosFHERIc FPESSIJRE. MM HG
TANK COLLAFSE
CHLORINE DIOXIDE
FT : 0.
1 594:
: 15 .
: 77
760
GROUND LEVEL CONCENTRATION FLUME FROM POINT SOURCE AIR RELEASE
90X FT 9000 FT
+ + + C) + + +
LEGEND
PPM
PPM
PPM
PPM
PPM
62A
-------
GROUND LEVEL CONCENTRATION FLUME FROM POINT SOURCE AIR RELEASE
900 FT SOURCE 900 FT
+ + + 0 + ÷ +
1245421
11122222111
11111111111
11111111111
11111111111
11111
GPID INCREMENTS———:> Y= 30 FEET AND X= 500 FEET
COMMENTS
COMPOUND
STABILITY CLASS
EFFECTIVE SOURCE HEIGHTS FT
EMISSION RATE LB/HR
VERASE WIND SPEED. MFH
AMBtENT TEMF’ERATURE. DES F
TMtJ FHERIC FRESSURE MM HG
TANK COLLAPSE
CHLORINE DIOXIDE
:D
• U (_)t_)
15940 • 000
1 5 000
: 77 •
7 :) •
(FEET)
5Cn)
1 (>Cx)
1500
2(x) )
2 5:x)
3000
35 (n )
LEGEND
1 -
17.36105
TO
41.66652
PPM
2
-
41.66652
TO
138.8384
PPM
3
-
1.8.8884
TO
208.3326
PPM
4
—
208.3326
TO
277.7768
PPM
5
—
277.7768
TO
347.2211
PPM
62B
-------
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
9000 FT SOURCE 90: :> FT
(FEET) + + + 0 + ÷ +
5000
10000
15000
20000
30000
:5oc) :)
400(1(1
4500C
50000
s soo(:)
boot:’o
7ot:)o(:) ********************** *
75000 ********* 4***********
80000
.85000
90000
95000
100000
LEGEND
* - CONCENTRATiON OVER — . 1 F’Ftl
GRID INCREMENTS———> Y= 300 FEET AND X 5000 FEET
COMMENTS : T M:: COLLAPSE
COMPOUND CHLORINE DIO IDE
STABILITY CLASS : 0
EFFECTIVE SOURCE HEIGHT, FT : 0.000
EMISSION RATE. LB/HR :15940.0(1(1
AVERAGE WIND SPEED, MPH : i5.000
AMBIENT TEMPERATUREq DEG F 77.000
ATMOSPHERIC PRESSURE, MM HG : ThO. 0 0 0
62C
-------
GROUND LEVEL CONCENTRATION FLUME FROM POINT SOURCE AIR RELEASE
900 FT SOURCE 90’: F
+ + + 0 + + +
* ** ** * * * ** ** * * *
* * ***** * *** * *
COMMENTS
COMPOIJND
STABILITY CLASS
EFFECTIVE SOURCE HEIGHT. FT
EMISSION RATE. LB/HR
AVERAGE WIND SFEED MPH
AMBIENT TEMFERATUREe DEG F
ATMOSPHERIC PRESSURES MM HG
: TANK COLLAPSE
CHLORINE DIOXIDE
15940.000
: 1 5 . 00C)
77. 000
761:) . 000
(FEET)
500
1 00
1500
2C )C
25(>)
3000
3500
4000
4500
LEGE ND
* - CONCENTRATION OVER — 10 PPM
GRID INCREMENTS———> Y= 30 FEET AND X= 500 FEET
62D
-------
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
900 FT SOURCE 900 FT
+ + + 0 + + ————————— +
1245421
11122222111’
11111111111
11111111111
11111111111
11111
GRID INCREMENTS———> Y= 30 FEET AND X= 500 FEET
COMMENTS
COMPOUND
STABILITY CLASS
EFFECTIVE SOURCE HEIGHT. FT
EMISSION RATE. L.B/HR
AVERAGE WIND SPEED. MPH
AMBIENT TEMFERATURE. DEG F
ATM’JSPHERIC PRESSURE. MM HG
: TANK COLLAPSE
CHLORINE
:D
(_) .
5608 (:)00
is 00c
77 —
760 000
(FEET)
500
1 ooo
1500
2000
2500
3000
3500
LEGEND
1
-
5.886323
TO
14.12717
F’PM
2
—
14.12717
TO
47.09058
PPM
3
—
47.09058
TO
70.63588
PPM
4
-
70.63 88
TO
94.18116
PPM
S
-
94.18116
TO
117.7265
PF’I1
62E
-------
(FEET)
50
100
150
20C)
250
300
35C)
4()C)
450
55(1)
SOURCE
123555321
111222333222111
1111122222222211111
11111i11l111111111111
11111111111111111111111
11111111111111111111111
11111111111111111111111
l l ll l l l l l lI l l l l l l l l li
11111111111111111.
111111111
GRID INCREMENTS ———:: Y .3 FEET AND X= 50 FEET
COMMENTS
COMPOUND
3TABILIr’ CLASS : D
EFFECTIVE SOURCE HEIGHTS FT
EMISSION RATE. LB/HR
AVERAGE WIND SPEED, MPH
AMBIENT TEMPERArURE. DEG F
TMOSPHER I C FF:ESSURE, MM HG :
TANK COLLAPSE
CHLORINE
t) 0(1)()
56Ci8
15 .
•77 . 000
• 00w)
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
90 FT 90 F
+ ÷ + 0 + + +
LEGEND
1
-
111.852
TO
268.4448
PPM
2
-
268.4448
TO
894.8161
PPM
-
894 8161
TO
1 4 • 4
PPM
4
-
1342.224
TO
1789.632
PPM
5
-
17 9.631
TO
2237.04
PPM
62 F
-------
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
900 FT SOURCE 900 FT
(FEET) + + + 0 ÷ + +
500
1000
1500
2000
2500
3000
3500
4000
4500
5000
5500
6000
6500
7000
7500
8000
8500
9000
9500
10000
LEGEND
* - CONCENTRATION OVER — 1 PPM
GRID INCREMENTS———> ‘1= 30 FEET AND X= 500 FEET
COMMENTS TANK COLLAPSE
COMPOUND CHLOR I NE
STABILITY CLASS D
EFFECTIVE SOURCE HEIGHT, FT 0.000
EMISSION RATE. LB/HR : 5608.000
AVERAGE W I ND SPEED MPH 15. 000
AMBIENT TEMPERATURE . DEG F 77.000
ATMOSPHER IC PRESSURE, MM HG 760 . 000
62G
-------
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
90 FT SOURCE 90 FT
(FEET) + + + 0 + + +
50
100 * 4* 4* 4*4*4* 4*4* 4*
150
200
250
300
350
400
45’)
500 * * * * * * 4 * * * * * * * * 4 * * * * * * * 4 * * * 4 * * * * * * * * * * * * * * *4* * *
550 ******* ******************************************
600 ************************************************ .4
650 ******* ******************************************
700 *44*4*4 *4* ***************************************
750 ********** ***************************************
