Fact Sheet: Preventing Accidental Releases: Chlorine Gas

Alaska Department of Environmental Conservation
Division of Environmental Quality
January 1995

A fact sheet on preventing accidental releases of chlorine gas, from the Alaska Department of Environmental Conservation Division of Environmental Quality.

Need Additional Information?

Contact:

• Pollution Prevention Office, Department of Environmental Conservation, 563-6529
  
• Community Right-to-Know Coordinator, Department of Environmental Conservation, 465-5220
  
• Division of Emergency Services, Department of Military and Veterans Affairs, 428-7000

Preventing Releases

Virtually all accidental releases can be prevented. Hazardous substance releases, however, are an all too common occurrence. Releases are costly for communities and facilities.

This fact sheet introduces cost effective options to prevent and mitigate chlorine releases. This information is intended as general guidance only. It is not a substitute for any applicable local, state or federal regulations. Specific release costs and facility prevention choices should be determined on a case-by-case basis. Contact the non-regulatory DEC Pollution Prevention Office, 562-6529, for more information or a copy of a more detailed report on ways to prevent chlorine releases.

Did You Know?

• In Alaska, chlorine gas is one of the most prevalent extremely hazardous substances. Chlorine gas is primarily used as a disinfectant by swimming pool, drinking water and wastewater facilities.

• Chlorine is a greenish-yellow gas with a characteristic odor. Chlorine is primarily a respiratory toxicant that can cause lung irritation, and death.

• Chlorine gas, by far, presents the greatest chemical threat to community populations in Alaska. According to the State and Regional Hazards Profile, there are 150 facilities in Alaska that use or store over 1,500 tons of chlorine at any one time. Based on population estimates, ten or more people could be affected by a release at almost 99% of these facilities.

• National studies indicate that approximately 75% of all accidental releases of hazardous chemicals occur at fixed facilities. Chlorine gas is one of the ten hazardous chemicals most commonly involved in a release, AND the one most likely to result in death or human injury due to a release.

What Are the Common Causes of Releases?

Operations and maintenance failures, equipment failures, and process failures are the three leading causes of accidental releases of chlorine. Significantly fewer releases are caused by unauthorized activity, natural events, and fires.

Operations and Maintenance Failures include lack of adequate training, standard operating procedures, safety programs, management commitment to safety, and faulty repairs and inattentiveness leading to leaks, overfills, and broken equipment.

Equipment Failures include defective equipment design, construction and installation that result in overflowing containers, and leaking piping, valves, and gaskets.

Process Failures include pressure, temperature, flow and fluid chemistry changes that result in tank and/or piping ruptures.

Available Facility and Hazardous Substance Information

Department of Environmental Conservation

• Release reports
  
• Annual Facility Hazardous Substance Reports
  
• State and regional hazards profiles
  
• Preventing Accidental Releases of Anhydrous Ammonia, Chlorine Gas & Bulk Fuels

• State Emergency Response Commission
  
• Local Emergency Planning Committee contacts.

Why Prevent Releases?

Preventing accidental releases of chlorine gas benefits both communities and facilities.

Communities Benefit From:

• Good image as a place to live and work with low risk to human health and safety from a release.
  
• Reduced costs from emergency response personnel responding to fewer or no releases.
  
• Cleaner environment creating opportunities for other businesses and increasing visitor popularity.

• Reduced costs due to fewer or no accidental releases.
  
• Increased worker satisfaction from employee awareness that management is concerned about safety.
  
• Good business practices resulting in fewer federal, state, and local restrictions on operations.

What Could Facility Release Costs Include?

Facility owners/operators and employees are not always aware of the full range of potential costs associated with an accidental release. Below are the types of costs that a facility may incur. For a general estimate of actual release costs, see the Chlorine Gas Release Scenario Costs fact sheet.

