RBD California, Inc., DBA Pure Water Pool Service - Executive Summary

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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 
 
DBA Pure Water Pool Service has an emergency response plan in effect.  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 avoid injuries. 
3.)To protect the environment. 
4.)To minimize property damage. 
 
DBA Pure Water Pool Service maintains an emergency plan which 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 REGULATED SUBSTANCE 
 
Startup of the chlorine system 
occurred in 1999.  The process is located at 5012A Salida Blvd., Salida, California 95368.  The chlorine system for DBA Pure Water Pool Service consists of chlorine one-ton containers which are the storage vessels.  Chlorine gas 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 and Maximum Amount) 
 
Filling Manifold 
 
Scrubber Sytem 
 
The maximum quantity of chlorine that can be stored on site for the DBA Pure Water Pool Service is 4,000 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.  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.  
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 
 
DBA Pure Water Pool Service 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 system that is used in conjunction while transferring chlorine.  A manual alarm is located near the chlorine fill station which can be activated to warn employees in the case of a chlorine release.  The area is secured with crash posts and the ton containers are secured to stands in case of an earthquake. 
 
 
FIVE YEAR ACCIDENT HISTORY 
 
There have been no releases of chlorine at the DBA Pure Water Pool Service within the last five years (June 1994 through June 1999). 
 
 
EMERGENCY RESPONSE PROGRAM 
 
If a release of chlorine were to occur, DBA Pure Water Pool Service's response plan is to call 911 in order to reach the Fire Department's HAZMAT team.  DBA Pure Water Pool Service has a B-kit available at the facility for the HAZMAT team's use 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 Hazard Analysis (PHA) provided the mitigation measures outlined below to improve safety at DBA Pure Water Pool Service. The PHA was comprised of one session that included a "What-if" analysis, and a series of checklists.  The following recommendations were made during this study and will be completed by June 200: 
 
R01) Verify that procedures in place state that only the president and the manager perform chlorine deliveries with the vendor. 
 
R02)  Consider installing a chlorine detector near the chlorine fill station which is ti 
ed to an outside alarm company who will notify the proper personnel/authorities of an alarm. 
 
R03)  Coordinate with the Fire Department (HAZMAT team) that a B-kit and SCBAs are available in case of a chlorine release, and the necessary contact phone numbers in order to reach a responsible person at the facility. 
 
R04) Post a chlorine health diamond on the building or gate. 
 
R05)  Verify that the operating procedures in the Process Safety Management program are a correct representation of those used at DBA Pure Water Pool Service. 
 
R06)  Verify that the Mechanical Integrity section in the Process Safety Management program is a correct representation of DBA Pure Water Pool Service's maintenance program. 
 
R07)  Install a wind sock so that is visible from all locations of the building. 
 
R08) Post emergency phone numbers (business phone number, chlorine vendor's phone number) on the front gate so that emergency responders (HazMat team) can contact a responsible party. 
 
R09)  Perform annual  
evacuation drills for the entire facility.
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