K.A. Steel Chemicals - Executive Summary |
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In this distribution facility, we handle chlorine, which is considered hazardous by EPA. The same properties that make chlorine valuable as a commodity also make it necessary to observe certain safety precautions in handling chlorine to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as that of our 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 upon the Chlorine Institute's Pamphlet 64, Emergency Response Plan for Chlorine Facilities. The emergency response plan includes procedures for notification of the local fire authority who will assist in notification of any potentially affected neighbors. One operation that we conduct at this facility is to repackage and distribute chlorine to water treatment facilities and general industry. We also use chlorine to manufacture sodium hypochlorite for customers. Chlorine is received by rail car. It is then used in the manufacturing of sodium hypochlorite, as well as in filling Department of Transportation ( DOT) containers for use by customers. This facility has equipment for unloading rail cars and equipment to fill DOT containers. We have a very experienced operational staff with an average of over 12 years per employee. Access to the site is restricted to authorized facility employees, authorized management personnel and authorized contractors. The regulated substance handled at this distribution facility is chlorine. The total inventory of chlorine stored at this plant is 600,000 pounds. Although unlikely to occur, our Worst-Case Scenario would be failure of a 90 ton rail car of chlorine which would release 180,000 pounds of chlorine. It is assumed that the entire cont ents are released as vapor, which is heavier than air. The distance to the endpoint of 0.0087 mg/L ( 3 ppm) would be 14 miles. Our alternative release scenario would be the gas valve on a ton cylinder remaining open and mitigation stops the release in twenty minutes. The distance to the endpoint of 0.0087 mg/L ( 3 ppm) would be 2 miles. Our facility is operated in accordance with recommendations from the Chlorine Institute. All our chlorine lines are constructed with seamless schedule 160 pipe which is twice the thickness of pipe normally recommended for handling chlorine. In the last few weeks we have completed installation of a state of the are rail car valve closure system. This system will automatically close all rail car valves in the event: - a leak is detected by any of the six new outdoor chlorine sensors, - a hooked-up rail car that is accidentally moved; - a power failure occurs; or - an emergency stop button is pushed. Our facility also recently installe d a diesel back -up generator to provide power during an outage. The cost of these two safety upgrades was over $200, 000. In the last 5 years, we have had 5 accidental releases that resulted in lost work time for an employee. These were small enough in nature that no off-site persons were affected. During that same 5 year period, we had one accidental release of sufficient quantity to trigger regulatory reporting requirements. This incident did not injure any persons on-site or off-site. Our emergency response program is highlighted by the fact that we have over 25 employees that are OSHA 40 hour trained emergency responders. We maintain adequate response equipment to respond to any size chlorine leak that could occur at our facility. The local fire department has reviewed our emergency response plan and has conducted training for their personnel on our site. All of our employees receive annual emergency response plan training. An item that we are currently wor king on to improve safety at our facility is enhancing our preventative maintenance inspection program to include ultrasonic testing of pipelines and valves with a recently purchased tester. This will give us the ability to locate potential bad spots inside pipelines and fix them before a release can occur. Should there be any questions or concerns regarding the safe handling of chlorine at K.A. Steel Chemicals Inc., please visit our website at www.kasteelchemicals.com or contact Brad Budner our Operations Manager at (630)243-2279 or Dave Celovsky our Health and Safety Manager at (630)243-2260. |