Facility Direct Costs

• Chemical loss
  
• Attorney's fees
  
• Equipment damage
  
• Waste disposal
  
• Clean up
  
• Public relations
  
• Process disruption
  
• Increased insurance premiums

• Property damage
  
• Economic loss
  
• Punitive damages
  
• Injury/loss of life

• Civil and criminal penalties
  
• Restoration and Damages
  
• Administrative penalties
  
• State expenses
  
• Attorney's fees

• Civil and criminal penalties
  
• Administrative penalties
  
• Cost recovery

What Can Be Done?

There are three basic categories of options that facilities can use to prevent and mitigate accidental releases.

1. Eliminate Releases - Eliminate the use of a hazardous substance by substituting a less or non-hazardous substance. This protects the facility and the surrounding community from a hazardous substance release. By eliminating the use of toxic substances a facility can also significantly reduce current and potential costs and liabilities. There are several alternatives to chlorine gas for water disinfection, however, many of them pose their own hazards. Substitutes include hypochlorites, chlorine dioxide, chloramines, ozone, and ultraviolet radiation. A facility must carefully review these options to determine whether they are feasible.

2. Reduce Risk - Build a comprehensive program to prevent accidental releases. This step can eliminate the greatest causes of hazardous substance releases: operations, maintenance, and equipment problems. Facilities with greater than 2,500 lbs of chlorine gas may soon be required by the Clean Air Act Amendments to start a pollution prevention program. A facility should identify risks and determine methods of limiting those risks throughout its operations, including:
   • Inventory reduction/control: Reduce inventories of hazardous substances to the minimum needed, to reduce the potential for releases.
     
   • Management systems: Ensure that management practices and worker training give priority to prevention and release reduction.
     
   • Personnel training: Ensure that all personnel are adequately trained.
     
   • Security measures: Improve security to minimize the potential for unauthorized activities.
     
   • Process design: Install additional sensors to allow better monitoring of process conditions.

3. Reduce Consequences - By installing and maintaining specific equipment and structures a facility is able to reduce the adverse affects of many releases, including those that may not be a function of the facility's operations, such as: natural events, fires, and unauthorized activities. A facility should identify its best options to mitigate accidental releases. Such options include:
   • Gas detectors: electrochemical gas detectors are commonly used to detect very low concentrations of chlorine. Early detection may allow time for repairs to be made using specifically designed chlorine emergency kits.
     
   • Containment systems: "coffins" can be used in some circumstances to enclose a leaking cylinder and remove it from the facility.
     
   • Treatment systems: scrubbers and absorption tanks are used to neutralize the chlorine before the gas is vented. Scrubbers are currently required by the Unified Fire Code for all new facilities using chlorine gas.

What Do Chlorine Gas Releases Cost?

The following scenario provides a rough idea of the cost ranges that are usually incurred as a result of a chlorine gas release from a water treatment facility. A specific facility may incur costs in some or all of these cost categories as the result of an accidental release.

Assumptions

Average size water treatment facility in Alaska	5 employees
Facility 16ses 75% of a one ton tank (1500 lbs)
People in area are alerted or evacuated

Usual Costs

These are the costs a facility usually must bear in the event of a release.

Chemical loss	$2,000
Process disruption (down time)	$10,000-20,000
Litigation (legal fees & personnel time)	$20,000-500,000
State penalties & cost recovery (DEC & OSHA)	$2,000-400,000
Equipment damage	$10,000-50,000
Public relations (advertising & personnel time)	$2,000-30,000
TOTAL	$46,000-1,002,000

(see full report for basis for estimate)

Possible Costs

Depending on the circumstances, these are additional costs a facility will often have to bear in the event of a release.

• Federal penalties and cost recovery: The EPA, Coast Guard and federal OSHA may all be able to assess penalties and/or collect expenses from the facility depending on agency jurisdiction. These fees can vary greatly.

• Third party suits: Property damage, injury/loss of life, economic loss, and punitive damage suits may be brought by the public against the facility. Depending on the outcome of these suits a facility may incur little or great (millions) additional costs.

• Increased insurance premiums: Worker's compensation and pollution insurance. Worker's compensation may increase according to a schedule, if a worker is injured and situation is not remedied. Pollution insurance is probably not a factor for a chlorine release because many facilities do not have it.