Gulbrandsen Manufacturing, Inc. - Executive Summary

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Gulbrandsen Manufacturing, Inc. is a leader in the chemical manufacturing industry and has always been committed to protecting associates, the community, and the environment from highly hazardous incidents through safely operating our facility. 
Facility Overview:  Gulbrandsen Manufacturing, Inc. owns and operates a chemical manufacturing plant located in Orangeburg, South Carolina.  The facility is regulated under RMP due to on-site chlorine storage in excess of the RMP applicability threshold of 2,500 pounds.  Chlorine is used for water treatment which serves the purpose of treating process water used at the facility.  Chlorine is stored in a 90-ton railcar having a capacity of 180,000 pounds.  
Chemical Safety Overview:  The facility's overall approach and commitment to chemical safety is demonstrated by 1) the existing management, training, procedure and maintenance systems already in place at the facility, and 2) the hazard assessment, prevention program and emergency response pro 
visions implemented specifically for chlorine in response to the RMP requirements.  The management structure and oversight to ensure safety is documented in the facility's RMP and includes compliance with applicable regulations, codes and standards (OSHA PSM Standard and US EPA 40 CFR 68). 
Release Scenarios:  Worst-case and alternative release scenario assessments were conducted for the facility's single largest vessel based on US EPA's Offsite Consequence Analysis guidance.  The worst-case release scenario for chlorine is a 10-minute gaseous ground release of 180,000 pounds of chlorine and the alternate release scenario assumes a >  inch hole in the tank resulting in a release rate of 1,400 pounds per minute of chlorine.  Public receptors were determined to be located within the impact zone of both the worst-case and alternative releases.  The resulting worst-case and alternative release impact zones were 25 miles and 1.6 miles, respectively.   
Five-Year Accident History:  Due to ou 
r excellent accident release prevention programs, Gulbrandsen has had only one RMP reportable accident/release of chlorine within the five years proceeding RMP submittal.  This 500 lb gas release occurred on February 25, 1996, and did not result in any injury or damage to persons or property at Gulbrandsen or in the surrounding area. 
Prevention Program:  The facility has implemented a Program Level 3 Prevention Program for chlorine, as required by the RMP rule, in accordance with the US EPA guidance.  These prevention program provisions are specifically intended to minimize the probability and/or consequence of any accidental chlorine release from the facility and include such measures as process hazards analysis, operating procedures, training, contractors, pre-startup safety, mechanical integrity, hot work permit, management of change, incident investigation, emergency planning and response, and compliance audits.  The facility prevention program is an ongoing system based on period 
ic training, incident investigations, audits, procedure revisions, and RMP updates as required to reflect facility change and RMP requirements. 
Emergency Response Program:  The facility's Emergency Response Program has been perfected to produce the maximum effective response in the least amount of time.  The facility has coordinated response with the Emergency Operation Center to ensure that they will respond to any accidental release from the chlorine system.  The facility has also established its own Emergency Response Reference Guide, which outlines six groups that will handle the response activities, including the Emergency Team, the Repair Team, the First Aid and Rescue Team, the Evacuation Team, the Communication Team, and the Environmental and Clean-Up Team.   
Safety Management and Changes:  The facility is committed to ensuring its operations are safe and in accordance with all RMP requirements, and has established a senior manager responsible for RMP development, implementat 
ion, and compliance.  This manager is committed to maintaining the safety of the RMP covered chlorine systems through active adherence to the appropriate procedures and codes.  To ensure that the appropriate changes occur as necessary to maintain/improve safety, ongoing hazard reviews, training, audits, maintenance and investigations will be conducted as required by RMP.  Updates to the RMP will be completed as necessary in response to these activities. 
Summary:  As documented in this submittal, the RMP for the facility has been completed in accordance with all 40 CFR 68 requirements and the facility has certified compliance.  Gulbrandsen takes pride in and is committed to conducting business in strict conformity with all applicable laws in a safe and responsible manner.  The very highest priority is placed on the health and safety of Gulbrandsen's associates and the community in which we conduct business.
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