Aqua Clear Pools, Inc. - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
Aqua Clear Pool, Inc. has an emergency action plan in effect. The Emergency Action Plan (Plan) is detailed in the Emergency Planning and Response section of this PSM/RMP document. This Plan was designed to meet the following objectives:
1.) To save lives.
2.) To minimize and avoid injuries.
3.) To protect the environment.
4.) To minimize property damage.
Aqua Clear Pool, Inc. maintains a safety committee whose members are the designated emergency coordinators for the facility. The Plan provides the response organization and notification procedures, evacuation routes, chlorine health hazards, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility. This Plan is reviewed and updated at least once per year. This Plan was reviewed and updated to ensure compliance with the PSM and RMP regulations, and to ensure that the plan is kept current.
TATIONARY SOURCE AND REGULATED SUBSTANCE
Aqua Clear Pool, Inc. facility, located in Chatsworth, California, is located approximately two miles south of Highway 118 and six miles west of Highway 405. The area immediately surrounding the facility is industrial. A residential population exists approximately one-half mile to the northeast of the facility.
One-ton chlorine containers are stored in an outdoor, shaded area at the north end of the offices and supplies building. Crash posts are positioned around the chlorine area to protect the cylinders from vehicle impact. A maximum of eleven cylinders are stored on site at any given time.
The Aqua Clear Pool, Inc. facility repackages liquid chlorine to purify water at swimming pool locations throughout Los Angeles county. There are two manifolds used in the transfer process of liquid chlorine from one-ton containers to 20-25 pound containers. Any chlorine vapor that is displaced from the 20-25 pound container is vented to an eject
or system and scrubbed with water.
The maximum quantity of chlorine on site is 22,000 pounds.
The facility noted four full time employees on-site in Item 1.11. It should be noted that there are additional employees who work off-site. They visit the facility in the morning to pick up supplies and then spend the rest of the day working off-site.
HAZARD ASSESSMENT SUMMARY
Worst Case Release Result Summary
The worst case release for this facility was that of the maximum quantity of chlorine that can be stored in the largest vessel in 10 minutes. The largest vessel at this facility is a one ton chlorine container which holds a maximum of 2,000 pounds of chlorine. This vessel is stored outside, therefore, no passive mitigation measures were used. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed and F stability. The facility is located in an urban setting. The reference table, Exhibit 4-4, from EPA's RMP Guidance for Wastewater Treatment Plan
ts was used to find the potential downwind distance to 3 ppm as a result of this worst case release scenario. The release reaches off-site and may affect population receptors. No environmental receptors were affected by this potential release scenario.
Alternative Release Result Summary
The alternative release was that of a 5/16 inch diameter leak from a pipeline containing liquid chlorine. Based on the pressure in the tank, the release rate was calculated to be 72 pounds/minute. Since there is no accident history at this facility, this release scenario was based on the possibility of a leak in the pipeline or a flange seal leak. The meteorological conditions used were 3 meters/second wind speed, and D stability. The facility is located in an urban setting. The reference table, Exhibit 4-12, from EPA's RMP Guidance for Wastewater Treatment Plants was used to find the potential downwind distance to 3 ppm for the alternative release scenario. This release reaches off-site and ma
y affect other industrial facilities. No residental areas or environmental receptors were affected by this potential release scenario.
NOTE: The population was estimated using 1990 census tract data with the Landview. III Environmental Mapping Software. When calculating population densities for large areas which encompass many tracts, the accuracy is rated as good; however, for small areas that encompass only two or three partial tracts, the population data may be skewed on the high side due to the unequal distribution within the tract. A visual inspection of the area potentially affected by the alternative release scenario revealed no houses or apartment complexes.
ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
Aqua Clear Pool, Inc. has a Process Safety Management program in place to manage the handling of chlorine. In addition, common industry standards, policies, and procedures are utilized to ensure safe practices are be
ing performed. This includes common practices outlined by the Chlorine Institute and the National Association of Gas Chlorinators.
Two trained and experienced operators are present during the repackaging operation.
No flammables are stored near the chlorine Fill Station.
The Aqua Clear facility is enclosed by a fence with access allowed only through two driveways. During off hours, the main gate is locked to prevent access. There is a security system for the buildings that will notify an alarm monitoring company (Westinghouse) in the event of an intrusion. This system will also call the emergency response team in the event of a chlorine release (chlorine detector connected with main security/alarm system).
The one ton filling system is manned by two trained operators during the repackaging operation. The hours of actual repackaging are limited to an annual average of 1-2 hours per day, five days per week. Containers are closed and stored during non-r
The one ton filling system can be isolated by closing the Jamesbury ball valves. Both the transfer cylinder and the one ton container valves can be closed, and the vent valve will be opened to purge the line if necessary. Finally, there are two scales in use to prevent overfilling due to a mis-calibrated scale.
FIVE YEAR ACCIDENT HISTORY
There have been no reported releases of chlorine at this facility over the last five years since June 1994. It should be noted that this operation has never had an uncontrolled release of chlorine since beginning operations in North Hollywood in 1988.
EMERGENCY RESPONSE PROGRAM
In the event of an uncontrolled leak, plant personnel will assess the immediate situation. If necessary, the Los Angeles City Fire Department (LACFD) will be contacted through the 911 exchange. The LACFD will be advised of the occurrence and provide response personnel if required for the emergency. CHLOREP can be contacted by calling (304)843-1300.
Plant personnel shall guide and render assistance to responding agencies and coordinate containment procedures, as required.
The Office of Emergency Services will be notified if any release is of a reportable quantity by calling (800)852-7550.
The Mission Hills Medical Center, 10306 Sepulveda Boulevard, will be used as the primary receiving medical center. Physicians have been notified that chlorine inhalation treatment should be administered to any victims and routine examination for evidence of pulmonary edema (water in the lungs), initiated if any cases are severe enough to warrant such attention. Both city emergency and private transportation will be used to convoy victims to the Hospital.
PLANNED CHANGES TO IMPROVE SAFETY
The Hazard Analysis provided the mitigation measures outlined below to improve safety at Aqua Clear Pool, Inc. The recommendations are scheduled to be implemented on or before June 1, 2000.
1. Consider installing a solenoid actuated shut off valve at the
one ton container that can be actuated at a remote location to isolate a release.
2. Consider installing an "extention arm" for the fill valve situated at the one ton container. This would allow for easy shut down in the event of a release during the fill procedure.