H. Krevit & Co., Inc. - Executive Summary |
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In this facility, we manufacture sodium hypochlorite using chlorine and sodium hydroxide. The material that poses the greatest risk to our neighbors is chlorine. The railroad cars that chlorine is shipped in are extremely durable, and are tested regularly. The design has been gradually improved for nearly a century, with an excellent safety record. Our employees are trained in the proper use and emergency procedures to handle these railcars. We conduct both classroom training and hands-on drills in the appropriate use and emergency response procedures. The process that we use to blend chlorine with sodium hydroxide and water is automated, but we continuously monitor the process. The automated system has redundant safety features for automatic shutdown, including alarms. There are also several methods for manual shutdown. Similar plants are in use in approximately one hundred locations around the world, and information about "near-miss" incidents is shared and used for continuo us improvement. We have the equipment and training to shutdown automatically or manually, even during a release. It is our policy to observe all Federal and state rules and regulations, and to conduct all of our compliance efforts with a high level of quality. Chlorine is stored as a compressed gas, in liquid form. For reporting our worst-case scenario, we used the rupture of a chlorine transfer hose. Failure of a 90 ton railroad car of chlorine would release 180,000 pounds of chlorine. It is assumed that the entire contents are released as a vapor, which is heavier than air. The sdistance to the endpoint of 0.0087 mg/L (3 ppm) is 14 miles. In reality, if a hose were broken, and an emergency valve known as an "excess flow valve" failed to stop the release, the chlorine really would vaporize and be released to the air, because the boiling point of chlorine is very low. However, the scenario of an entire tank release is extremely unlikely and difficult to imagine, since the phys ical action of vaporizing cools the liquid, which substantially slows the rate of boiling, or vaporizing. This would give our staff and emergency responders time to react, and time to stop the release. However, even a chlorine release that is stopped within 30 minutes could be toxic to our nearby neighbors. Our alternative release scenario is a hose failure that is stopped in one hour. The distance to toxic endpoint is 0.3 miles. This facility complies the OSHAs Process Safety Management rules, and EPAs Accidental Release Prevention Rule. This facility is operated in accordance with recommendations from the Chlorine Institute. We had an accidental release of chlorine on Our emergency response program involves the training of our in-house staff in the properties of chlorine, and the use of Scott Air Packs and Chlorine Institute "C" kits, that we are always able to stop a chlorine release. It involves the notification of government authorities. We are careful to operate an d maintain our equipment properly so that there is no need for a response, but we are ready. We plan on tearing down a building near the railcars to eliminate that as a fire hazard, and on conducting coordinated response drills with our staff and the fire department. |