Three local news articles (here,
here,
and here)
about a chlorine gas leak at a pool chemical manufacturing facility in
Westlake, LA that lead to local shelter in place warnings and a diversion of
traffic on nearby Interstate 10. No injuries have been reported. The leak
apparently occurred in a chlorine gas pipeline coming into the plant. The cause
of the leak has not been reported.

A post-hurricane chlorine leak and fire at the facility
almost three years ago is still under
investigation
by the Chemical Safety Board.

While this leak was probably (still have not heard a number
for the amount of chlorine released) reportable under various EPA regulations,
this incident does not appear to rise to a level that would require reporting to
the chemical Safety Board under 40
CF 1604
. With no serious injuries reported and no reported damage to the
facility, this would not be a reportable release from the CSB’s point of view.

This type of incident calls into question the regulations
reliance on ‘property damage’ as an assessment of the degree of hazard
associated with a release. While there may have been some damage to the
pipeline (do not know yet) that resulted in the release it is unlikely to have
risen to $1-million standard for ‘substantial property damage’, there were
other damages incurred both at the facility and in the surrounding community
that could have risen above that target value. According to the news articles,
the shelter-in-place order affected production at at least one other chemical
facility and impacted homes and businesses within 1-mile of the facility.
Additionally, the diversion of traffic on a major interstate (not to mention
local roads in the shelter-in-place area) would have imposed some additional
costs on those vehicles diverted, a minimal time and fuel cost on an individual
basis, but in aggregate that could be a substantial number.

These outside costs incidental to the release would be hard
for the facility owner to know in advance or calculate on the fly. If I were
crafting the authority for the CSB rule today, I would require them to include
a standard for off-site effects from a release beyond serious injuries or
substantial property damage that take into account the size of a
shelter-in-place, or evacuation order or the number of people affected by such
orders.

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Author Of this post: PJCoyle

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