BOO
850
900 *4*4* ** * ******* *************** *4* 4*4*4*44*4*4
950 4* 4* 4* 44* 4*4* 4*4* **************************
1000
1050
1100
1150 * 4* 4*4* 4*4* 4* 4*
1200
LEGEND
4 — CONCENTRATION OVER — 30 PPM
GRID INCREMENTS-——> ‘/= 3 FEET AND X= 50 FEET
COMMENTS TANK COLLAPSE
COMPOUND CHLORINE
STABILITY CLASS
EFFECTIVE SOURCE HEIGHTS FT 0.000
EMISSION RATE 1 LE t/HR 5608.000
AVERAGE WIND SPEEDI MPH 15.000
AMBIENT TEMPERATURE. DEG F 77.000
ATMOSPHERIC PRESSURE, MM HG 760.000
62H
-------
APPENDIX VI
Credible Worst Case Scenario
Anhydrous knnnonia Storage Tank
63
-------
GROUND LEVEL CONCENTRATION FROM INSTANTANEOUS (PUFF) RELEASE
TRAVEL TIME DISTANCE 7500 FT SOURCE 7500 FT
MINUTES FEET
0 0
3.8 5000
7.6 10000
11.4 15000
15.2 20000
18.9 25000
22.7 29999
26.5 35000
30.3 40000
34.1 45000
37.9 50000
41.7 54999
45.5 59999
49.2 64999
53.0 70000
56.8 750c>0
60.6 80000
64.4 85000
68.2 90000
72.0 95000
75.8 l0 0 00c)
79.5 losocx:)
83.3 109999
87.1 114999
90.9 119999
94.7 124999
LEGEND
* - INDICATES AREA WHERE CONCENTRATION IS OVER 25 PPM
GRID INCREMENTS ———.> X= 5000 FEET AND ‘1= 300 FEET
PLOT INTERF’RETAT ION
THE PLOT DEPICTS THE MOVEMENT OF A CROSS SECTION OF THE PUFF. THE PLOT SHOLAJE
TRAVEL DISTANCES AND THE TIME IT TAKES THE CROSS SECTION TO REACH EACH LOCAT C
THE CROSS SECTION IS SHOWN AS A PROFILE LINE (****) WHICH REPRESENTS THE
MAXIMUM WIDTH OF THE PUFF WHERE THE SPECIFIED LEVEL OF CONCERN IS EXCEEDED
IT CAN BE ASSUMED THAT THE ACTUAL PUFF I AT A GIVEN TRAVEL TIME AND
CORRESPONDING DISTANCE. IS CIRCULAR WITH RADIUS EQUAL TO THE CROSS SECTION
COMPOUND NAME : AMMONIA
COMMENTS TANK COLLAPSE
STABILITY CLASS : 2
SOURCE STRENGTH LB :68112.00
EFFECTIVE SOURCE HT. 1 FT 0.00
(WERAGE WIND SPEED. MPH 15.00 - 63A
-------
INITIAL PUFF WIDTH, FT
INITIAL PUFF HEIGHT, FT :
AMBIENT TEMPERATURE, DEG F:
ATMOSPHERIC PRESSURE, MMHG:
SAMPLING TIME, SECONDS
0.00
0.00
77.00
760.00
0.00
63B
-------
GROUND LEVEL CONCENTRATION FROM INSTANTANEOIJS (PUFF) RELEASE
TRAVEL TIME
MINUTES
C —)
3.8
7.6
11.4
15.2
18.9
22.7
26. 5
DISTANCE
FEET
0
5000
10000
15000
20000
25000
29999
35000
40000
* - INDICATES AREA WHERE CONCENTRATION IS OVER 500 PPM
GRID INCREMENTS ———> X= 5000 FEET AND ‘1= 300 FEET
PLOT INTERPRETATION
THE PLOT DEPICTS THE MOVEMENT OF A CROSS SECTION OF THE FUFF. THE PLOT SHOWS
TRAVEL DISTANCES AND THE TIME IT TAKES THE CROSS SECTION TO REACH EACH LOCATI r
THE CROSS SECTION IS SHOWN AS A PROFILE LINE (****) WHICH REPRESENTS THE
MAXIMUM WIDTH OF THE PUFF WHERE THE SPECIFIED LEVEL OF CONCERN IS EXCEEDED
IT CAN BE ASSUMED THAT THE ACTUAL PUFF, AT A GIVEN TRAVEL TIME AND
COPF:ESPONDING DISTANCE. IS CIRCULAR WITH A RADIUS EQUAL TO THE CROSS SEOTtON
COMPOUND NAME
COMMENTS
STABILITY CLASS
: AMMONIA
TANI::: COLLAPSE
OURCE STRENGTH., LB :68112.00
EFFECTIVE SOURCE HT. . , FT : 0.00
AVERAGE WIND SFEED, MFH : 15.00
ATMOSFHER IC MI X HE I GHT • FT: 5000 . 00
I N I TI AL PUFF WIDTH FT : 0. 00
INITIAL PUFF HEIGHTS FT : 0.00
AMBIENT TEMPERATURES DEG F: 77.00
ATMOSPHERIC PRESSURE MMHG: 760.00
SAMPLING TIME, SECONDS : 0.00
7500 FT
SOURCE
I ————+————+———.—+————+————O————+_——_+——__+____+ -___---
7500 FT
LEGEND
63C
-------
GROUND LEVEL CONG. AS A FUNCTION OF TIME AT A SPECIFIC DOWNWIND POINT
TIME (MIN) CONCENTRATION
AFTER PPM AT
RELEASE 5280 FT.
3 . 0(3 o.c o
3 . 08 0 . 00
3.17 0.00
3.25 0.01
cj. .
3.42 4.94
3.50 63.55
3.58 551.54
3.67 3231.66
.75 12783.27
3.83 34136.92
3.92 61542.33
4.00 74901.49
4.08 61542.33
4.17 34136.92
4 25 12783.27
4.33 3231.68
4.42 551.54
4.50 63.55
4.58 4.94
4.67 0.26
4.75 0.01
4 . 83 0 . 00
4.92 0.00
COMPOUND NAME : AMMONIA
COMMENTS : TANK COLLAPSE
STABILITY CLASS
SOURCE STRENGTH. LB :68112.00
EFFECTIVE SOURCE HT., FT : 0.00
AVERAGE WIND SPEED. MPH 15.00
ATMOSPHERIC MIX HEIGHT. FT: 5000.00
INITIAL PUFF WIDTH. FT : (3.00
INITIAL PUFF HEIGHT. FT : 0.00
AME IENT TEMPERATURE DES F: 77.00
ATM’JSPHERI C PRESSURE, MMHG: 760.00
SAMPLING TIME. SECONDS : 0.00
63D
-------
GROUND LEVEL CONC. AS A FUNCTION OF TIME AT A SPECIFIC DOWNWIND POINT
TIME (tIIN)
AFTER
RELEASE
19.50
19.75
2 . 00
20.25
20.50
2C).75
21
21 .25
21. 50
21 .75
22.00
22.25
22.50
22.75
23 . 00
23.25
23.50
23.75
24 .00
24.25
24. 50
24.75
25.00
25.25
25. 50
25.75
26. ()()
26.25
26. 50
—
27 . 00
:7.25
27.50
27.75
28.00
28.25
COMFiJUND NAME
COMMENTS
STASILITY CLASS
CONCENTRATION
PPM AT
31680 FT.
0 . oc:’
Cn:)
0 . 00
c) .
O . C x)
0 . 01
o . 06
0.29
1.14
12. 01
32.05
75.03
154.07
277.60
438.82
608.62
740.59
790.65
740.59
608 .62
438.83
277.60
154.07
75.03
32.05
12 .01
3.95
1.14
0.29
o .
0.01
0 .
