Harcros Chemicals Inc. -- Houston - Executive Summary
EXECUTIVE SUMMARY |
1. Accidental release prevention and emergency response policies
In this distribution facility, we store 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, and the training of our personnel.
Our emergency response program is based upon the Chlorine Institute's Pamphlet 64, Emergency Response Plans for Chlorine Facilities. The emergency response plan includes procedures for notification of the local fire authority and notification of any pot
entially affected neighbors.
2. The stationary source and regulated substances handled
One of the primary purposes of this facility is to store chlorine and sulfur dioxide for distribution to our customers which include water treatment facilities and general industry. Chlorine and sulfur dioxide are received in 150 pound cylinders and 2,000 pound containers and are shipped in the same packages. Chlorine and sulfur dioxide are not used or repackaged at this facility. 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 90,000 pounds. The maximum total inventory of sulfur dioxide stored at this facility is 30,000 pounds. Average inventories are much less.
3. The worst-case release scenario and the alternative release scenarios, including administrative controls and mitigation measures to limit the distance for each reported scenario
t-Case Scenario - Failure of a 2,000 pound container of chlorine. It is assumed that the entire contents are released and vaporized in 10 minutes. The distance to the endpoint of 0.0087 mg/L is 1.3 miles as determined by the EPA's "RMP Comp" computer program.
Alternative Release Scenario (Chlorine) - The same as the Worst-Case scenario except the contents of the ton container are released during "average" weather conditions. This scenario is unlikely but provides a 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 the alternate release scenario 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.
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 no accidental releases that have resulted in deaths, injuries or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage or environmental damage.
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 discussed this program with Houston Fire Department. A representative of the Houston Fi
re Department visited this plant on April 7, 1999.
7. Planned changes to improve safety.
This distribution facility was constructed in 1955. 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.