Advanced Leisure Services, Inc. DBA Pool Chlor - Executive Summary

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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 
 
Pool Chlor 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. 
 
Pool Chlor 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 REGUL 
ATED SUBSTANCE 
 
Startup of the chlorine system occurred in 1988.  The process is located at 2218 Executive Dr., Garland, Texas 75041.  The chlorine transfer process for Pool Chlor consists of chlorine one-ton containers (maximum of 10) which are the storage vessels.  Chlorine liquid is dispensed from a one ton container through a filling manifold to a 15 and 20 pound cylinders (maximum of 140).  The system also includes a scrubber water tank and pump.  The maximum quantity of chlorine on site is 20,000 pounds.  The filling station is located under a canopy and behind a fire wall.  The transfer containers are located in a chilled storage container. 
 
 
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. The r 
eference table from the EPA's RMP Guidance for Wastewater Treatment Plants was used to determine the distance to the toxic endpoint of 3 ppm.  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.  This release reaches offsite and may affect public receptors.  No environmental receptors were affected by this potential release. 
 
 
ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS 
 
Pool Chlor 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.  In addition to the Management Programs, there is a scrubber system that is used in conjunction while transferring chlorine.  The facility plans to upgrade the current chlorine sensor.  The sensor will be tied to an off-site alarm company who will notify the fire department.  The sensor will also be tied to an alarm which will alert operators on-site.  A fire wall is installed around the ton containers in order to protect the chlorine ton containers from excessive hear from fire. 
 
 
FIVE YEAR ACCIDENT HISTORY 
 
There have been no reported releases of chlorine at this facility over the last five years (6/21/94 through 6/21/99). 
 
 
EMERGENCY RESPONSE PROGRAM 
 
Pool Chlor employees and contractors will report releases or spills of ha 
zardous substances an any other emergency situation to Larry Bickmore.  Larry Bickmore, the Incidend Coordinator, will immediately be informed of the emergency situation and its location.  The IC or designated alternate will evaluate and identify the extent and details of the emergency.  Ultimately the Incident Coordinator will need to decide: 
 
1.  If evacuation is necessary, and if so, which employees/contractors need to evacuate. 
 
2.  If the primary assembly location is not appropriate (due to weather conditions), action must be taken to direct employees and contractors to the secondary assembly location.  And if outside assistance (emergency response team) is needed and who should. 
 
3.  The Incident Coordinator also needs to communicate to the outside assistance personnel and the personnel from Pool Chlor (who are helping with the mitigation) as much information from the Hazardous Materials Incident Report as possible.  This will help with the mitigation and the evacuation. 
 
 
PLANNE 
D CHANGES TO IMPROVE SAFETY 
 
The Process Hazard Analysis (PHA) provided the mitigation measures outlined below to improve safety at Ft. Worth Pool Chlor.  The recommendations are scheduled to be implemented by June 2000. 
 
R01 Ensure that the new chlorine sensor/alarm system is installed in a timely manner.  Document the actions taken by the chlorine sensor if a leak of chlorine is detected. 
 
R02 For all personal protective equipment (such as gas masks, goggles/face shields, glove, etc.) ensure that proper training is provided and documented. 
 
R03 Provide labeling on valves and controls. 
 
R04 Ensure that all operators are aware of what they are expected to do in case of an alarm at the facility. 
 
R05 Install and locate the windsock such that employees can see it from all areas of the facility. 
 
R06 Consider installing a remote shut down switch interlocked with a valve in the chlorine liquid feed line. 
 
R07 Post evacuation instructions including routes and assembly areas. 
 
R08 Post emerg 
ency phone numbers in the office. 
 
R09 Establish a policy to hold and document an annual evacuation drill at the facility.
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