o . Cx)
o . Cx)
AMMONIA
TANK COLLAPSE
SOURCE STRENGTH LB :68112.00
EFFECTIVE SOURCE HT., FT : 0.00
AVERAGE WIND SPEED 4 MFH : 15.O ()
ATMOSPHERIC MIX HEIGHT 4 FT: 5000.00
INITIAL PLIFF WIDTH. FT : 0.00
INITIAL F’UFF HEIGHT FT 0.0)
AMBIENT TEMFEPATURE. DEC F: 77.00
ATMOSPHER I C • MMHG: 760.00
SAMPLING TIME. SECONDS 0.00
63E
-------
APPENDIX VII
Credible Worst Case Scenario
Chlorine Rail Car
64
-------
GROUND LEVEL CONCENTRATION FLUME FROM POINT SOURCE AIR RELEASE
(FEET)
5000
10000
1 O00
20000
25000
30000
35000
40000
SOURCE
0
24542
112222211
111111111
11111111111
111111111
111111111
11111
GRID INCREMENTS——-> 1= 300 FEET AND X= 5000 FEET
COMMENTS
COMPOUND
STABILITY CLASS
EFFECTIVE SOURCE HEIBHT FT
EMISSION RATE. LB/HR
AVERAGE WIND SPEED. MFH
AMBIENT TEMPERATURE. DES F
ATMOSPHEF:IC PRESSURES MM HG
1 RAIL CAR
CHLORINE
(} • C)C)0
: 180000 000
15 o Ou
77
7o(:)
9000 FT
9000 FT
LEGEND
1
—
4.372267
TO
10.49344
PPM
2 -
10.49344
TO
34.97814
PPM
3
-
34.97814
TO
52.4672
PPM
4
-
52.4672
TO
69.95627
PPM
5
-
9.95627
TO
87.44534
PPM
64A
-------
GROUND LEVEL CONCENTRATION PLUME FROM POINT SOURCE AIR RELEASE
9000 FT SOURCE 9000 FT
(FEET) + + + 0 + + ÷
5000
10000
15000
20000
25000
30000
35000
40000
45000
50000
55000
60000
65000
70000
75000
80000
85000
90000
95000
100000
105000
LEGEND
* - CONCENTRATION OVER — 1 PPM
GRID INCREMENTS———> Y= 300 FEET AND X= 50C”) FEET
COMMENTS 1 RAIL CAR
COMFOUND : CHLORINE
STABILITY CLASS
EFFECTIVE SOURCE HEIGHT. FT 0.000
EMISSION RATE. LB/HR : 1e(:)(:)oO.0Oo
AVERAGE WIND SFEED MPH : 15.000
AMBIENT TEMPERATURE. DEG F : 77.000
ATMOSFHER IC PRESSURES MM HG 760.000
64B
-------
GROUND LEVEL CONCENTRATION FLUME FROM POINT SOURCE AIR RELEASE
** * * * * * * * * ****** ****
* * * x x x * * ****** **** ****** xxx
* xx ** * xxx * **** *** ******** *****
************** *******************
xx * *** * ** ** xxx xxx xxx
xx ****x *** xx *
xx * xx * xx
xx xxx xxx xx
GRID INCREMENTS———:> Y= 30 FEET AND X= 500 FEET
COMMENTS
COMPOUND
STABILITY CLASS
EFFECTIVE SOURCE HEIGHT, FT
EMISSIJN RATE. LB/HR
AVERAGE WIND SPEED, MPH
AMBIENT TEMPERATURE, DEG F
ATMOSPHERIC PRESSURE, MM HG
1 RAIL CAR
: CHLORINE
: X18()C)C’ () 000
15.000
: 77 000
: 760 . 000
900 FT SOURCE
9Cn: FT
(FEET)
500
1000
1 5 0
200’)
2500
30(n)
3500
4000
45 n:
500’)
550’)
6000
650(3
7000
7500
8000
8500
90( 3( 3
9500
10t) ) )
10500
LEGEND
* - CONCENTRATION OVER — 30 PPM
64C
-------
GROUND LEVEL CONCENTRATION FROM INSTANTANEOUS (FUFF) RELEASE
TRAVEL TIME DISTANCE 7500 FT SOURCE 7500 FT
MINUTES FEET
0 0 I——— +————+————+————+————O ————+————+————+————+————
3.8 5000
7.6 1(’000
11.4 15000
15.2 20000
18.9 25000
22.7 29999
26.5 350C)0
30.3 40000
34.1 45000
37.9 50000
41.7 54999
45.5 59999
49.2 64999
53.0 70000
56.8 75C)00
60.6 80000
64.4 8500’:)
68.2 90000
72.0 95 0C)C)
75.9 10000’ :)
LEGEND
* - INDICATES AREA WHERE CONCENTRATION IS OVER 30 FFM
GRID INCREMENTS ———> x= sooo FEET AND ‘1= 300 FEET
PLOT INTERPRETATION
THE PLOT DEPICTS THE MOVEMENT OF A CROSS SECTION OF THE F’UFF. THE PLOT SHOW5
TRAVEL DISTANCES AND THE TIME IT TAKES THE CROSS SECTION TO REACH EACH LOC Ti:
[ HE CROSS SECTION IS SHOWN AS A PROFILE LINE (** *) WHICH REPRESENTS THE
MAXIMUM WIDTH ‘JF THE PUFF WHERE THE SPECIFIED LEVEL OF CONCERN IS EXCEEDED
IT CAN BE ASSUMED THAT THE ACTUAL FUFF. AT A GIVEN TRAVEL TIME AND
CORRESPONDING DISTANCE. is CIRCULAR WITH A RADIUS EQUAL TO THE CROSS SECTION
COMPOUND NAME : CHLORINE
COMMENTS 1 RAIL CAR
STABILIT’y CLASS
SOURCE STRENGTH LB : 18C)000 .00
EFFECTIVE SOURCE HT., FT 0.00
AVERAGE WIND SPEED, MPH : 15.00
ATMOSPHERIC MIX HEIGHT. FT: 5000.00
INITIAL PUFF WIDTH. FT : 0.U0
INITIAL PUFF HEIGHT, FT : 0.00
AMBIENI TEMPERATURE. DEG F: 77.00 640
A Mfl r r.y,’ • 7L ‘
-------
GROUND LEVEL CONC. AS A FUNCTION OF TIME AT A SPECIFIC DOWNWIND POINT
TIME (MIN) CONCENTRATION
AFTER PPM AT
RELEASE 2640 FT.
1 . so 0 . 00
1.53 0.00
1.57 0.00
1 . 60 0 . 03
1.63 0.34
1.67 3.57
1.70 30.33
1.73 2t:’5.4 1
1.77 1110.91
l. () 4797.35
1.83 16541.65
1.87 45542.29
1.90 100117.40
1.93 175736.90
1.97 246306.40
2.00 275642.60
2.03 246306.40
2.07 175736.90
2.10 100117.40
2.13 45542.29
2.17 16541.73
2.20 4797.35
._) — —r i i
._. .LJJ •
2.27 205.41
-
2.37 0.34
2.40 0.03
2.43 0.00
2.47 0.00
COMPOUND NAME : CHLORINE
COMMENTS 1 RAIL CAR
STABILITY CLASS
SOURCE STRENGTH • LB 180000. 00
EFFECTIVE SOURCE HI. • FT : 0.00
AVERAGE WIND SFEED. MPH 1s.ot:
ATMOSPHERIC MIX HEIGHT, Fl: 5000.00
INITIAL PUFF WIDTH, FT 0.00
INITIAL PUFF HEIGHT. FT : 0.00
AMBIENT TEMFERATURE. DEG F: 77.00
ATMOSPHERIC PRESSURE • MMHG: 760.00
SAMPLING TIME. SECONDS : 0.00
64E
-------
GROUND LEVEL CONC. AS A FUNCTION OF TIME AT 4 SPECIFIC DOWNWIND POINT
TIME
(MIN)
CONCENTRATION
AFTER
PPM AT
RELEASE
5280
FT.
7.00 0.00
3.07 0.00
3.13 0.00
3.20 0.00
3.27 0.01
3.33 0.16
3.40 1.79
3.47 15.18
ioo.o5
512.91
3.67 2044.87
3.73 6339.99
3.80 15286.44
3.87 28662.83
3.93 41795.30
4.00 47394.71
4.07 41795.30
4.13 28662.83
4.20 15286.44
4.27 6339.99
4.33 2044.88
4.40 512.91
4.47 ioo. 05
4.53 15.18
4.60 1.79
4.67 0.16
4.73 0.01
4 . 80 0 . 00
4 . 37 0 . 00
4 . 93 a . 00
COMPOUND NAME CHLORINE
COMMENTS : 1 RAIL CAR
STABILITY CLASS
SOURCE SrRENGTH, LB :X1B0000. Oo
EFFECTIVE SOURCE HT. • FT : 0.00
AVERAGE WIND SPEED MPH : 15.00
ATMOSPHERIC MIX HEIGHT, FT: 5000.00
INITIAL PUFF WIDTH, FT 0.00
INITIAL PUFF HEIGHT, FT : 0.00
AMBIENT TEMPERATURE, DEG F: 77.0(
ATMOSPHERIC PRESSURE, MMHG: 760.00
SAMPLING TIME, SECONDS : 0.00
64F
-------
62 . Oc) 0 . 00
62 . 50 c,
63.00 0.00
63.50 0.00
64.00 0.Oc)
64.50 0.01
65.00 0.03
65. 50 0.09
66.00 0.21
.66.5 1 ) U.46
67.01:) 0.96
6750 1.85
68.00 3.34
68.50 5.62
69.00 8.82
69.5C) 12.91
70.00 17.64
70.50 22.48
71.00 26.74
71.50 29.67
72.00 30.71
72.50 29.67
73.00 26.74
73.50 22.48
74.00 17.64
74.50 12.91
75.00 8.82
75.50 5.62
76.00 3.34
76.50 1.85
77 . 00 0 . 96
77. 50 0. 46
78.00 0.21
78.5t: 0.C)9
79 — 0 . 03
79.50 0.01
80 . 00 0 .
