Earlier this week the Clorox company announced that the were switching their consumer bleach manufacturing from chlorine gas to high-concentration sodium hypochlorite feed stock. The change will be phased in at all seven production facilities over a number of years. The Clorox company announcement noted that this was done as part of their commitment to strengthen their operations and “add another layer of security”.
Greenpeace was quick to applaud the move that eliminates both the chlorine gas used on site and the “equally disastrous risks posed by the transport of 90-ton rail cars of chlorine gas”. Greenpeace has been pressuring all consumer bleach producers to eliminate the use of chlorine gas in the manufacture of their product.
The move by Clorox being announced this week is sure to be used as justification for the IST provision included in all three titles of HR 2868 that will be debated on the House floor this week. Actually, the opponents of the mandatory IST provisions of the bill are likely to be able to use the same announcement to support their position.
Voluntary IST Implementation
The chemical industry will be quick to point out that this is a perfect example of how responsible chemical companies are continuously evaluating their processes to ensure the highest levels of security and safety. If the implementation is feasible and appropriate to the facility, an enlightened industry will institute the techniques without government intervention.
Greenpeace would, of course, respond that if that were the case, then Clorox would have made the change years ago. Greenpeace wouldn’t have had to wage a public relations campaign to convince the company to change over to an obviously safer process.
Practically speaking this switch-over demonstrates how complex an IST implementation can be. Clorox is able to do a plant-by-plant switch over to minimize the disruption to their business. According to Clorox CEO Knauss “Our plant-by-plant approach will also enable us to apply what we learn along the way, ensure supply availability, minimize business disruptions and help make sure the transition is undertaken in the most effective manner possible."
Since CFATS addresses each plant separately, all seven plants would be required to implement this IST process essentially simultaneously. This would result in a dangerous business interruption in a competitive market place. Without being able to learn from previous plant mistakes the change over would take longer in total plant hours. It would also significantly increase corporate costs for executing the total change over.
Is this IST?
Actually, this may not be an ‘IST implementation’ under the current provisions of HR 2868. Clorox is not eliminating the use of chlorine gas in their new process; they are simply moving it to another location, the manufacturer of the high concentration sodium hypochlorite solution. If that manufacturer uses chlorine gas in their operations, instead of direct manufacture from salt for instance, there has been no elimination of risk only transfer of risk.
It is unlikely that a new facility is being constructed to manufacture the industrial strength bleach that will be used at these seven facilities. To determine if this is an IST implementation that could be directed by the Secretary the question becomes does the bleach production facility increase in Tier level ranking because of the new business. If it does, the Secretary could not require Clorox to implement this process change.
An interesting question arises if the manufacturing facility is already a Tier I facility, but this new business requires a doubling of the typical on-site chlorine storage. The current wording of the §2111 provisions would allow the Secretary to order the change in that case, since the Tier ranking would not change. Does increasing the population at risk at the other facility justify mandating an IST requirement at the Clorox facility.
Then one needs to consider the transportation consequences of this change. An 80 ton rail car of chlorine gas should produce about 5.4 million pounds of household bleach (6% Sodium Hypochlorite). To produce the same amount of household bleach from a concentrated hypochlorite solution (50% is about the maximum concentration available) would take a little over 4 railcars.
Unfortunately most hypochlorite producers are reluctant to ship in rail cars because of time constraints due to the fact that high concentrations of hypochlorite start decomposing into chlorine gas the longer they sit without temperature controls. This is why most industrial strength bleach is shipped by truck. And it requires about 16 trucks to provide a similar amount of chlorine as a rail car of chlorine gas.
Shipping chlorine by rail car is demonstrably safer (fewer release accidents per mile shipped) than shipping by truck. So has over all safety been increased?
Another thing is that bleach and ammonia make a real nice improvised explosive as long as you can keep them apart until you want the explosion to happen. So what happens when an aqueous ammonia tank truck is deliberately drained into a sewer line while a short distance away a truck load of bleach is dropped into the same sewer? A large explosion that releases large quantities of chlorine gas is what happens. By all means, lets increase the numbers of truck loads of industrial strength bleach on the roads.
IST Is Complex
Going into the IST debate tomorrow, lets remember that IST is a complicated issue. Sure, if you eliminate tank cars full of chlorine, the facility becomes less of a target. But a facility is easier to secure than the open roads. Moving the more easily defended target into lager numbers of less lethal, but still dangerous targets, is of questionable efficacy.
Making a decision to implement IST techniques is going to be one of the most difficult decisions that we require people to make, in the private sector or in government. There are lots of pros and cons to weigh. We need to make sure all parties have the necessary tools to make an effective and appropriate decision.
I spent 15 years in the US Army as an Infantry NCO. After getting out of the Army I started working in the chemical industry, getting my BSc Chemistry degree while working as a technician. I spent 12 years working as a process chemist in a specialty chemical company. I'm now working as a QA Manager in a specialty chemical manufacturing facility.