Pomona Valley Pool Chlor - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Pomona Valley Pool Chlor 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. Pomona Valley 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. STATIONARY SOURCE AND REGULATED SUBSTANCE Startup of the chlorine system occurred in 1971. The process is located at 2133 West Foothill Boulevard in Upland, California. The chlorine transfer process for Pool Chlor 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 20 pound cylinders are then used off-site to treat swimming pools. The transfer system is equipped with a sodium hydroxide solution scrubber tank to neutralize any chlorine residual in the piping once the transfer process is complete, thereby preventing the chlorine gas from escaping to the atmosphere. The maximum quantity of chlorine on site is 8,000 pounds of chlorine. HAZARD ASSESSMENT SUMMARY Worst Case Release Result Summary The worst case release for this facility was that of the maximum quantity of chlorine that can be stored in the largest vessel in 10 minutes. The largest vessel at this facility is a one ton chlorine container which holds a maximum of 2,000 pounds of chlorine. This vessel is stored outside, therefore, no passive mitigation measures were used. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed and F stability. The facility is located in an urban setting. The reference table, Exhibit 4-4, from EPA's RMP Guidance for Wastewater Treatment Plants was used to find the potential downwind distance to 3 ppm as a result of this worst case release scenario. The release reaches off-site and may affect population receptors. No environmental receptors were affected by this potential release scenario. Alternative Release Result Summary The alternative release was that of a 5/16 inch diameter leak from a pipeline containing liquid chlorine. Based on the pressure in the tank, the release rate was calculated to be 72 pounds/minute. Since there is no accident history at this facility, this release scenario was based on the possibility of a leak in the pipe line or a flange seal leak that continues until the tank is empty. The meteorological conditions used were 3 meters/second wind speed, and D stability. The facility is located in an urban setting. The reference table, Exhibit 4-12, from EPA's RMP Guidance for Wastewater Treatment Plants was used to find the potential downwind distance to 3 ppm for the alternative release scenario. This release reaches off-site and may affect population receptors. No environmental receptors were affected by this potential release scenario. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Pool Chlor has recently implemented 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, the chlorine r epackaging process is only operational one hour per day, five days per week. While the transfer process is not in operation, all chlorine tank valves are closed. Only two facility personnel are trained to operate the transfer process. FIVE YEAR ACCIDENT HISTORY There have been no reported releases of chlorine at this facility over the last five years since June 1994. EMERGENCY RESPONSE PROGRAM Pool Chlor has a Hazardous Materials Business Plan in effect at the facility and on file with the San Bernardino County Fire Department. The facility works closely with the local fire department and Continental Chemical, the chlorine supplier. The facility plans to contact 9-1-1 in the event of an emergency. In addition, Continental Chemical is available to respond to a release of chlorine. The facility has three full time employees on site. The Owner is designated as the Emergency Coordinator in the event of an emergency. In the event of a release of chlorine, the personnel will evacua te out the front of the building, opposite of the hazard, contact 9-1-1 and their neighbors in the building. PLANNED CHANGES TO IMPROVE SAFETY The Hazard Analysis, Hazard Assessment, and External Events Analysis studies provided the mitigation measures outlined below to improve safety at the Pool Chlor facility. The recommendations are scheduled to be implemented on or before December 1999. Process Hazard Analysis Recommendations R01 Review the operating procedures to ensure that they are an accurate representation. Review the operating procedures annually and certify that they are accurate. Use the operating procedures to train new employees. R02 Certify the two trained fill operators using the Senior Operator form included in the Training section of the PSM/RMP manual. R03 Add "warning" to the operating procedures to alert operators that they need to be prepared to stop the transfer process sooner when the ambient temperature is in excess of 100 F. COMPLETE R04 Add warning to operating procedures that Vent Valve should be closed during transfer process. COMPLETE R05 Prepare a Contractor Package for the Continental Chemical delivery driver to ensure he is aware of the hazards of chlorine and that he has had the proper training. R06 Conduct an informal inspection of the one ton containers that are delivered. This should include the general condition, currency of hydrostatic test, and valve protective housing. R07 Obtain data from Hammond Company for chlorine valves. R08 Consider the feasibility of installing a secondary containment for the 55 gallon drums (concrete curb or secondary tank). R09 Have employees sign certification that they have reviewed to Business Plan. External Events Recommendations S01: Consider securing each container using two nylon "Kevlok" straps which use a "come-along" buckle to ensure that the strap is tight (520-881-2130). Typically, these straps are rated at 5000 pounds. Two chains can be used to secure each container, but they must be kept tight around the container. S02: Consider driving metal spikes or re-bar through the wood tracks into the ground for added stability. |