So . 5’) 0 . 00
81 . oo 0 .00
81 . 5: . (1 1)
COMPOUND NAME : CHLOR I NE
COMMENTS 1 RAIL CAR
STABILITY CLASS
SOURCE STRENGTH, LB %18oO )c) .00
EFFECTIVE SOURCE HT.. FT 0.00
AVERAGE WIND SFEED MPH 15.00
ATMOSPHERIC MIX HEIGHT, Fl: 50C)0.00
INITIAL PUFF WTDTH FT 0.00
INITIAL PUFF HEIGHT. FT : 0.00
AMBIENT TEMF’ERATURE, DES F 77.00
ATMOSPHERIC PRESSURE, MMHG: 760.01)
SAMPLING TIME, SECONDS : 0.00
GROUND LEVEL CONC. AS A FUNCTION OF TIME AT A SPECIFIC DOWNWIND POINT
TIME (MIN) CONCENTRATION
AFTER PPM AT
RELEASE 95t)40 FT.
64G
-------
GROUND LEVEL CONCENTRATION FROM INSTANTANEOUS (PUFF) RELEASE
TRAVEL TIME DISTANCE 7500 FT SOURCE 7500 Fl
MINUTES FEET
0 I ————+————+————+————+————o————+————+————+————+————!
56.8 5000
113.6 10000
170. 5 15000
227 .3 20000
284.1 25000
340.9 29999
LEGEND
* - INDICATES AREA WHERE CONCENTRATION IS OVER 30 PPM
GRID INCREMENTS ———:: X= 5000 FEET AND Y= 300 FEET
PLOT I NTERPRETAT ION
THE PLOT DEPICTS THE MOVEMENT OF A CROSS SECTION 0F THE PUFF. THE FLOT sHow ;
TRAVEL DISTANCES AND THE TIME IT TAKES THE CROSS SECTION TO REACH EACH LOCATIC’
THE CROSS SECTION IS SHOWN AS A PROFILE LINE (****) WHICH REPRESENTS THE
MAXIMUM WIDTH OF THE F’UFF WHERE THE SPECIFIED LEVEL OF CONCERN IS EXCEEDED
IT CAN BE ASSUMED THAT THE ACTUAL PUFF AT A GIVEN TRAVEL TIME AND
CORRESPONDING DISTANCE. Is CIRCULAR WITH A RADIUS EQUAL TO THE CROSS SECTION
cOMPOUND NAME CHLtJR I NE
COMIIENTS I RAIL CAR
STABILITY CLASS 1
SOURCE STRENGTH. LB : 1B0000.O0
EFFECTIVE SOURCE HT. • FT : 0.00
WERAGE WINO SPEED, MPH .1..
AThOSPHEF: IC MI X HEIGHT • FT: 5000 .00
DJITIAL. PUFF WIDTH. FT : 0.00
INITIAL PUFF HEIGHT, FT : 0.00
AMBIENT TEMPERATURE DES F: 77.00
4TMOSPHERIC PRESSURE. MMHG: 760.00
SAMPLING TIME, SECONDS : C).00
64 1- i
-------
GROUND LEVEL
CONC. AS A FUNCTION OF TIME AT A SPECIFIC DOWNWIND POINT
TIME (MIN)
CONCENTRATION
AFTER
PPM AT
RELEASE
2640 FT.
10.00
ii. .00
12.00
1:.. 00
14.00
15.00
16.00
17.00
13. o O
19 . 00
20 .00
21 .00
22.00
23.00
24.00
25.00
26.00
27. oc’
28 . 00
29 . 00
30 . 00
00
32.00
33.00
34.00
35.Ot )
36.00
37 . C I I : :)
t)0
.39 . oo
40 . C x)
41.00
42 . 00
43 . 00
44.00
45.00
46 . 00
47.00
43 . 00
49. L’ O
0.00
0.01)
0.00
0.00
0 .00
0.00
0.00
0.01
0.08
0.53
3.01
14.48
59.04
204.03
597.67
1483.94
3122.91
5570.52
3422.10
10792 .83
11723.04
10792 .82
3422.10
5570. 51
3122.91
1483.94
597.67
204.03
59.04
14.48
3.01
u.53
0 . 08
0 . 01
0 .
o . 00
Cx)
o . 0(3
C) •
00
:1
SOURCE STRENGTH. LB
EFFECTIVE SOURCE HI. • FT
AVERAGE WIND 5PEED. MPH
ATMOSPHERIC MIX HEIGHT, FT
INITIAL PUFF WIDTH, FT
INITIAL PUFF HEIGHT, FT
AMBIENT TEMFERATURE. DEG
ATMOSPHER IC PRESSURE, MMHG:
SAMPLING TIME. SECONDS
7.18C)0C>0 .1)0
o .
1.C)C )
5(300 . Qt)
0.1)0
0.00
F 77 00
760 . oo
0 . 00
COMPOUND NAME
COMMENTS
STABILITY CLASS
: CHLORINE
1 RAIL CAR
641
-------
GROUND LEVEL CONC. AS A FUNCTION OF TIME AT A SPECIFIC DOWNWIND POINT
TIME (MIN) CONCENTRATION
AFTER PPM AT
RELEASE 5280 FT.
40 . 00 C). 19
41.00 0.47
42.OC) 1.11
43.00 2.49
44.00 5.35
45.00 10.94
46.00 21.36
47.o (:) 39.86
48.00 70.99
49.01) 120.75
so . 0 (3 196. 10
51.00 304.12
52.00 450.33
53.00 636.75
54.00 859.70
55.00 1108.32
56.00 1364.36
57.00 1603.73
58 .00 1801) .02
59.00 1929.14
60.00 1974.21
S1.O () 1929.14
62.00 18(X) .02
63.00 1603.73
64.00 1364.36
65.00 1108.32
66.0(3 .959.70
a7 .0o 636.75
68.00 450.33
34)4.12
70 . (:) J 196 . 10
71 .00 120.75
72. 0 ) 70.99
73.00 39.86
74.00 21.36
75.00 10.94
7 6. o O 5.35
77.00 2.49
79.4)0 i. li.
79.o (:) t) .47
COMPOUND NAME : CHLORINE
COMMENTS : 1 RAIL CAR
STA9ILITV CLASS
SOURCE STRENGTH. LB :X lB 00 0 0.c)0
EFFECTIVE SOURCE KT. • FT : 0.00
VERA( E WI NO SPEED. MPH 1 .00
ATMOSPHER IC MI X HE I GHT FT: 5000.00
INITIAL FUFF WIDTH, FT 0. OC)
INITIAL PUFF HEIGHT, FT : 0..00
AMDIENT TEliFEF:ATURE DEG F: 77.oc
ATMOSPHERIC PRESSURE. MMHG: 760.00
SAMPLING TIME, SECONDS : C)C)C>
64J
-------
GROUND LEVEL CONC. AS A FUNCTION OF TIME AT A SPECIFIC DOWNWIND POINT
26 ’:) . 00 4 . 66
262.00 5.62
264.00 6.71
266.00 7.93
268.00 9.28
270 .00 10.76
272.00 12.36
274.00 14.07
276.00 15.85
273.00 17.70
280.00 19. 56
282.00 21.42
284.00 23.24
286.00 24.96
288.00 26.56
290.00 28.00
292.00 29.23
294.00 30.22
296.00 30.96
298.OC) 31.40
300.00 31. .55
302.00 31.40
304 . 00 30 . 96
306.00 30.22
308.0’:) 29.23
310.00 28.00
312.00 26.56
314.00 24.96
316.00 23.24
318.00 21.42
320.00 19.56
322.00 17.70
324.00 15.35
326.00 14.07
328.00 12.36
33 0.oo 10.76
332.00 9.28
7.93
. .
