Rabun Apparel, Inc. - Executive Summary
Rabun Apparel, Inc. is a manufacturer of men's and boy's underwear and t-shirts located in Rabun Gap, Rabun County, Georgia. This facility maintains a 4,000 pound chlorine system for treatment of wastewater effluent and stores up to 12,000 pounds of chlorine, totaling 16,000 pounds of chlorine onsite. Based on criteria specified in 112(r) of the Clean Air Act (CAA), the source is classified as "Program III". |
The worst-case scenario for this facility, as specified in the CAA, is a release of approximately 2,000 pounds of chlorine within 10 minutes followed by vapor cloud dispersion. The radius of influence to the specified endpoint of 0.0087 mg/L is 0.9 miles based on modeling using RMP*Comp.
The alternative scenario involves the release of 2,000 pounds of chlorine due to a cross-threaded coupling after container replacement. The release, if unnoticed by the operator, would occur over approximately 60 minutes, followed by plume dispersion. Based upon Class B atmospheric conditio
ns the toxic vapor cloud is predicted to extend 0.7 miles (1,191 yards) based on the ALOHA modeling program.
Both scenarios affect offsite receptors. There are no administrative controls in use that could reduce the predicted effects, however, the chlorine system is contained within a building which serves to impede the rate of dispersion of the gas and connected to a functional alarm system which will be responded to by the HazMat Team.
There have been no incidents involving the chlorine system in the last five years which presented any threat of personnel or property damage on or off the site.
Rabun Apparel maintains a Technician Level HazMat Team and will respond to emergency releases in accordance with 29 CFR 1910.120 (HAZWOPER). The Dillard Volunteer Fire Department will be summoned by 911 to provide logistical support.
Process Hazard Analysis of this system is conducted at least once every five years by Rabun Apparel personnel in accordance with 29 CFR 1910.119, Process Sa
fety Management of Highly Hazardous Chemicals. There are currently no known system deficiencies and no planned changes to the current standard operating procedures or safety protocols.