tag:blogger.com,1999:blog-9122514974659083342.post241717490138853288..comments2024-02-02T22:30:20.736-05:00Comments on Chemical Facility Security News: Significant Changes in Chlorine Dispersion ModelsPJCoylehttp://www.blogger.com/profile/03390039682578324978noreply@blogger.comBlogger2125tag:blogger.com,1999:blog-9122514974659083342.post-9796977904011586062017-02-24T17:14:06.393-05:002017-02-24T17:14:06.393-05:00You might want to update info on chlorine industry...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. <br /><br />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. <br />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.<br /><br />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.<br /><br />1] Kuehne Chemical Co., Inc. – Delaware City<br />1645 River Road<br />New Castle, Delaware<br />RMP EPA ID: 1000-0002-5073<br />Activity: bleach manufacturing<br /><br />RMP Date: 5/3/16<br />Chemical: chlorine<br />Amount: 180,000 lbs. (rail car)<br />Distance to endpoint: 0.5 miles<br />Residential population within distance: 0<br />Model: Chlorine Institute Pamphlet 74 - Guidance on Estimating the Area Affected by a Chlorine Release<br /><br />RMP Date: 5/4/11<br />Chemical: chlorine<br />Amount: 180,000 lbs. (rail car)<br />Distance to endpoint: 13<br />Residential population within distance: 480,000<br />Model: RMP Management Program Guidance for Offsite Consequence Analysis<br /><br />2] Sierra Chemical Co., Stockton Facility<br />1010 Industrial Drive<br />Stockton, Calif.<br />RMP EPA ID: 1000-0013-3991<br />Activity: chlorine repackaging and bleach manufacturing<br /><br />RMP date: 12/10/15<br />Chemical: chlorine<br />Amount: 180,000 lbs. (rail car)<br />Distance to endpoint: 0.33 miles<br />Residential population within distance: 0<br />Model: HPAC model scenarios from Chlorine Institute Pamphlet 74, Edition 6<br /><br />RMP date: 7/20/09<br />Chemical: chlorine<br />Amount: 180,000 lbs. (rail car)<br />Distance to endpoint: 14 miles<br />Residential population within distance: 364,261<br />Model: EPA’s RMP*Comp(TM)<br /><br /><br /><br />Anonymoushttps://www.blogger.com/profile/14147107779261096853noreply@blogger.comtag:blogger.com,1999:blog-9122514974659083342.post-36842817454422980012016-09-04T17:04:49.714-04:002016-09-04T17:04:49.714-04:00I missed this excellent piece a year ago. Are the...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.<br />So some papers there might follow up on this significant development.<br />Fred MillarAnonymoushttps://www.blogger.com/profile/14147107779261096853noreply@blogger.com