Bay Area Pool Chlor, Inc. - Executive Summary

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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 
 
Bay Area Pool Chlor, Inc. has an emergency response plan in effect.  The Emergency Response 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. 
 
Bay Area Pool Chlor, 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, RMP, and CalARP regulations, and to ensure that the plan is  
kept current. 
 
STATIONARY SOURCE AND REGULATED SUBSTANCE 
 
Startup of the chlorine system occurred on 1986.  The process is located at 291 Rickenbacker Circle, Livermore, CA 94550.  The chlorine transfer process for Bay Area Pool Chlor, Inc. consists of chlorine one-ton containers which are the storage vessels.  Chlorine liquid is dispensed from the one ton container through a filling manifold to a 15 pound cylinder.  The maximum quantity of chlorine on site is 16,000 pounds. 
 
HAZARD ASSESSMENT SUMMARY 
 
Worst Case Release Result Summary 
 
Scenario Description: Release of the maximum quantity of chlorine that can be stored in a vessel - 2,000 pounds in 10 minutes.  No passive mitigation measures were used.  The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed, and F stability.  Reference table from the EPA's RMP Guidance for Wastewater Treatment Plants was used to determine the distance for the toxic point of 3 ppm.  This release reaches off-site and may 
affect population receptors.  No Environmental receptors were affected by the potential release scenario. 
 
 
Alternative Release Result Summary 
 
Scenario Description: A release of chlorine gas from 5/16 inch diameter leak.  The release rate of chlorine due to the pressure of the tank is 72 pounds/minute, however, because the system is located inside the building passive mitigation was considered when determined the maximum down wind distance.  The meteorological conditions used were 3 meters/second wind speed, and D stability.  Reference table from the EPA's RMP Guidance for Wastewater Treatment Plants was used to determine the distance for the toxic point of 3 ppm.  This release reaches off-site and may affect population receptors.  No Environmental receptors were affected by the potential release scenario. 
 
ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS 
 
Bay Area Pool Chlor, 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 being performed.  This includes common practices outlined by the Chlorine Institute and the National Association of Gas Chlorinators. 
 
FIVE YEAR ACCIDENT HISTORY 
 
There has been a release of a chlorine at the Bay Area Pool Chlor, Inc. on February 26, 1997.  The accident was noted during the Process Hazard Analysis study that approximately 5 pounds of  chlorine was released.  The causes of the release, the facility's subsequent actions, and the mitigation measures that resulted from the incident were discussed as part of the PHA study. 
 
EMERGENCY RESPONSE PROGRAM 
 
The Bay Area Pool Chlor, Inc. has an emergency response plan in effect at the facility.  The Emergency Response Plan (Plan) is detailed in the Emergency Planning and Response section of the PSM/RMP document.  This Plan was designed to meet the following objectives:  
 
1.) To save lives. 
2.) To minimize and avoi 
d injuries. 
3.) To protect the environment. 
4.) To minimize property damage. 
 
The Bay Area Pool Chlor, Inc. maintains a safety committee whose members include the emergency coordinators for the facility.  The Plan provides the response organization and notification procedures, evacuation routes, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility.  
 
The Plan also includes the Emergency training for all Bay Area Pool Chlor, Inc. employees.  Bay Area Pool Chlor, Inc. performs periodic emergency evacuation drills to enhance the emergency response skills of its personnel. 
 
The Emergency Response Plan is reviewed and updated by the Bay Area Pool Chlor, Inc. responsible person, Mr. Kim A. Skinner at least once a year.  This Plan will be review and updated to ensure compliance with the PSM, RMP, and CalARP regulations, and to ensure that the plan is kept current.  
 
PLANNED CHANGES TO IMPROVE SAFETY 
 
The Hazard Analy 
sis provided the mitigation measures outlined below to improve safety at Bay Area Pool Chlor, Inc.  The changes will be completed by March 1, 2000. 
 
R01 Consider posting emergency telephone number near the telephones and outside the chlorine room entrance. 
 
R02 Consider installation of visible chlorine alarm (i.e., red light) outside the chlorine room entrance. 
 
R03 Consider feasibility of installation of a thermal expansion device.     
 
R04 Ensure that the delivery trucks are properly chocked prior to unloading the chlorine containers. 
 
R05 Install a windsock visible from all side of the building. 
 
R06 Conduct an evacuation drill at least once a year and document the results. 
 
R07 Post floor plans and/or work place maps with evacuation instructions. 
 
R08 Prepare an emergency response plan including evacuation procedures and rally location. 
 
R09 Test the chlorine detector in accordance with the manufacturer's recommendation at least once a month. 
 
R10 Ensure that piping and  flexible line 
are inspected daily in accordance with the manufacturer's requirements. 
 
R11 Ensure that the scrubber system is inspected daily for operation.  Check caustic concentration and add if necessary. 
 
R12 Test the chlorine detector in accordance with the manufacturer's recommendation at least once a week.
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