338.00 5.62
COMPOUND NAME : CHLORINE
COMMENTS 1 RAIL CAR
STABILITY CLASS : 1
SOURCE STRENGTH. LB :7.180000.00
EFFECTIVE SOURCE HT. • FT 0.00
AVERAGE WIND SPEED. MPH : 1.00
ATMOSPHERIC MIX HEIGHT, FT: 5000.00
INITIAL PUFF WIDTHS FT 0.00
INITIAL PUFF HEIGHT. FT : 0.0’:)
AMBIENT TEMPERATURE. DEG F: 77.00
ATMOSPHERIC PRESSURE. MMHG: 76O.OC
SAFIFLING TIME. SECONDS : 0.00
TIME
(MIN)
CONCENTRATION
AFTER
PPM AT
RELEASE
26400
FT.
64K
-------
APPENDIX VIII
Mill Plot Plan
65
-------
ENVIRONMENrAL PROTECTION AGENCY
MILL AUDIT, INTERNATIONAL PAPER CO.., JAY, IIAINE
‘ U i
11
-------
APPENDIX I
Hazardous Substance Storage
66
-------
IIJLL.. I-4LIIJLI, £NI .KN141 UNRL PAP .PC LU. JHY, MRINE
HAZARDOUS SUBSTANCES AND STORAGE
Wood and Fuel
MW O i Pt leA
MW DUpe PU.P
MW Dupe Pile C
MW Du os Pile 0
U I , DUpe Sl1o1, I IJ
M1FD i s Sila2 , J
MIF Duos 511o3,91
MW Doe S11o4, J
C _______ _______ _______ ________ _______ _______
TYPE hazard 11 1175 1LY /Lrt D
MW
MW la d
MW 0.. .4
MW lowiduood
MW 4 d
MW Røw uood
UIF lo d
MW Duos
MW DUps
MW Dupe
Dupe
/He. TYPE D1 .
Tr i ck
Rail
Totsi
Cold duck
CoLd duck 2
Cold duck 3
Cold duct 4
Truck
Rail
Total
—+ lMT 1—:———I 2ImT 2—
Fuel Cords —
Fuel Cords —
Fuel Cords 2 ,500
Fuel Cords —
Fuel Cords
Fuel Cads —
Fuel Cords
Fuel Cueite —
Fuel Cueits —
Fuel Cor its —
Fuel Cosits 3,000
Q50 __
4 S&F i40’
I’Si , x4*’
I’P&H 140’
Sh siO’
cg,itu —
Cositi —
CUts —
Catits —
Cimits —
Cueits
Cuelts —
Fuel
Fuel
Fuel
Fuel
Fuel
Fuel
Fuel
Fus I
Fuel
Fuel
Fuel
“452
2,710
14,000
13,000
162
aol
201
100
MW hut & last. Truck
MW lark & Masts Rail
MW lark I Mast, Total
VOl lark I Masts lii
MW lark 1 haste Outude 1
MW Bsrk$ Mist, ztaid. 2
V I I Heavy Oil Staq. Oil
V I I Heavy 011 Its Oil Oil
-------
.l’IV .L rcLu Il’1t.J’4 I I - IL I-’I’CU I I SUN MI. .NL V
MILL AUDIT, INTERNATIONAL PAPER CD ., JAY,
HAZARDOUS SUBSTANCES AND STORAGE
Groundwood and Pulp
M AINE
TW 1 1—I.S E—--: l—0EU U —:
TY Huard (JUTS 001LY (014*1k /L /P€j TYPE 0I I.
CDP flY :—-4(4J T i—:———+ v T 2—:
IS, 400 ____ ____ ____
6,160 __ __
15,400 ____ ____ ____
a—n. i t —
IS MID b&-) I S4O4 ( SB
BPS IS Liv,1 l .—2 IQS’04 (SB
BPS C-Ti. 100. 638/3/2120 C12 • 01(2 (SB
BPS Uuiw 150 5.aj C22 • p 11 (2 (56
BPS 2—lw 205 606/11/828 CLIC • p1010 ( 56
BPS 25D S..J C1.)C + 0010 ( 56
0-T ,r 405 588110/882 C102 • p14 (5 (56
BPS WoIw 455 5.i1 C12 • 01C5 1 56
B—B1s P1aM
15111 5
ISLrno l
C—lw 1011.
C—lw 1082.
Wp1r I Sul
6—lw 208 482/W602
H-Tw 308 460/12.5/554
r 355 S.al
b-lw 409
455 Sial
10
10
230
__ __ 28.530
.1,, U. Fl. 11.90 30’ 21.308
.zn UO Fl. 11.58z30’ 21,308
— F&o i6o .72 108.284
— ______ !OdxlO’ 17,624
Ii ,’ U. Ft .o 17.SdxlOS 188.911
______ lb Na20
______ lb K O
650 lb C12
5 l lbCl2
5,419 lb C12
367 lb C12
1,686 11 C102
i V-MITE
SI V-MIlE
SI V-MiTE
Tr
St.rq.
I 4—>S02 Bum — —
I 4—) 502 4400 8
lQ b4—) 0 70
10
2
SO — bino
2,200 ,000
2,200 8,800
2,200 ,000
.LPDS
5-W MILL: 65005155 —
650/10 Dr Stk SV Kvr Dig *—) I S.OI (56
: 630/10 5- Stk Ilila. lm b a.—) 1 S.G( I
630/10 Dr 91k 12 ha. Ta,* 4 .—) IQS.GI (56
K, t , Knot lot I (.—) I€S.G4 (56
P 15 5- S Ib Flit. I I r Sul EL—) I S.OI ( IS O
015 5- StI Fill. $2 IJuJw 5 &l US.—) )2S.GI ( 56
P15 750/1.1 PS Dr. S laM EL—) IQ1 OI 156
P15 5 SIb D I. (St 181 Dent 18.—) 1* 5 .04 156
P15 S. c. 5cr. D ii 181 Tai*
D-P1A) 1111.1. 680 05155
P15 680/20 5 Stk S I k ’r Di 18.—) 1* 5 .04 (55
P15 10% 5 Stk Sd. Ua w IS.—) 1*5.04 156
P15 5 SIb Flit. 181.—) 1*5401 556
P15 84 LS 120 551 910% 15.—) 1*5.01 (558
P 15 g1i. Flit. US.—) 1*5.04 (58
975 6PM
97 5 6 DM
975 6PM
7905 D M
7,735 6PM
7.755 6DM
io,av 6DM
v.500 6PM
5506DM
1,020 6PM
233_
TaM
laM
laM,
24’0x47’
139,042
122,205
lb 55
18,934
lb K’S
— laM
?4 ’di47’
559.042
53.585
lb 11.20
7.547
lb ) S
- lank
2*’da47’
139.042
32,93
lb 11.20
7347
b l S
—— Tan.
i2’d .13’
10,998
lank
40’raSO’
469.983
152,349
lb 11.20
22.302
lb 4425
— TaM
—
34’ doll)’
201728
66.644
lb 14 .20
lbNa20
lbKa2O
9,666
lb 1425
lbHZS
lb l S
— lank
18’dalO ’
19,034
lb Na20
lb 142$
24’dx47’
159,042
371,703
287,770
$1900
138.205
2,004
250,067
71,170
lb 55
lb 11.20
ibUa2 O
lb 11a20
lb 11.20
18,934
44,251
34,259
9,730
lb 4425
lb HZ’S
LbI€S
lb 1429
lb H2S
— Uo 1w
38 .04
80,560
1,411
lb Na20
lb 11.20
lb 0.2
107 .zn
88.382
4,054
lb MaOl
530 .1.
