Pool Chlor of Nevada Inc. - Executive Summary

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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 
 
The Pool Chlor of Nevada Inc. facility has an emergency action plan in effect.  The Emergency Action Plan (Plan) is detailed in the Emergency Planning and Response section of the PSM/RMP document, which is maintained at the facility and updated as necessary.  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 of Nevada 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 com 
pliance with the PSM and RMP regulations, as well as to incorporate facility changes. 
 
Pool Chlor of Nevada Inc. has coordinated emergency response efforts with the local fire department.  In the case of a major chlorine-related emergency, it is the policy of Pool Chlor of Nevada Inc. to evacuate and to allow the fire department to respond to the emergency. 
 
 
STATIONARY SOURCE AND REGULATED SUBSTANCE 
 
The Pool Chlor of Nevada Inc. facility has been in operation since 1973.  The facility is located at 5560 Procyon Street in Las Vegas, Nevada  89118.  The system was constructed in accordance with all applicable federal, state, and local regulations. 
 
The Pool Chlor of Nevada Inc. facility receives and repackages liquefied chlorine into small 20 pound cylinders that are then used to treat water at local private residence swimming pools.  The maximum amount of chlorine on site is 8 one-ton containers (16,000 pounds).  The entire system including the fill station, one-ton containers, scrubb 
er tank and pump, is located outside under a canopy.  Misters are used to cool the chlorine containers during high temperatures. 
 
 
HAZARD ASSESSMENT SUMMARY 
 
*  Worst Case Release Result Summary 
 
     Scenario Description:  Release of the maximum quantity of chlorine that can be stored in a vessel (one-ton container) - 2,000 pounds in 10 minutes.  Since the chlorine system is located outside, no passive mitigation measures were taken into account.  The most pessimistic meteorological conditions were used: 1.5 meters per second wind speed, and F stability.  The Risk Management Program Guidance for Waste Water Treatment Plants reference tables were used to determine the maximum distance to the toxic endpoint of 3 ppm.  This release reaches off site and may impact population receptors.  No environmental receptors were affected by this potential release. 
 
*  Alternative Release Result Summary 
 
    Scenario Description: A release of chlorine from resulting from a 1/4 inch diameter hole in 
a pipe.  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 Risk Management Program Guidance for Waste Water Treatment Plants reference tables were used to determine the maximum distance to the toxic endpoint of 3 ppm.  This release reaches off site and may impact population receptors.  No environmental receptors were affected by this potential release. 
 
 
ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS 
 
The Pool Chlor of Nevada Inc. chlorine transfer system has many safety features.  Much of the safety of the system is inherent in the policies and procedures that govern the operation of the system.  For example, the Pool Chlor of Nevada Inc. facility operates in accordance with OSHA's Process Safety Management regulation. 
 
It is planned to install an emergency shut down switch that will activate (close) a motorized valve on the  
chlorine liquid supply line when pressed. 
 
In addition, common industry standards, policies, and procedures are utilized to ensure safe practices are being performed.  This includes common practices recommended by the Chlorine Institute. 
 
 
FIVE YEAR ACCIDENT HISTORY 
 
There have been no chlorine accidents at the facility since June 1994. 
 
 
EMERGENCY RESPONSE PROGRAM 
 
The Pool Chlor of Nevada Inc. has an emergency action plan in effect at the facility.  The Emergency Action Plan (Plan) is detailed in the Emergency Planning and Response section of the PSM/RMP document maintained at the facility.  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. 
 
In the event of a major chlorine emergency, Pool Chlor plans to evacuate the facility and call 9-1-1 to alert the local emergency responders.  Pool Chlor plans to coordinate emergency response efforts with th 
e local fire department on a periodic and ongoing basis. 
 
Pool Chlor of Nevada 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, as well as to incorporate facility changes due to the renovation of the facility. 
 
 
PLANNED CHANGES TO IMPROVE SAFETY 
 
The Process Hazard Analysis (PHA) provided mitigation measures to improve safety at the Pool Chlor of Nevada Inc. facility located at 5560 Procyon Street in Las Vegas, Nevada 89118.  The recommendations are scheduled to be complete by March 2000. 
 
R01    Consider installing crash posts at filli 
ng stations. 
 
R02    Consider providing gas masks, goggles/face shields, gloves, or other appropriate PPE to all employees as policy.  If it is decided to provide this equipment, ensure that the proper training is also provided. 
 
R03    Install a chlorine leak detector and the associated controls. 
 
R04    Document the actions taken by the chlorine sensor if a leak of chlorine is detected. 
 
R05    Update labeling on valves and controls. 
 
R06    Ensure that all operators are aware of what they are expected to do in case of an alarm at the facility. 
 
R07    Consider installing a remote shut down switch interlocked with a valve in the chlorine liquid feed line. 
 
R08    Post evacuation instructions including routes and assembly areas. 
 
R09    Consider posting emergency phone numbers in the office. 
 
R10    Establish a policy to hold and document an annual evacuation drill at the facility. 
 
R11    Consider installing manual isolation valves on either side of the scrubber pump. 
 
R12    Documen 
t the chlorine sensor monthly calibration test. 
 
R13    Consider having an off-site security company monitor the chlorine sensor during off-hours.
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