Pool-Chem D.L.S. Enterprises, Inc. - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
Pool-Chem D.L.S. Enterprises, Inc. 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. 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-Chem D.L.S. Enterprises, 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, and to ensure that the
plan is kept current.
STATIONARY SOURCE AND REGULATED SUBSTANCE
Startup of the chlorine system occurred in 1977. The process is located at 3646 South 36th Street, Phoenix, AZ 85040. The chlorine transfer process for Pool-Chem D.L.S. Enterprises, Inc. 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. These cylinders are used off-site for the treatment of residential swimming pools.
The maximum quantity of chlorine on site is four one ton containers or 8,000 pounds.
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 measure
s 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 (November 1998) 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 pipeline or a flange seal leak. 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 (November 1998) 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-Chem D.L.S. Enterprises, Inc. 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, the chlorine repackaging process is only operational for a minimal amount of time per day, five days per week. While the transfer process is not in oper
ation, all chlorine tank valves are closed.
FIVE YEAR ACCIDENT HISTORY
There have been no reported releases of chlorine at this facility over the last five years (June 1994 through June 1999).
EMERGENCY RESPONSE PROGRAM
The Pool-Chem D.L.S. Enterprises, Inc. has an emergency response plan in effect at the facility. In the event of a chlorine release at the facility, the fill operator has been instructed to secure equipment by closing all valves. Then, the operator will evacuate area by sounding the emergency horn. There are two switches that will activate the alarm: at the chlorine fill station and inside the warehouse. This horn can be heard throughout the facility.
There is an emergency contact list that includes 9-1-1 and the Phoenix Fire Department Hazardous Materials division. In addition, there is a neighbor-call list. The facility has worked with the Fire Department and has available for their use a B-Kit for the one-ton chlorine containers and a Self Contained Bre
PLANNED CHANGES TO IMPROVE SAFETY
The Hazard Analysis provided the mitigation measures outlined below to improve safety at Pool-Chem D.L.S. Enterprises, Inc. These recommendations are expected to be implemented by December 15, 1999.
R01: Verify and update the neighborhood emergency telephone list once per year.
R02: 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 and/or route-men
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.
R04: Add warning to operating procedures that Vent Valve should be closed during transfer process. Also include instructions for how to proceed if Vent Valve is left open and liquid chlorine flows into the PVC pipeline.
R05: Consider usi
ng a cap (special fitting with no center-hole) for the flexible piping connection that attaches to the transfer container. Include attaching the cap in the shut down procedures.
R06: Review mechanical integrity forms and update as necessary.
R07: Prepare a certification for the existing operators to satisfy the initial training requirements (Grandfather Clause).
R08: Prepare training forms for on-the-job training certification for new operators.
R09: Consider labeling the valves based on the piping diagrams and incorporate the valve numbers in the operating procedures.
R10: Maintain equipment certificates for the life of the equipment.
R11: Install a windsock on the roof, visible by employees.
R12: Consider adding a containment dike for the caustic tank.
R13: Post the evacuation procedures with meeting location and telephone numbers in the office area and the warehouse area.
R14: Review emergency response plan on an annual basis and document this training session.