The Clorox Company of Puerto Rico - Executive Summary

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The Clorox Company of Puerto Rico 
Caguas, Puerto Rico 
1. Accidental Release Prevention and Emergency Response Policies 
We at The Clorox Company of Puerto Rico (Clorox) are strongly committed to employee, public and environmental safety.  This commitment has led us to develop a comprehensive accidental release prevention program that includes design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility.  It is our policy to implement appropriate controls to prevent possible releases of regulated substances.  If a release should occur, our highly trained emergency response personnel are on site to control and mitigate its effects.  We have coordinated our emergency procedures with the local fire department, which provides additional emergency response coordination and expertise. 
To learn more about The Clorox Company please visit our web page at:  WWW.CLOROX.COM. 
2. The Stationary Source and the Regulated Substances Hand 
Our facility's primary activity involves the manufacture of Clorox household bleach and other household cleaning products.  We have one regulated substance present at our facility -- chlorine.  Chlorine is used in the production of sodium hypochlorite, which is the active ingredient in Clorox bleach and Tilex Instant Mildew Remover.  We produce additional cleaning products (Mistolin and Lestoil) which do not include the use of a RMP regulated substance. 
The largest single container of chlorine at our facility is 2000 pounds -- the capacity of the one-ton cylinder in which the chlorine is received.  Four of these cylinders (totaling 8000 pounds of chlorine) are manifolded together during the production of sodium hypochlorite.  The covered process at this facility as defined by the EPA is the chlorine handling system that includes storage and use of this regulated substance in the production of sodium hypochlorite. 
3. The Worst Case Release Scenario and the Alternative Release Sce 
nario, including administrative controls and mitigation measures to limit the distances for each reported scenario 
To perform the required off-site consequence analysis for our facility, we have used the look-up tables and equations provided by the EPA in the RMP Off-Site Consequence Analysis Guidance and the RMP*Comp modeling software recommended by the EPA.  This detailed information has been submitted to the EPA and to the Puerto Rico Environmental Quality Board (EQB). 
Worst-Case Release Scenario 
The worst-case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from our chlorine manifold system inside the chlorine cylinder enclosure.  By definition, the worst-case scenario could not include the use of the active prevention and mitigation systems developed by Clorox, which include sensors, alarms, emergency shutdown systems, air scrubbers and the emergency response team. 
Alternative Release Scenario 
The alternative release scenario 
for our facility takes into account the passive and active mitigation controls.  The EPA requires that a facility consider its release history in determining its alternative release scenario.  This facility has not had any releases resulting in off-site consequences since startup of operations in 1975.  However, a scenario with off-site consequences was developed by Clorox to comply with EPA requirements.  This information has also been submitted to the EPA and to the EQB.  
4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 by the EPA.  This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition.  Our chlorine handling process is covered by the OSHA PSM standard under 29 CFR 1910.119.  Our facility is also subject to the notification requirements of Section 302 of the Em 
ergency Planning & Community Right-to-Know Act (EPCRA). 
Y2K Readiness 
All facility safety functions are tested routinely as part of our on-going safety programs and have been subjected to additional testing for Y2K readiness.  Clorox launched a comprehensive, company-wide Y2K program in 1997, with outside assessment conducted by Engineering Services Inc., a third-party Y2K engineering firm. 
Our facility manufacturing systems are designed with multiple safety features to avoid any problems that could be caused by failure of a specific device or control system.  The automatic portion of our normal bleach facility operations are designed for "fail-safe" operation in the event of a control system failure or a power outage.  Critical functions are additionally protected by battery back-ups.  Finally, we have over-riding controls that are hard-wired to an emergency stop ("E-stop") system.  This E-stop system is also designed for fail-safe operation, and it requires manual intervention to r 
eset and start the system.  With these layers of safety and back-up systems, and the testing we have completed on critical components, we believe our facility is prepared for Y2K. 
Process Safety Information 
Clorox maintains a detailed record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. 
Process Hazard Analysis 
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently.  The methodology used to carry out these analyses is a Hazardous Operability Studies (HazOps).  The study is conducted by a team of qualified personnel with expertise in engineering and process operations.  Per EPA and OSHA requirements, the HazOp is revalidated at least every five years or whenever the process is significantly changed.  Any findings related to the hazard analysis are addressed in a timely manner. 
Operating Procedures 
For the pur 
poses of safely conducting activities within our chlorine handling process, Clorox maintains written operating procedures.  These procedures address various modes of operation such as startup, operations (normal and emergency), and shutdown.  The information is regularly reviewed and is readily accessible to operators involved with the process. 
Clorox has a comprehensive training program in place to ensure that process operators are completely competent in the operating procedures associated with the process.  New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently.  Refresher training is provided annually or more frequently as needed. 
Mechanical Integrity 
Clorox carries out highly documented maintenance checks on process equipment to ensure proper functions.  Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and  
vent systems, emergency shutdown systems, controls and pumps.  Maintenance operations are carried out by qualified personnel with previous training in maintenance practices.  Furthermore, these personnel are offered specialized training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
Management of Change 
Written procedures are in place at Clorox to manage changes in process chemicals, technology, equipment and procedures.  Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. 
Pre-startup Reviews 
Pre-start-up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Clorox.  These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for 
safe start-up prior to placing equipment into operation. 
Compliance Audits 
Clorox conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented.  Although EPA required that these audits are conducted every three years, Clorox audits its chlorine-handling facilities annually.  Corrective actions resulting from the audit findings are addressed in a safe and prompt manner. 
Incident Investigation 
Clorox promptly investigates any incident associated with the chlorine process, including false alarms and potential and actual releases of chlorine regardless of the quantity.  These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the incident from reoccurring.  All reports are retained for a minimum of five years. 
Employee Participation 
Clorox believes that process safety management and accident prevention are a team effort.  Company employees are strongly en 
couraged to express their views concerning accident prevention issues and to recommend improvements.  In addition, our employees have access to all information created as part of the facility's implementation to the RMP rule in particular information resulting from process hazard analyses. 
On occasion, our company hires contractors to conduct specialized maintenance and construction activities.  Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out.  Clorox has a strict policy of informing the contractors of known potential hazards related the contractors work and the processes.  Contractors are also informed of all the procedures for emergency response should an accidental release of chlorine occur. 
5. Five-Year Accident History 
The Clorox Company has had an excellent record of preventing accidental releases over the last five years.  Due to our stringent release prevention policies, there has been no accidental r 
elease as defined by the EPA during this period at this facility or any similar Clorox facilities across the United States.  Specifically, this facility has experienced no accidental releases resulting in off-site consequences since operations began in 1975. 
6. Emergency Response Plan 
Clorox has developed and implemented a written emergency response plan to deal with accidental releases of hazardous materials.  The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. 
To ensure proper functioning, our emergency response equipment is regularly inspected and serviced.  Emergency drills are conducted at least quarterly to ensure that the system works as planned.  In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emer 
gency response. 
The facility has coordinated its emergency plan with the Civil Defense of Caguas. 
7. Planned Changes to Improve Safety 
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program.  Improved training, coordination with local emergency responders, and additional release detectio sensors are some of the upgrades undertaken to improve safety at our facility before submitting our RMP.  Additionally, the plant will develop a written procedure to coordinate emergency communication with the residential community near the facility.  We expect this to be completed by December 1999. 
8. Certification Statement 
The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. 
Name: Arnoldo Azuela 
Signature: __________________________ 
Title: Plant Manager 
Date: __________________________
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