KIK SO CAL - Executive Summary
FEDERALLY MANDATED RMP SUBMISSION |
1. Accidental Release Prevention and Emergency Response Policies
KIK So Cal is manufactures and packages household cleaning products such as bleach, ammonia, and dry laundry detergent. Chlorine (liquid under pressure) is a manufacturing process chemical that is considered a hazardous material and is a regulated substances under the Federal Accidental Release Program. The City of Santa Fe Springs Fire Department recognized the KIK So Cal facility as a Stationary Source under the Federal regulations and requested this Risk Management Plan (RMP). KIK So Cals policy is to adhere to all applicable Federal and State of California rules and regulations. Safety depends upon proper construction design and safety features of the facility, accurate operating and emergency procedures, and effective training of personnel.
2. Stationary Source and Regulated Substances
The KIK So Cal manufacturing and packaging facility occupies 7.5 acres
at 9028 Dice Road in Santa Fe Springs, California. As a Stationary Source, there is one regulated process for chlorine, the unloading/caustic soda addition process.
The chlorine is unloaded directly to the facility bleach plant from two 180,000-lb capacity rail tankcars parked on adjacent rail spurs. The continuous-process bleach plant mixes the liquid chlorine with a dilute caustic solution to form household bleach (sodium hypochlorite) that is stored. Sodium hypochorite is not a regulated substance.
3a. Worst Case Release Scenario
The Worst Case release scenario for interconnected equipment must consider the largest quantity of a regulated substance handled on site in a single vessel at any time, taking into account administrative controls on the vessels contents and usage as per the CCR Title 19 Division 2 Chapter 4.5 Article 2 Section 2750.3(b).
The 180,000 lbs of chlorine makes the rail tankcar the largest vessel in the chlorine feed system. The Worst Case release scen
ario for the chlorine rail tankcar is the release of the entire capacity at a rate of 18,000 lbs per minute for a ten minute duration. The distance to the endpoint of 3 ppm would extend over a large area beyond the boundaries of the stationary source.
3b. Alternative Release Scenario
The Alternative Release scenario for the chlorine unloading / caustic addition process involves a transfer hose failures.
In the chlorine release scenario, the transfer hose failure would cause chlorine to be released at a rate of 14.2 lbs per minute for five minutes. The distance to the end point of 0.0087 mg/L would be just beyond the boundaries of the stationary source.
3c. Administrative Controls
Administrative controls to limit the distances for each reported scenario exist to restrict, to a minimum, the amount of chlorine lost from a rail tankcar if an accidental release were to occur; and preferably to not have a release occur. These administrative controls are inherent in the operational pr
ocedures for the chlorine unloading process system and the training provided to the operators.
3d. Mitigation Measures
Mitigation measures to limit the distances for each reported scenario exist to restrict the amount of chlorine released to a minimum, if a release were to occur; and preferably to not have a release occur. The mitigation measures are based on the design, inspection, testing, and maintenance of the chlorine unloading process system and their related equipment and components.
4. General Accidental Release Prevention Program and Chemical Specific Prevention Steps
The facility complies with all applicable Federal and State codes and regulations. There are safety meetings and safety training. The Process Safety Management (PSM) program implemented at the facility for the chlorine unloading system and the related activities and equipment represents the facilitys main active commitments to an accidental release prevention program.
5. Five Year Accident History
re have been no accidental releases of chlorine in the last five years.
6. Emergency Response Program
The Emergency Response Program is based upon the alerting of personnel at the facility to evacuate or shelter-in-place and await the arrival of responders from the City of Santa Fe Springs Fire Department at the assembly location if a release occurs that causes the evacuation or the shelter-in-place to be initiated.
7. Planned Changes To Improve Safety
There were commitments made under the Risk Management and Prevention Program (RMPP) that were scheduled implemented by September 1997. Current applicable codes and regulations are also reviewed as part of the Process Hazard Analysis element of the Process Safety Management (PSM) program to determine if other commitments need to be made to achieve increased operational safety for the regulated chlorine unloading / caustic addition process systems. These commitments will be prevention and mitigation measures for accidental releases o
f the regulated substances.