114,660
956
lb C102
US.-) 1* 5+04 USD
900/3.9/1912 IlL—) 1*5.04 t iM
900/3.5/2043 Cl2.p1l(2 (SB
500/3.5/2043 Cia .04(2 (558
C12.p 14 42 (SB
.c + o:o iiM
Marl • 0010 (55
Na l .0010 (56
460/10.7/641 : • oII&5 (556
• 04 5 US C
__ tbNa
__ ibM a 2 O
__ IbH2S
__ lb 442$
459 2bHaCJ
-------
V 4 I •—.i_ P r%I .J I • 4 IJI 4% P4I... V
MILL AUDIT, INTERNATIONAL PAPER CO , JAY, MAINE
HAZARDOUS SUBSTANCES AND STORAGE
Bleach Chemicals Preparation
TER1 . :—t AZ—; —c€UVERV-—; ST0R
TY H az ard fl .Y N*.m II. D iI o. TYPE DIPU . ITY. :— zi T l—:——--4 Z? T a—:
.O II S TI
Odaris.
C12, Li .s ê-40 T care C1Z, Iiq • qascarslt 120 42,000 _____ — _____ 360 720,000 lb ClE
c12, Uq.i 3-Vaps zcr T2, 11 • as1ar. —
Caustic Soda
NuOl, 50%s 1—100 T car N l, 50% ears — — ______ ______ ______ iOO 100,000 lb tIaOl
Na I, 50%.’ 2-tank, kaa4. 50% — — Tink 2-tB’ta24 91,3 .5 562,916 lb ka 4
. ‘ 2-task, l 4 . — — ____ — TOM e-rd 16’ 12,032 5.296 lb NsL14
lariti
C12 3l ous T . M 1, d i i 156 — Tank 12’dalG 13.621 3,510 lb C12 3.861 lb NaCJ4
Hy Stora 6aX , 40 qpl 156 —
Liquid Odizer Toi 2, 326
P C1 Plai*
I 4. 1—23 T Tr ,, k S04, 93%. Lbs —— -— ______ 6,000 45.030 lb H2S04
• 04. 4, 96% Lbs ____ 46.000 45. 02’) lb 142S04
N a 1 ) .pu , Car WaCI. Dry Lbs — — 60 Car ____ 90,000 ____ ____
NaCI Prep Ta,* NaC1, Soin 156 — — I-Tank U.S’x30’ 32,120 ____ —
lank MaC I, Soin 156 — — — 1-Tank 13.5s29’ 29,979 _____ _____ _____ _____
NaClO4. 4—100 1 Ca-s NaClD4, dry t.bs — — 4— Cars _____ 6O0 000 _____ _____
R I . ,. laik MaCjO’ ,, sal’s 156 — — ______ 2-Tanks 13 ..S’dxZ2 47,110 _____ —-
62 Storages hilt KaC G4, sot’n t56 — — — 2-Tanks 13.5’6s28 59.953 ____ ____ ____
Fir e 2-Tanks 1L3’daZI 53,956
SWSon erator . (56 -— ____ —-
øDpi TaM I S O __ __ __ __ __
Salt Cakes Disuolv. Tank 156 —
Cl e Rb . ... bar C2 , Bqpl ISO ___ ___ ____ ___ ___
TaM, C1 , pl ISO — 2—Tanks 10’daZS 29,374 1,960 lb Cl02
Task, FRP C102, $ p1 ISO — 1—Tanks 30’d 30 152,619 10,533 lb C102
C IZ NaZ1,406 ._ —
-------
V J. I II I II . 1% J I I I i p— i I
MILL UDXT, INTERNATIONAL PAPER CO.., JAY. MAINE
HAZARDOUS SUBSTANCES AND STORAGE
Black Liquor
•i. ua
A-tj,is
UIL/Soaol T
laM
Soap Co1l,ct..TmM
Eva a.. 6—,ff.ct
Sual TiNt ’ T14—V—t1
50% .. TaM
634 .. T..ik
.—Salt Cak.4M1a TaM
PK $.4 N a TaM
Diuolv. TaM.
U0% Ra Iø S t
(10% 1Ia1J4.lJ (E8
(10% Ma 4$ 1 G
)10% lIa kI 1
(10% NaGAWQS L 6
> % QS L
$4 tSS
125% $a M US6
>15% Ma0+KS lEG
INS. TflE DIIEN.
I-TaM 36’ea 0’
— 1—TaM 40’dxlO’
— 1-TiM 12’d 2O
1—TaM 30’dxl&’
—— 1-laM 18 ’0X25
L1Soap’ TaM
Soap o11ect.aTaM
Soap Star. TaM
zd.Tsr. ’ F T.i*
E ’ &
9.1 .1 la ii ’
. . St . TaM
634 . — T i
.—Sa1t tak,IlI1z laM
1p.’ Ku TaM
I. M i. TiNt. 66-9
. S .
D1,a.Iv. TaMe
(10% IU l44$ (SE
(10% PUD4$ (55
(10% lIaO+ ’KS LEG
(10% S (55
10% IUO44 LEG
110% MaQ4$ S 155
251 i: LEG
>25% 155
>25* NaOM 15$
>25* 155
125* N (SE
>25% MaO . 1 LEG
15* NaD4+KS LEG
— I—TaM 24’dx26’
— l—Taeà ______
— 1-TaM __
—
— —liitk ______
— 1—Tank ______
— 1—TiM ______
!7,981 134.382 lb N&20
_______ _______ lb Na20
> TU L .
TY Hazard LMTS DAILY l1.R..i’i tLO
PQC TY
:—4 ZMT
—$ ZMT
a——:
e.549
105.542
lb I (aZO
l KS
375,987
130,299
lb 1 1a20
lb KS
16.919
5,863
lb Ha20
lb KS
190.343
276,885
16Ha20
36,9%
1bK S
7,586
1.7.219
lb N .20
12.214
lb H
— 2—Tank 45’dxIO’
I—TaM 11’da20
I—Ta,* l0 ’dxZl
951,716
14,217
25,981
4,927
10,383
lbNa 2O
lb ka20
lb P 1 . 20
634
1,462
13,025
lbKS
lb KS
IbKS
lbKS
-------
V 4 1% • I9 j I b— $. P I I £ LiS I .4I L V
MILL AUDIT. INTERNATIONAL PAPER CO.., JAY,
HAZARDOUS SUBSTANCES AND STORAGE
Pulping and Recausticizing Liquors
MAINE
TYPE
‘ .ST1CX2II
tilE SI
Grtuo Uucr . S or19.
Gr U uor . 1aih.r
L Uguor wt Hadi
lint, Uquop. Cauot3c zrs
l&,jtt U uur . ci iri.i
lJutq UuoorO Storaq ,
Sp wlL ciarfi ,r
Nultiøir c,. Stora.
N d Washur
*ad Storaq.
F*itsr
Silo
ak lIa Storag.
Liuo Mikauo
)15% Ha04 S
15% iI tSG
15% NaO444 1
115% HaDI$ 1 G
115% Na 44+ ISG
115% Na3I4I4 L
115% Ha 4 I !
115% Na 4 LSG
Dii. Casstlc
Dii. aastic
Dii. Caustic
Dii. Caustic
Dii. Caustic
i—Tas Ii ‘dz24’
— 1-Tark 40’duW
— 1—Tadi 2D’dx2I’
— 4Tinki 16’dxID’
I -TarU 40’ dii26’
1 -1aM, ‘ 0.24’
—— 1-T rk ‘d .24’
— 1—Tan, 5’dLiG ’
—— -Tan4t 20 ’daIS’
173,719 173, 181
172.719 ______
187,112 ______
42,299 —-
u,E
‘,e . Liquor. Storap
Gre. ,, Liquor. C3 f it,
Grist Up — Hads
lint, Liquor. Causticizirs
lint, Liquor. aifi,r
18üt Uqusr. Storage
Mud Hadior
Lie. Mud Storag.
Lie. Filtor
Lie. Silo
HaaklJuh Storage
>15% NaG4$ %SG
>15% Na04 ’IES t
>15% NaG4$ USC
15% M S L
>15% Na 4+ LSG
>15% Na 444 USC
Dii. Caustic
Dii. Caustic
D I I. Caustic
Dii. Caustic
Dz1. Caustic
I—Tank 40’ dxE4’ 2 .
