Saturday, August 1, 2015

Significant Changes in Chlorine Dispersion Models

As I mentioned on Thursday the Chlorine Institute has published an updated version (Edition 6) of their Pamphlet 74. That pamphlet used to be titled “Guidance on Complying with EPA Requirements Under the Clean Air Act by Estimating the Area Affected by a Chlorine Release”. The new version removes reference to the EPA and is more simply called the “Guidance on Estimating the Area Affected by a Chlorine Release”. This reflects the more widespread use of the modeling data.

I do not have a copy of Edition 5 of this pamphlet, but I do have Edition 4 that I have used for a reference in a number of blog posts on chlorine releases that I have done over the years. So I am going to be comparing the downwind hazard predictions from these two versions of the Pamphlet.


Chlorine is a very common hazardous material and it is widely used in this country. It is certainly the largest volume toxic inhalation hazard (TIH) chemical shipped in the United States. It is typically shipped in the following types of containers:

150-lb. Cylinder;
1-Ton Container;
17-Ton Tank Truck Trailer; and
90-Ton Rail Tank Car

Chlorine is used as a disinfectant for water treatment and waste water treatment facilities. It is also used in the manufacture of a large number of industrial chemicals and pharmaceuticals. It is generally produced via the electrical disassociation of common salt, NaCl; producing both chlorine (Cl2) and caustic soda (NaOH). A less common, but still important, source of chlorine is as a byproduct of the production of magnesium from natural ores.

Chlorine gas was used as the first modern chemical weapon in World War I. The CDC reports that the immediately dangerous to life and health (IDLH) concentration of chlorine gas is 10 ppm while reporting that lethal effects have been seen at 34 to 51 ppm when exposed for over an hour. The OSHA personal exposure limit is 1 ppm with a short term exposure limit of 3 ppm.

The Chlorine Institute has been using the values of 3 ppm and 20 ppm as their standards for downwind exposure reporting in Pamphlet 74. In a release scenario exposure levels at less than 3 ppm are considered to be relatively safe in the short term. Exposures between 3 and 20 ppm will have some immediate medical effects that will probably require medical attention, but will probably still allow an otherwise uninjured person to self-evacuate from the affected area. Exposures over 20 ppm will almost certainly cause immediate health effects of a severity that would stop a person from self-evacuating from the affected area and may result in death.

Worst Case Scenarios
The table below describes the worst case scenario reporting from both versions of Pamphlet 74 and the RMP*Comp tool used to report downwind distance of concern for both the EPA Risk Management Program (RMP) and the DHS Chemical Facility Anti-Terrorism Standards (CFATS) program. All distances have been converted to feet.

Pamphlet 74 – Ed 6
Pamphlet 74 – Ed 4
20 ppm
3 ppm
20 ppm
3 ppm
.0087 ppm
150 lbs
1 ton
17 ton
90 ton

This obviously marks a serious departure from the previous guidance on downwind hazards from chlorine gas releases. According to both publications (pgs 16-17 in both Editions) the following conditions of the release are the same in both studies:

• The ambient relative humidity is 50%
• The ambient temperature is 77°F (25°C)
• Liquid chlorine is at 77°F and 100 psig before the release
• Surface roughness is 3.94 inches (0.1 meters). Such a surface roughness corresponds to a relatively flat, grassy, rural setting. A release in hilly terrain, forested area, and urban environment or over water may have significantly different terrain results.
• The wind speed is 3.36 miles/hour (1.5 meters/sec). The reference height for measuring the wind speed is 32.8 feet (10 meters).
• The contents of the container are released instantaneously and evaporated at a constant rate over a ten-minute period
• The atmospheric stability is class F (night, < 50% cloud cover)
• The release occurs at ground level
• Solar radiation is assumed at 0 Btu/hr/ft2
• Averaging time is 10 minutes
• Receptor height is 0 feet (ground level)

Modeling Differences

What is clearly different is that the two Editions are reporting results from different dispersion models. Edition 4 uses TRACE 8.0 developed by Safer Systems, Inc. Edition 6 uses Hazard Prediction and Analysis Capability (HPAC) 5.0 developed by DOD’s Defense Threat Reduction Agency (DTRA). There is a brief discussion about the model used in each report as the first appendix. What is missing, however, is any discussion in the latest edition about why the model changes were made and how that impacted the huge change in predictions reported.

What is mentioned in the press release announcing the latest version of the Pamphlet is that it “incorporates information obtained from the DHS ‘Jack Rabbit I’ chlorine release field tests”. I think that it would be safe to assume that TSA did not run tests meeting exactly the conditions specified in the report. I have not seen the final report on the Jack Rabbit I trails (and I suspect it is classified and thus I will never see it), but with only a total of ten releases split between chlorine and anhydrous ammonia, I would expect that the researchers would have varied the environmental situation as much as possible to obtain the type of results necessary to develop a robust model.

Without a robust discussion about the differences in the two models used to report the data in these two different editions of Pamphlet 74, it is hard to make a judgement as to which is the more appropriate model upon which to base regulatory and emergency response decisions. And make no mistake, with the wide discrepancy between the two sets of predictions provided in the two versions of the Chlorine Institute report, it is absolutely assured that that the manufacturers and users of chlorine will press for changes in safety and security regulations to reduce their costs of operations. And just as surely they will be vocally and vigorously opposed by any number of environmental activists.

Modeling Problems

I have discussed the modeling problems associated with chlorine dispersion modeling in a couple of earlier blogs. Back in March of 2010 I reported on the exposure estimates from Edition 4 of Pamphlet 74; saying:

“Looking at the charts on pages 24 and 25 of Pamphlet 74 it looks like anyone inadequately protected in the cloud for up to a couple of miles away from the catastrophic release from a full railcar is at serious risk of being killed by the cloud. Inadequate protection in the cloud at distances of up to 15 miles from the release could have very serious medical consequences.”

