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James River Corporation - National

Develop PSM/RMP Program

James River Corporation operates 4 pulp mills and 7 smaller facilities throughout the U.S. The pulp mills are regulated under PSM/RMP for Cl2, ClO2, HCl, NH3, and propane. The smaller facilities are regulated for propane only. The consulting team of Universal Dynamics and ENSR were contracted by James River Corporation to review the existing PSM program and assist James River develop an RMP program that meets EPA's regulatory requirements for each of the 11 facilities.

James River Corporation - Camas, Washington

PSM Compliance Audit/Technology Review

James River receives chlorine in 90-ton railroad cars and distributes it to several locations throughout the pulp mill. The major systems that handle and use chlorine include a chlorine vaporizer, sodium hypochlorite manufacturing system, chlorine to hydrochloric acid burner, and three bleach plants. UDA was contracted to perform an evaluation of the adequacy of the equipment, technology, and operating procedures used for chlorine delivery. In addition James River requested a PSM Compliance Audit. In the performance of the work,UDA:

• Evaluated the components of the chlorine delivery system (i.e. rail car, air compressor, steam supply, etc.) for their ability to function as an integrated system and prevent major chlorine releases.
• Compared the delivery system with currently available technology for release, prevention, and containment.
• Determined the physical integrity of the delivery system.
• Determined the adequacy of release monitoring and alarm systems.
• Evaluated the adequacy of the operating, maintenance, and emergency response procedures.
• Compared the existing PSM program with EPA's Risk Management Program (RMP) and recommended an approach to compliance with the RMP.