1—Tank 60’dz36’ 486A33
I —Tank _______ ________
3—Tanks 16’dzIO’ 45,118
— £—Ta,,a , G0’di.36’ 1,522,746
— I-Tank 40’dx2S’ 244,391
— 1—Tank 20’duli’ 42,299
I-Tank ‘d .ei’ 172.719
Ha zard 18 111$ lILY sS.$ ./k IL D
——DELiVERY——-:
I c. TYPE DIPEN. P ITY :—+ Z T 1—- :—-l ZNDT 2—-:
lb I 5
ib lES
lb S
172,719
173,181
lbNaZD
22,726
244,39!
245,045
lbMaZO
33,57!
61,0%
.
60,158
60,319
lb KaZO
8,264
244,39!
245,045
lbN .20
33,571
lb Na20
I—T?nb ‘d .? ’ 172.719
226.195
ibWa2O
30,989
I S
487,733
lb 1 1.20
66,819
lb 142$
15,080
lb 11.20
2,066
lb H2S
763,409
lb 11.20
104.587
lb 1425
-------
APPENDIX X
General Kraft Pulping Schematic
67
-------
JW .1 I%LJP419 .N II I’PCU $ L.. I .1 UPI H$ .NLY
MILL AUDIT, INTERNATIONAL PAPER CD., JAY, MAINE
w$t
Urn. Mud
Th
put,
C-
C4dan*atS
Uquor
Ste aq.
-------
APPENDIX X I
Pulp Process Hazardous Substance Summary
68
-------
ENVIRONMENTAL PROTECTION AGENCY
MILL AUDIT, INTERNATIONAL PAPER COW, JAY, MAINE
MATERIAL
1.. WOOD & FUEL
Round Wood
Chips
Waste Fuel
HA2MAT
CAPACITY
HAZMAT
2. GROUNDWOOD
V-BRITE
H2S20 4 - >S02
30,800 lb.
21,560 lb.
4. BLEACHING
Ti OA
T4OA
T1OB (2)
T4 ’DB
Chlorine Cars
Caustic Cers
Caustic TanI s
Ceustic Tar ks
Hypochiorite
Oxygei
Sulfuric Acid
Chlorate
R2 Solution
Methar ol
Chlorine Dioxide
C12
50’: NeOH
50’ NeOM
5” NeON
4” NeOC] .
100 02
98 K S0
Ne 2 C104
N82C I04
CH3OH
C 102
46,000 lb.
800,000 lb.
60,000 USG
188,000 USG
45,000 lb
800,000 lb
396,000 lb.
12.000 lb.
6. 8LACK lIQUOR
Weak L (15’:)
50 BL.
63’: BL.
Green Liquor
White Liquor
H 2 S
H 2 S
CeO
1 ,128,000 TJSG
2 • 200 ,000.USG
155,000 lb.
196,000 lb.
3. PULPING
A Digester
A slow Tanks
A Filtrate
B Digester
B Washer
B Filtrate
WBL-->H2 5
WBL--H2S
WBL-->H2 5
WBL-- >H2S
W L-->H2S
WBL-->H2S
Cl 2
C 102
C 12
Cl 02
160,000
320 , 000
670,000
160,000
372.000
287,000
80,000
114,000
46,000
189,000
360
100
91,000
12,000
5. CHEMICAL PREPARATION
USC
U SC
USC
USC
USC
USC
USC
USC
USC
USC
TON
TON
USC
USC
18,900
15,000
32,000
18,900
44,000
34,000
1,411
1,000
1,200
1,700
720,000
100,000
583,000
5,000
lb.
lb.
lb.
lb.
lb.
lb.
lb.
lb.
lb.
lb.
lb.
lb.
lb
lb
H-’S
H2 . .
H2 5
7. LIQUOR PREPARATION
60,000
lb.
lb.
Lise
-------
APPENDIX XII
Kraft Pulping Process/Pulping
Liquor Terms and Properties
69
-------
—. V 0 • e S i — . ——
MILL AUDIT, INTERNATIONAL PAPER CO.., JAY, MAINE
DEZCRIPTION •‘A” LINE LINE
Wood Softwood Hardwood & Softwood
Digester Kamyr SV Kamyr SV
B.S. W aahera DiIf. & Drum Diffusion
Unbi. MD
Bleaching CEND CEHD
C 102
Bleached HD
Recausticizing 2-green & white liquor lines
2-lime kiln lines
Recovery & Power :
Evaporators 2-sets with concentrators
Rec v. Boilers l-B&U; l-CEJGoteyark
Power Boilers 2-oil, 1-waste fuel (bark)
Steen 1,400 kLb/Hr high pressure- auperheated
Power & distribution, MW:
5j .. 12.800 vac ___ “ B” “ C” . ‘OTAL .
Turbogeneretor 30 25 30 85
Hydrogeneretor 10 10 10 30
Purchased 15 15
Total 55 50 40 145
Term Definition Units
(1) Total Alkali Total of all ‘viabie” sodium alkali cãmpounds. i.e. NaOH + g/L as Na 0
NatS + Na 7 COa + NJeSO + Na 7 S 7 0 1 + Na,S0,
(Does not include NaCI)
(2) Total T tratabl. Total of NaOH + Na 1 S + Na 2 CO, gIL as Na 2 0
Alkali (TTA)
(3) Ac ve A kall T:tal :1 NaCH + Na 1 S git. as NatO
(AA)
(4) Effective Alkali Total of MaCH + 1/2 Na 2 S g/L as Na 2 0
(EA)
Ra :! AA : A expressed as %
(5) Causticity Ratio of NaOH to NaOH + Na CO 3 % (on Na 2 0 basis)
(7) Sulfldity Ratio of Na,S to AA (or to TTA) S (on NatO basis)
NB: The basis of sulfidity must be defined in cacti case.
(8) Causticizing Same as causticity. (However, th. concentration of NaOH in S (on NatO basis)
Efficiency the green liquor should be subtracted so that the value of
(White Liquor) NaON represents only the pørtlon produced by the
causticizing reaction.)
(9) Residual Alkali concentration determined by acid titration. gIL as Na 2 0
Alkali
(Black Liquor)
(10) Reduction Ratio of Na 7 S to all soda sulfur compounds (sometimes S (on NatO basis)
Efficiency simQlified as ratio of NaPS to MaSS + Na 1 SO .)
(Green Liquor)
-------
APPENDIX XIII
Bleaching Vapor Collection
70
-------
I:
• I.
• I
I.
-
.
ii I - -
- —... . qr — - —
‘e,o . • ‘ •.
-9
SCcC. Ss3CI
-.-
r ii U
See.A,o44. -.
1 g 0
p
• - • —0
S
I
-------
APPENDIX XIV
Environmental Response Team Report
71
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
£DI$ON. P4LW JtR$Ly 0 1127
June 22, 1988
METIORANDUN
SUBJECT: International Pape
Safety Audit
FROM: Vickie L. S
Env i ronment a
TO: Steve Novick
US EPA Region I
This past April the USEPA Environmental Response Team took
part in an extensive safety audit conducted by the Environmental
Protection Agency, Region 1, at the International Paper Company in
Jay, Maine. The audit was performed due to several reports of
hazardous substance releases during the past year at the mill.
During the audit, several documents were requested from I.P., some
that were not available at that time. After the On-Site audit had
been completed, I brought the documents dealing with the mill’s
safety program, training program, and emergency response program
back with me to further evaluate them. I had also requested
additional safety training information in the form of a chart
depicting all the training courses, what the training consisted
of, who was required to take the training and how often. Although
I did receive some additional information from the mill, it was
not the information I had requested earlier. My overall comments
on the audit, the documents I brought back with me and that I
received in the mail, and some general recommendations for the
mill are contained in this report.
The mill’s structured safety program appears to be in its
initial phases. It was initiated only six weeks prior to the
audit and it is currently being implemented. Overall, the mill has
made good progress in the development of a safety program. I sug-
gest, however, they would benefit by better organization of all
the program elements. For example: the safety program has been
split between an Environmental section and the Human Resources
section; the duties of each apparently overlap, and the mill uses
more than one contingency/emergency response plan. When all plans
are looked at together most of the bases are covered, but neither
of the plans is complete by themselves. I recommend that it would
be less complicated and confusing for everyone if all aspects of
safety and health: policies, procedures, records, training, etc.,
could be handled in one place in one safety and health plan for
the entire mill.