In my blog post on what we now know as the start of the Jack Rabbit Project I noted that:

“It seems that the chlorine cloud from the two most recent catastrophic releases [Graniteville, SC and Macdona, TX] of chlorine from rail cars did not come anywhere near following the dispersion model for the release. TSA is initiating a two phase study of chlorine gas dispersion to clarify these discrepancies.”

Based upon the observed chlorine dispersions seen in these two accidents, it would seem obvious that the model used in the 4th Edition of Pamphlet 74 is more than a little exaggerative in it prediction of downwind areas of concern. And that, of course, was the reason for initiating the Jack Rabbit project in the first place. It would be interesting to see if anyone has gone back and used the observed data from those two real-world incidents to see how well the new model used in Edition 6 fits the observed conditions.

Of course, I would be very surprised if any reasonable model could accurately predict the dispersion cloud in a real incident. There are just too many variables that would affect both the macro and micro dispersion effects of the cloud. I discussed some of these in an earlier blog post.

The Use of the Dispersion Model

Practically speaking we do not need for an absolutely accurate prediction of gas cloud dispersions patterns. What we need is something that will allow facility safety personnel or emergency response personnel (depending on where the release takes place) to develop an initial plan for responding to a catastrophic chlorine release. With that in mind it would seem to me that we would want a plan that errors on the side of a larger downwind hazard area rather than one that underestimates the area.

From the new model, if it is appropriately supported by the Jack Rabbit data (including the upcoming Jack Rabbit II later this year), we have been grossly overestimating the potential exposure to chlorine releases from industrial facilities and transportation incidents. If that is true we may have overburdened producers and users of chlorine in the protective measures that we have required them to take.

Having said that, the relatively small downwind hazard areas described in the latest version of Pamphlet 74 feel like they are too small. This may lead us to reduce the protective burden to the point where we put people needlessly at risk near chlorine facility storage areas. Before we take that risk it would be prudent to ensure that there was a solid peer review of the model construction and methodology.


Fred Millar said...

I missed this excellent piece a year ago. Are there any new developments you have learned about, e.g., some peer review??? The gas dispersion modelers gather each summer at George Mason U for what seems to be a DHS-funded seminar.
So some papers there might follow up on this significant development.
Fred Millar

Fred Millar said...

You might want to update info on chlorine industry's astonishing risk minimization efforts to include a look at what they have done already to influence the major federal guidance documents they have explicitly said they are gunning for. Chlorine Institute has already bragged [exaggeratedly] on its website about influencing "almost all" of the Green Pages Table 3 levels for protective action distances in the widely used Orange Book the ERG.

And they have influenced the ALOHA program from NOAA [new RAILCAR module inserted] and perhaps most significantly for fixed facilities, the EPA's RMP program, as seen in recent RMP filings by Kuehne Chemicals in Delaware and Sierra Chemicals in Stockton CA. From sea to shining sea, as 4900 chlorine facilities nationwide comply with the RMP mandate to update their Offsite Consequence Analyses every 5 years. One would have to guess that US DHS and the insurance industry would view with alarm such cavalier and dangerously misleading efforts at "risk minimization on paper" -- vs. real risk reductions such as routing around major target cities.
Under the EPA’s Risk Management Planning (RMP) program chemical facilities that use large threshold amounts of certain extremely hazardous substances conduct an off-site consequences analysis of their potential worst-case release scenario. The result is a vulnerability zone analysis of potentially endangered residential populations. EPA allows a facility to select the modelling methodology it uses to perform the analysis from among credible atmospheric dispersion models or methods.

For decades the Chorine Institute, a chemical industry association, produced consistent vulnerability zone calculation guidance in its Pamphlet 74, Guidance on Estimating the Area Affected by a Chlorine Release. However, the Chlorine Institute’s Edition 6 revision of pamphlet 74, published June 2015, dramatically reduced the estimated distances associated with a chlorine gas release. The following are example facilities that used the revised Pamphlet 74 to recalculate their vulnerability zones – on paper.

1] Kuehne Chemical Co., Inc. – Delaware City
1645 River Road
New Castle, Delaware
RMP EPA ID: 1000-0002-5073
Activity: bleach manufacturing

RMP Date: 5/3/16
Chemical: chlorine
Amount: 180,000 lbs. (rail car)
Distance to endpoint: 0.5 miles
Residential population within distance: 0
Model: Chlorine Institute Pamphlet 74 - Guidance on Estimating the Area Affected by a Chlorine Release

RMP Date: 5/4/11
Chemical: chlorine
Amount: 180,000 lbs. (rail car)
Distance to endpoint: 13
Residential population within distance: 480,000
Model: RMP Management Program Guidance for Offsite Consequence Analysis

2] Sierra Chemical Co., Stockton Facility
1010 Industrial Drive
Stockton, Calif.
RMP EPA ID: 1000-0013-3991
Activity: chlorine repackaging and bleach manufacturing

RMP date: 12/10/15
Chemical: chlorine
Amount: 180,000 lbs. (rail car)
Distance to endpoint: 0.33 miles
Residential population within distance: 0
Model: HPAC model scenarios from Chlorine Institute Pamphlet 74, Edition 6

RMP date: 7/20/09
Chemical: chlorine
Amount: 180,000 lbs. (rail car)
Distance to endpoint: 14 miles
Residential population within distance: 364,261
Model: EPA’s RMP*Comp(TM)

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