Harcros Chemicals Inc. -- St. Gabriel - Executive Summary |
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ST. GABRIEL EXECUTIVE SUMMARY 2055 LDEQ Facility ID Number 1. Accidental release prevention and emergency response policies In this distribution facility, we handle chlorine and sulfur dioxide, which are considered hazardous by the EPA. The same properties that make chlorine and sulfur dioxide valuable as commodity chemicals also make it necessary to observe certain safety precautions to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as that of our co-workers, and to reduce the threat to nearby members of the community. It is our policy to adhere to all applicable Federal and State rules and regulations. Safety depends upon the manner in which we handle chlorine and sulfur dioxide, the safety devices inherent in the design of this facility, the safe handling procedures that we use, and the training of our personnel. Our emergency response program is based upon the Chlorine Institute's Pamphlet 64, Emergency Response Plans for Chlor ine Facilities. The emergency response plan includes procedures for notification of the local fire authority and notification of any potentially affected neighbors. 2. The stationary source and regulated substances handled One of the primary purposes of this facility is to repackage and distribute chlorine and sulfur dioxide to water treatment facilities and general industry. We also manufacture sodium hypochlorite (bleach) and sodium bisulfite as byproducts of the packaging processes. Chlorine and sulfur dioxide are received by rail car and used to fill DOT approved containers. Access to the site is restricted to facility employees, management personnel, and authorized contractors and visitors. The maximum total inventory of chlorine stored at this facility is 655,000 pounds. The maximum total inventory of sulfur dioxide stored at this facility will be 416,000 pounds. Average inventories are much less. 3. The worst-case release scenario and the alternative release sc enarios, including administrative controls and mitigation measures to limit the distance for each reported scenario Worst-Case Scenario - Failure of a full 90 ton (180,000 pound) rail car of sulfur dioxide. It is assumed that the entire contents are released and vaporized in 10 minutes. The distance to the endpoint of 0.0078 mg/L is 16 miles as determined by the EPA's "RMP Comp" computer program. Alternative Release Scenario (Chlorine) - A 2,000 pound container develops a leak and the entire contents are released (as a gas) in 10 minutes. This scenario is unlikely but provides a more reasonable basis for emergency planning purposes. The distance to the toxic endpoint of 0.0087 mg/L (as determined by RMP Comp) is 0.30 miles. Alternative Release Scenario (Sulfur Dioxide) - This scenario is the same as that for chlorine. A 2,000 pound container releases its entire contents in ten minutes. Again, this is very unlikely to happen and is being used for emergency planning purposes . The distance to the toxic endpoint of 0.0078 mg/L is 0.20 miles as determined by RMP Comp. The effects from more likely release scenarios would not extend far from the point of release. The effects from these alternate release scenarios extend beyond our property boundaries as required by EPA regulations. 4. The general accidental release prevention program and the specific prevention steps This distribution facility complies with EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations. This facility is operated in accordance with recommendations from the Chlorine Institute and with the Responsible Distribution Process of the National Association of Chemical Distributors. 5. Five-year accident history Within the past five years, this facility has had four accidents that qualify to be reported as part of the Risk Management Plan. Three of the accidents resulted in minor injuries to four employees. During the other accident, a smal l release (3 pounds) caused local responders to shut down the highway in front of the plant for a brief time as a precaution. As a result of this accident, several local residents have claimed vague "physical impacts". 6. The emergency response program This facilities emergency response program is based upon the Chlorine Institute's Pamphlet 64, Emergency Response Plans for Chlorine Facilities. We have coordinated this program with the Iberville Parish EPC. 7. Planned changes to improve safety. This distribution facility was constructed in 1977. We continue to participate in the Chlorine Institute and National Association of Chemical Distributors programs, and continue to improve our operations in accordance with Responsible Distribution Process guidelines. |