Petra Chemical Company - Executive Summary

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RISK MANAGEMENT PLAN 
Clean Air Act Amendments, Section 11(r) 
 
 
Executive Summary 
 
A.  Accidental release prevention and emergency response policies 
 
In this manufacturing facility, we handle chlorine, which is considerably hazardous by EPA.  The same properties that make chlorine valuable as a commodity also make it necessary to observe the certain safety precautions in handling chlorine to prevent unnecessary human exposures, 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, 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, in part, upon the Chlorine Institute's Pamphlet 64, Emergency Response Plans for Chlorine Faciliti 
es.  The emergency response plan includes procedures for notification of the local fire authority and notification of any potentially affected neighbors. 
 
B.  The stationary source and regulated substances handled 
 
The primary purpose of this facility is to manufacture sodium hypochlorite for customers.  Chlorine is received by rail car.  It is then used in the manufacturing of sodium hypochlorite.  This facility has equipment for unloading rail cars.  Access to the site is restricted to authorized facility employees, authorized management personnel and authorized contractors.  The regulated substance handled at this facility is chlorine.  The total inventory of chlorine stored at this plant is 180,000 pounds. 
 
C.  The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distance for each reported scenario. 
 
Worst-Case Scenario - Failure of a 90 ton railroad car of chlorine would release 180,000 p 
ounds of chlorine.  It is assumed that the entire contents are released as vapor, which is heavier than air.  The distance to the endpoint of 0.0087 mg/L (3 ppm) will be determined by the model you use. 
 
Alternative Release Scenario - A break occurs in the piping which delivers the chlorine to batching (blending) process.  The distance to the endpoint of .0087 mg/L (3 ppm) is determined by the conditions and the model you use.  This has the potential to extend past the facility's boundary. 
 
 
D.  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. 
 
E.  Five-year accident history. 
 
We had an accidental release of chlorine on June 7, 1997. The areas surrounding this facility were evacuated, and 23 workers in the surrounding industria 
l area received medical attention. No deaths occurred as a result of the release. 
 
F.  The Emergency Response Program 
 
This facility's emergency response program is based upon the Chlorine Institute's Pamphlet 64, Emergency Response Plans for Chlorine Facilities.  We have discussed this program with the County Local Emergency Planning Committee and the City Fire Department.  A representative of the City Fire Department and many of the emergency responders visited this plant on or about July 1,1997. 
 
G.  Planned changes to improve safety 
 
This facility was constructed in 1952, and it has operated safely for over four (4) decades.  We continue to improve our programs to insure the maximum safety for our employees and the surrounding areas.    As a result of the incident in 1997, all safety procedures and systems were reassessed.  This facility now utilizes three levels of safeguards to protect against an accidental realease: (1) perimeter/process area sensors with automatic shut-off of t 
he process using chlorine, (2) automatic shut-down system which is activated by loss of pressure or electricity, and (3) manual-remote shut-down system which can be operated from the processing area, the office area and secondary areas within the facility which are remote from the processing system.
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