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I observed that International Paper Company has been training
their employees in On the job safety for many years, but a formal,
written training program, is still in its early stages. Some
training courses have not been completely developed, and employee
training records appear to be sporadic. Missing from the set of
documents I reviewed is a written Hazardous Communication Program,
and the MSDSs that were provided dO not fulfill OSHA’s hazard corn-
inunication requirements. It is difficult to make recommendations
in this area without additional information, Such as course con-
tent, frequency of refresher training, who is required to be
trained, etc. The information that was given to us on training at
the mill, which included a general training manual, a safety prac-
tices guide, the International Paper Safety Policy Manual, the
Pulp Mill Safety Manual-including mill “do’s and don’t’s”, and
sundry other unrelated training documents, all seemed to be fairly
basic, and no explanation was given as to where each fit in with
the other in the overall safety program at I.P. Therefore, I rec-
ommend a more complete written training program and record keeping
procedure to ensure that all employees receive the required train-
ing be implemented. All training Should be included in this pro-
gram, and it should be part of the Overall safety and health pro-
gram and the mill’s safety and health plan.
In the area of emergency preparedness and community right to
know, the mill is working very diligently towards community
planning with both of the counties on its borders. Despite some
in house difficulties, plans seem to be progressing well. The
mill has had funds approved for installation of the SAFER system,
which they plan on using for demonstration and planning exercises
with the communities. International Paper Company also has a plan
for developing a HAZNAT response team which will be available to
the bordering communities for emergency response.
International Paper Company has made plans for a solid HAZMAT
team. The documents should be more complete and detailed, but the
overall organization and management of the team is good. I
suggest that 6 to 8 individuals may not be enough for a team with
this responsibility. The fire brigade will be called in to assist
as a supplement to the team; however, in acting as a support orga-
nization, the fire brigade is an extension of the HAZ? T team, and
as such may require additional training and medical monitoring.
The following areas relative to the HAZMAT team should be
improved; explanations of exact training, risk evaluations, air
monitoring, and contingency planning. The who, what, and when’s
need to be identified. The actual location for equipment storage
should be identified in the plan, as well as maintenance
procedures. The equipment list is extensive, and it emphasizes
spill response kits or repair kits, rather than protective gear.
The plan only calls for 4 SCBA units. My site observations
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revealed several more units around the miii. I recommend th t
more be made available to the HAZMAT team, especially if the” viii
be expected to respond to emergencje off-site. In addition’ dif-
ferent types of protective suits Should be made available. CcIH
recommends the following suit materials for the contaminants on-
site:
Contaminant SUAt Materiais
Ammonia Ch or ne/ Butyl, Neoprene, Natural
Chlorine Dioxide Rubber, Saranex
H2S Butyl, Neoprene, vc
NaOH Natural Rubber, Neoprene
Nitrile, saranex
Sulfuric Acid Natural Rubber, Neoprene
Nitrile, PVC, Saranex
Phosphoric Acid Butyl, Neoprene, vc
Another reference for the Selection of chemical protective
clothing is the USEPA Guidelines for the Selection of Chemical
Protective Clothing, February, 1987.
The Respiratory Protection Program defined by International
Paper meets the requirements prescribed by OSHA 1910.134. However,
there are some issues which I recommend be included in the pro-
gram. I.P. depends upon the employee to maintain and clean their
respirator, however, I did not observe this happening at. the
plant. The respiratory program should address the following ques-
tions: Are there any periodic inspections? Are personnel fully
capable and trained in the maintenance of their equipment? Is
there a system for proficiency testing? Is there any refresher
training in the event long periods of time elapse between use? Who
does the training? Is there any monitoring of the work area while
respirators are being worn? Is there a periodic review of air-
borne levels of contaminants? What monitoring is performed during
emergencies? I suggest referring to OSHA 29 CFR 1910.134 for the
requirements.
I would also recommend that a lot more attention be focused on
dermal protection during emergencies and accident mitigation.
Along with additional dermal protection for hands, feet, body, and
limbs, I recommend a more detailed decontamination plan be insti-
tuted and followed for PPE and other equipment-especially after
accident mitigation.
The HAZNAT team plan included plans for a medical monitoring
program, but I did not find any other written program for the
other mill employees. This information could be missing from the
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docuJ efltS I received, and without it there is no indication that
the safety plan contains OSHA 1910 guidelines. is another facet
of a medical monitoring program, I would Suggest the mill have,
both posted and written in their plan-which is a sub-part of the
overall mill safety and health plan, symptoms of heat and cold
stress. This is especially true in the dryer building and during
the extremely Cold months of winter. For more information and
additional assistance in developing a medical monitoring program,
i recommend consulting with OSHA.
The mill’s monitoring program for airborne contaminants, and
the alarm system, augmented as it will be upon completion, seem to
be technically Sound and well planned. I was pleased to learn
that the mill is investigating perimeter monitors. On the other
hand, there did appear to be some problems during the simulation
exercise with alarms that could not be heard, and some areas were
identified that could and should have additional alarms/warning
devices considered. If the alarm System malfunctions, it should
become the highest priority to get it back in operation again.
Finally, I cannot recommend strongly enough that the mill
develop some way of performing pre-emergency risk analysis. In
the prevention of accidents, “prevention” is the operative word.
is you know, risk analysis is important and written procedures are
a necessity. My on-site visit did not reveal such documents,
which leaves me with the impression of a “reactionary” approach-
wait until something happens, then investigate it, then make
changes if necessary. Even the accident investigation procedures
did not appear to be consistent mill-wide and were not written
down and included in the mill’s safety and health plan. Some
questions that arise are: Who reviews the results? Is there a
formal report? Are records kept in a central location? Who
authorizes capital/procedural changes as a result of the investi-
gation? Many unanswered questions that could be answered in a
written policy/procedure.
There was reference to risk analysis programs in the emergency
preparedness plan, but no follow up report or survey was
presented. The only documents presented by the mill as risk
analysis programs were various industrial hygiene surveys
performed by outside companies-usually on a piece of equipment
purchased from that company, and they too raised some questions:
Did I.P. follow up on the recommendations? Were corrective
actions taken to mitigate the leaks and prevent further failures?
Here again, the reference to present leaks and failures indicates
a reactionary approach. Upper management have apparently been
introduced to survey/audit functions through the DuPont training
seminar, but a follow-up or action plan is not evident. A more
rigorous, periodic review of plant conditions and potential risks
is necessary and highly recommended.
In conclusion, International Paper Company has a strong begin-
ning in putting together and implementing their safety and health
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program. There are particular strengths in the Upgraded plans for
alarms and air monitoring, the plans for working with the commu—
nity, the development of their HAZ! T team, and possibly their
training program, although it’s difficult to tell by the informa-
tion presented. My Strongest recommendations are that the entire
safety and health program be organized more completely and in one
department or unit, and better records should be kept. I believe
that the information given to us in the several Contingency/ emer-
gency/safety plans can be consolidated. I also suggest investiga-
tion into protection from dermal exposure, expanded decontainina-
tion procedures, and most importantly, International Paper Company
should become a preventive mill verses a reactionary mill by
developing procedures for pre-einergency risk/hazard analysis.
Some additional general comments:
1) The evacuation procedures would be enhanced if maps
accompanied them. Also, a.thorough explanation of the entire
plant evacuation process would assist in evaluating an integrated
egress from individual areas.
2) Pictures and diagrams would enhance the respiratory
protection program.
3) A wider selection of personal gas detectors in the form of
real time monitors for the HAZMAT team would be nice.
4) The vessel entry procedure needs supplemental information
such as specific test requirements prior to entry, and is the
instrument calibrated and/or working properly?
5) How does 1.P. ensure subcontractor personnel have adequate
training, medical monitoring, etc.?
6) Are employees who are potentially e cposed to lead com-
pounds enrolled in a blood monitoring program?
CC: Ray DiNardo, Region I
Ellen Gilley, TAT
Rod Turpin, ERT
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