MLS Superior Pool Service, Inc. - Executive Summary

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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 
 
Superior Pools 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. 
 
Superior Pools 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. 
 
 
STATIONARY SOURCE AND R 
EGULATED SUBSTANCE 
 
The business was established in 1987 and startup of the chlorine system at its present address occurred in 1995.  The process is located at 7952 W. Gold Dust, Suite #4, Peoria, Arizona 85345.  The chlorine system for Superior Pools consists of chlorine one-ton containers which are the storage vessels.  Chlorine liquid is drawn from the ton container to 20 pound cylinders.  Below provides a list of the chlorine equipment. 
 
Chlorine Tanks (one ton containers) 
(2 - Operational Amount): Located inside and outside of warehouse facility. 
 
Chlorine Tank (20 lb. container) 
(50 - Maximum that can be stored): Located within the warehouse facility. 
 
Filling Manifold: Located at the south end of the facility. 
 
Scrubber System: Located at the south end of the facility. 
 
The maximum quantity of chlorine that can be stored on site is 6,000 pounds. (3 one-ton containers) 
 
 
HAZARD ASSESSMENT SUMMARY 
 
Worst Case Release Result Summary 
Scenario Description: Release of the maximum quan 
tity of chlorine that can be stored in a vessel - 2,000 pounds in 10 minutes.  The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed, and F stability. The reference table from the EPA's RMP Guidance for Wastewater Treatment Plants was used to determine the distance to the toxic endpoint of 3 ppm in urban conditions.  This release reaches offsite and may affect public receptors.  No environmental receptors were affected by this potential release. 
 
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 per minute.  The meteorological conditions used were 3 meters per second wind speed, and D stability.  The reference table from the EPA's RMP Guidance for Wastewater Treatment Plants was used to determine the distance to the toxic endpoint of 3 ppm in urban conditions.  This release reaches offsite and may affect public recept 
ors.  No environmental receptors were affected by this potential release. 
 
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 due to the unequal distribution within the tract.  Based on visual observation of the area, no residences are in the imediate vicinity of the facility. 
 
 
ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS 
 
Superior Pools 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.  In addition to the Management Programs, there is a scrubber sys 
tem that is used to neutralize any residual chlorine gas in the vent line while transferring chlorine. 
 
 
FIVE YEAR ACCIDENT HISTORY 
 
There has been no reportable release of chlorine at the facility. 
 
 
EMERGENCY RESPONSE PROGRAM 
 
If a release of chlorine were to occur, Superior Pools' response plan is to call 911 in order to reach the Fire Department's HAZMAT team.  A B-kit for ton containers is available for the responders in order to mitigate a chlorine release.  Employees will evacuate the facility to a point that is upwind of the hazard.  Evacuation drills are performed annually.  The emergency response plan provides the response organization and notification procedures, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility.  This plan was reviewed and updated to ensure compliance with the PSM and RMP regulations, and to ensure that the plan is kept current. 
 
 
PLANNED CHANGES TO IMPROVE SAFETY 
 
The Process H 
azard Analysis (PHA) provided the mitigation measures outlined below to improve safety at Superior Pools.  The PHA was comprised of one session that included a "What-if" analysis, and a series of checklists.  The recommendations were made to improve safey and are scheduled to be implemented by June 2000: 
 
R01  Ensure that the HazMat team has a qualified responder to use the B-kit. 
 
R02  Consider feasibility of purchasing a coffin for the 20 pound cylinder in case the 20 pound cylinder valve leaks. 
 
R03  Consider feasibility of installing a fire alarm. 
 
R04  Give neighbors emergency phone numbers in case of a chlorine release, fire, etc.  Inform them to evacuate to Gold Dust Ave. or shelter-in-place if a chlorine release occurred. 
 
R05  Coordinate with the Fire Department that they should  go directly to the maintenance manager in the event of a release of chlorine or fire after hours.  Post a sign at the gate entrance that will alert a responder to this. 
 
R06  Coordinate with the HazMa 
t team to use the SCBA located within the warehouse if necessary.  Have the SCBA tested for tank pressure. 
 
R07  Install metal posts around the tank located outside of the warehouse building.  Ensure that they will not be a hindrance for forklifts during chlorine deliveries. 
 
R08  Review the Operating Procedure and Mechanical Integrity sections of the PSM/RMP to ensure that the procedures are consistent with Superior Pools. 
 
R09  Have Material Safety Data Sheets available on site for employees to read and understand the effects of chlorine. 
 
R10  Place cones around the supplier's truck during deliveries. 
 
R11  Consider feasibility of installing a wind sock. 
 
R12  Install an eyewash basin inside the warehouse area and ensure fresh water is maintained in the unit.  Include in the Operating Procedures that the warehouse roll-up door remains open during filling operations.
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