RBD Enterprises DBA Pure Water Pool Service - Executive Summary

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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 
 
Pure Water Pool Service 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. 
 
Pure Water Pool Service 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. 
 
ST 
ATIONARY SOURCE AND REGULATED SUBSTANCE 
 
Startup of the chlorine system occurred on 1983.  The process is located at 13704 Thermal Dr., Austin, Texas 78728.  The chlorine transfer process for Pure Water Pool Service 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 20 pound cylinder.  The maximum quantity of chlorine on sie 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.  No passive mitigation measures were used.  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 for the toxic endpoint of 3 ppm for an urban area.  This release reaches off-site and may aff 
ect 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.  The meteorological conditions used were 3 meters/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 for the toxic endpoint of 3 ppm for an urban area.  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 
 
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 and the National Association of Gas Chlorinators. 
 
FIVE YEAR ACCIDENT HISTORY 
 
There have been no reported released of chlorine at this facility over the last five years (6/21/94 through 6/21/99). 
 
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.  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 Hazard Analysis provid 
ed the mitigation measures outlined below to improve safety at Pure Water Pool Service.  The changes will be completed by May 31, 2000. 
 
R01  Install a chlorine sensor/alarm system.  Ensure that alarm activation will notify emergency response personnel and the fire department. Document the actions taken by the chlorine sensor if a leak of chlorine is detected.  Test the sensor/alarm system regularly. 
 
R02  For all PPE (such as gas masks, goggles/face shields, gloves, etc.) ensure that proper training is provided and documented. 
 
R03  Ensure that all inspections and testing of equipment is documented. 
 
R04  Provide labeling for valves and controls. 
 
R05  Ensure that all operators and employees are aware of what they are expected to do in case of an alarm at the facility. 
 
R06  Install and locate a windsock such that employees can see it from all areas of the facility. 
 
R07  Consider installing a remote shut down switch interlocked with a valve in the chlorine liquid feed line. 
 
R08  Inc 
lude emergency phone numbers for Roam Dunn and Mark Tarpley in emergency notification list. 
 
R09  Establish a policy to hold and document an annual evacuation drill at the facility. 
 
R10  Consider providing CPR training for operators.
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