Kemiron Pacific Inc. - Executive Summary |
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EXECUTIVE SUMMARY Kemiron Pacific currently manufactures and distributes liquid ferric chloride and liquid ferrous chloride throughout the southern California area from its facility located in Fontana, California. Over 95-percent of Kemiron's sales of these products are to municipalities for use in both drinking water and wastewater purification. These iron salts are highly versatile being used in such diverse water treatment applications as primary coagulation, biological oxygen demand (BOD) reduction, total suspended solids (TSS) reduction, odor and corrosion control, phosphorous removal, sludge conditioning, color removal and co-precipitation of heavy metals. The main raw material required in the manufacture of ferrous chloride and ferric chloride is chlorine. At the Kemiron Pacific manufacturing facility located at 14000 San Bernardino Ave in Fontana, chlorine is delivered in 90 ton railcars. One chlorine car is hooked up at a time for unloading into the manufacturing proce ss. The facility consists of an office building with a control room, three large storage tanks, six production vessels, two scrubbers for controlling fugitive emissions, safety equipment, and emergency response equipment. There is also a state of the art chlorine detection, shut down, and alarming system controlling the offloading of the chlorine. The facility is manned by Kemiron Pacific personnel while ferrous chloride and ferric chloride are being manufactured. When the facility is shut down, security provides 24 hour surveillance of the facility. Unauthorized entry into the facility is prevented by property line fencing which is patrolled and security guards at the gated entrances. The Kemiron Pacific accidental release prevention policy involves a unified approach that integrates technologies, procedures, and management practices. All applicable procedures of the U.S. Environmental Protection Agency (EPA) Prevention Program are adhered to. Furthermore Kemiron Pacific has a no tolerance policy toward unsafe practices or behavior by employees especially when in conflict with existing approved procedures. The Kemiron Pacific emergency response policy involves the preparation of a response plan tailored to the Fontana facility and to the emergency response services available in the community. Kemiron is in compliance with the EPA Emergency Response Program requirements. Chlorine Release Scenarios RMP regulations require offsite consequence analysis for a potential release of chlorine to the atmosphere. Kemiron Pacific is required to consider two release scenarios, identified as "worst case" and " alternative scenario". The first scenario is defined by the EPA, which states that " the owner or operator shall assume that the maximum quantity in the largest vessel is released as a gas over 10 minutes," due to unspecified failure. The alternative scenario is defined as "more likely to occur than the worst-case release scenario". Atmospheric disper sion modeling has to be performed to determine the distance traveled by the chlorine released before its concentration decreases to the "toxic endpoint" selected by the EPA of .0087 mg/liter, which is the Emergency Response Planning Guideline Level 2 (ERPG-2). This is defined by the American Industrial Hygiene Association (AIHA) as the "maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action." The residential population within a circle with a radius corresponding to the toxic endpoint distance has to be defined, "to estimate the population potentially effected". To determine the radius of this circle, Kemiron Pacific used an air dispersion modeling program called RMP*COMP which was provided by the EPA. The worst case release scenario for the Kemiron Pacific p lant located in Fontana, California involves the failure of one railcar containing 90 tons of chlorine. The EPA mandated conditions are the entire amount is released in a 10 minute time period, use of the one-hour average ERPG-2 for toxic endpoint, consideration of the population residing within a full circle. These assumptions may be unrealistic because: 1. Only a fraction of the liquefied chlorine would flash to a vapor. The rest would form liquid droplet aerosols. This greatly changes the dispersion characteristics. 2. Only the population down wind of a release would be affected, not the area of a full circle encompassing the release. The EPA mandated meteorological conditions of wind speed 1.5 meters per second, stability class F, and temperature of 77 F were used. When the atmospheric dispersion modeling for the worst case scenario was completed, a distance to toxic endpoint of 14 miles was obtained. The residential population potentially affected was 1,400,000. The alter native scenario involves the rupture of a transfer hose, which is used to connect the rail car to the chlorine transfer system, possibly due to an earthquake. The amount of chlorine released would be 118 pounds. The duration of the release would occur in one minute which makes the release rate 118 pounds per minute. The weather conditions used were wind speed of 3 meters per second, stability class D, and temperature at 77F. The estimated distance to toxic endpoint (.0087 mg/liter) obtained from the air dispersion modeling was .2 miles or 1056 feet. There would be no residential population affected. The alternate scenario incorporates consideration for active mitigation measures. The chlorine handling system is equipped with a state-of-the-art chlorine detection and shutdown system. If chlorine is detected at 1 ppm or higher, an alarm goes off and the valves on the chlorine railcar close. The valves are automatic fail-close ball valves. There is a similar valve located in the chlorine system piping which also closes when chlorine is detected. These valves isolate the chlorine railcar and the chlorine piping from the atmosphere during upset conditions which limits the release to the amount of liquid chlorine contained in the transfer hose and 60 feet of chlorine system piping. Accidental release Prevention Program The general Kemiron Pacific accidental release prevention program is based on the following key elements: 7 PSM Program in compliance with Cal OSHA requirements 7 Preventive maintenance program 7 Extensive training of the operators 7 Use of accurate and effective operating procedures 7 Use of state of the art process and safety equipment 7 Use of Process Hazard Review to reveal potential hazards and assign corrective actions 7 Implementation of monthly safety inspections. Chemical specific prevention steps include availability of self-contained breathing apparatus (SCBA) used during emergency response, half face respirators for each employee to be used during hook up and disconnect of chlorine rail cars, a vacuum system for pulling the chlorine out of the chlorine lines before hook up and disconnect of chlorine rail cars, a state of the art chlorine detection system which activates our emergency shutdown system, and special training for all employees on the hazardous and toxic nature of chlorine. Five Year Accident History Kemiron Pacific Inc. has had one RMP reportable accidental release of chlorine in the past five years. One pound of chlorine was released during a chlorine pipeline maintenance procedure. Although a one pound of release chlorine is below Federal limit of a reportable quantity, medical attention was required for one Kemiron Pacific employee who was exposed to direct chlorine inhalation. The employee was sent to the hospital for observation and was released two hours later. He returned to work the next day. No one offsite was injured or evacuated. Emergency Response Program Kemiron Pacific in Fon tana has an emergency response program, which has been reviewed by the San Bernardino County Fire Department (part of Business Plan). The program includes an emergency response decision tree and a notification plan. Emergency response drills are performed annually (One such drill was performed in May of 1997 with the San Bernardino County Fire Department. It involved over thirty S. B. County personnel). All operators have been trained as Hazardous Material Responders for chlorine emergencies. All operators attend monthly safety meeting and must pass the emergency response refresher training course conducted annually. This course is eight hours of intense training on safe chlorine handling practices and hands on experience with emergency response equipment. All new hires must pass the initial 40 hour Haz-Mat training course before working in the facility. Training is key to our Emergency Response Program. Planned Changes to Improve Safety In January of 1997, Kemiron Pacific p erformed an internal audit and identified 8 changes that would improve safety in our chlorine handling system. These recommended actions were implemented by the end of February 1997 as required. |