Kuehne Chemical Co., Inc. - Executive Summary |
|
Kuehne Chemical Co., Inc. Executive Summary The following is written to comply with N.J.A.C 7:31-7.1 Incorporated by reference 68.155. A. The accidental release prevention and emergency response policies at the stationary source; Kuehne Chemical has in place three programs designed to address accidental release prevention and emergency response issues. These programs have been reviewed and approved by the New Jersey Department of Environmental Protection. The first program is the Discharge Prevention Containment and Countermeasure Plan. This plan is designed to ensure Kuehne Chemical has the appropriate precautionary procedures in place to address likely release scenarios. This plan focuses on release prevention. Second, Kuehne Chemical has in place a Discharge Cleanup and Removal Plan. This plan is designed to ensure Kuehne Chemical has the ability to initiate a response to a release. The DCR plan outlines actions Kuehne Chemical intends to take to mitigate the effects of t he release and to minimize off-site impact. The third plan is Kuehne Chemical's Emergency Response Plan. This plan provides emergency response information for the most likely emergency incidents and release scenarios. The plan addresses on-site and off-site response activities for both HAZMAT and medical related incidents. This plan includes the recommendations established in the Chlorine Institute's Pamphlet 64, Emergency Response Plans for Chlorine Facilities B. The stationary source and regulated substances handles; At the South Kearny facility, Kuehne Chemical repackages and distributes chlorine and sulfur dioxide. C. The worst-case release scenarios and the alternative release scenarios, including administrative controls and mitigation measures to limit the distances for each scenario: EPA has designated the "Worst Case Release Scenario" to be based upon the total failure of the largest tank or vessel at the facility and a total release of the hazardous substance in a ten (10) minute period. Our worst-case scenario is identical for each of the two hazardous substances (Chlorine, Sulfur Dioxide) stored at this facility. Each scenario involves the complete failure of a ninety-ton railroad tank car, fully loaded with product, discharging the entire contents in a period of ten (10) minutes. Chlorine Worst-case scenario: In the event of a total failure of a rail road tank car of chlorine which discharges its entire contents within a ten (10) minute time frame, the resulting cloud of chlorine vapor would be immediately dangerous to both life and health for a distance exceeding 14 miles according to the RMP*Comp calculations. There has never been a failure of this type for a stationary chlorine rail car and this scenario must be considered highly improbable. Alternate scenario: An alternate scenario for chlorine involves a pipeline leak, which releases one pound per minute of chlorine for a duration of 50 minutes, releasing a total of 50 pounds of material. The RMP*Comp calculation for this scenario shows a distance of less than 0.1 miles to the endpoint. There is no residential population within this area. Sulfur Dioxide Worst Case scenario In the event of a total failure of a rail road tank car of sulfur dioxide which discharges its entire contents within a ten (10) minute time frame, the resulting cloud of vapor would be immediately dangerous to both life and health for a distance exceeding 16 miles according to the RMP*Comp calculations. There has never been a failure of this type for a stationary sulfur dioxide rail car and this scenario must be considered highly improbable. Alternate scenario: An alternate scenario for sulfur dioxide involves a pipeline leak, which releases one pound per minute of chlorine for a duration of 50 minutes, releasing a total of 50 pounds of material. The RMP*Comp calculation for this scenario shows a distance of less than 0.1 miles to the endpoint. There is no residential population within this area. Kuehne Chemical has installed throughout the South Kearny facility chlorine monitors, which will alert personnel in the control room of a chlorine release. Additionally, similar detection devices monitor the sulfur dioxide transfer area during transfer operations. The control room, which is manned 24-hours a day, 7 days a week and is equipped atmospheric monitoring equipment. D. The general accidental release prevention program and chemical specific prevention steps: Kuehne Chemical's South Kearny facility is full compliant with all local, state and federal regulations pertaining to the storage and handling of chlorine and sulfur dioxide. As stated in "A" above, Kuehne Chemical has three major programs in place, which addresses accidental release prevention issues. Furthermore, the New Jersey Department of Environmental Protection's Toxic Catastrophe Prevention Act has regulated Kuehne Chemical since the programs inception. The NJ TCPA program, which was the fi rst of its kind in the country, is considered to be more stringent than the related Accidental Release Prevention Program administered by the Environmental Protection Agency. E. The five-year accident history: Date Material Quantity Impact On-site/Off-site July 20, 1998 Chlorine <5 pounds None March 23, 1999 Chlorine <1 pound None July 5, 1999 Chlorine 0 None October 19, 1999 Sulfur Dioxide 0 None April 12, 2000 Chlorine <1 pound None May 30, 2000 Chlorine <5 pounds None July 3, 2000 Chlorine <1 pound None July 6, 2000 Sulfur Dioxide <1 pound None F. The emergency response program; Kuehne Chemical's Emergency Response program which is designed to address the most likely to occur emergency incidents and release scenarios. The plan outlines on-site and off-site response activities for both HAZMAT and medical related incidents. This plan includes the recommendations established in the Chlorine Institute's Pamphlet 64, Emergency Response Plans for Chlorine Facilities. G. Pla nned changes to improve safety. |