Nevada Chemical Company - Executive Summary |
`EXECUTIVE SUMMARY The Company has established a comprehensive Process Safety Management Program incorporating policies, procedures and training which will provide for the safe handling of chlorine. Procedures provide for a "Fail Safe" mode of operation, where the chlorine transfer lines are tested every time they are connected and before transfer begins, This is a daily activity. The company's service for residential swimming pools includes the disinfection of pool water with chlorine gas. Chlorine gas treatment of pools has proven to be the most effective method of disinfection as well as providing the highest water clarity. IT is not only the preferred treatment by most pool owners, but provides for a better general state of public health related to residential pools. Process Description: Chlorine is received in one-ton shipping and storage containers which are provided by the manufacturer. One-ton containers have been in use for well over 50 years; the design and maintenance of these containers has proven to be highly reliable and safe for transporting and storing chlorine. They are also designed for rugged transportation and are virtually indestructible. Special emergency repair kits are kept an hand to stop a leak from any point of the container, whether it be the valve , fusible safety plugs, or on the container itself. The primary activity at the facility is to transfer chlorine form the one-ton container into a number of small cylinders which hold 20 pounds of chlorine. It is these smaller cylinders which are carried to the pool site for use. The filling system is equipped with a vent system to absorb any residual chlorine from the transfer lines after filling is complete. There is essentially no chlorine released to the atmosphere during or after this operation. Once again, note that all lines are leak tested prior to chlorine transfer; this is a daily event. Emergency Response Plan: The facility maintains a wri tten Emergency Action plan which establishes responsibilities and predetermined actions to follow in the event of an emergency. Prevention is a major part of the company's operating policy, and to insure an emergency doesn't occur, the storage and transfer area are located in a separate protected area, extensive daily leak checks are performed before any transfer takes place, and equipment is inspected and tested regularly, and replaced as needed as part of a preventive maintenance program. A comprehensive training program is also designed to insure only trained and qualified personnel handle chlorine. Emergency Response Program: The Emergency Response Program provides for coordination with outside emergency response agencies. Primary response will be performed by trained emergency response personnel. Training and/or drills are conducted periodically. The plan also provides for procedures to notify the public if needed during an emergency. Five Year Accident Hist ory: There have been no accidents, releases, or incidents involving chlorine at the facility during the past five years, or prior to that. Worst Case Scenarios: Two worst case scenarios were evaluated to determine the potential off site impact from a release of chlorine. The first scenario, which is specified by the guidelines calls for the release of the entire contents of the largest container within a ten minute period. This also must be evaluated for the absolute worst case weather conditions. That is during a calm night when the highest off site concentrations would occur. This scenario shows a potential adverse impact up to 4.5 miles from the source. The same release occurring during the worst day time conditions would have a potential effect up to 2.5 miles from the source. Alternate Worst Case Scenario: A more realistic alternate worst case scenario was evaluated, and showed a potential adverse impact for a distance of 600 yards. This scenario is based on a total line break during a filling operation, and also assuming the operator can not close the main shutoff valve, which is easily accessible. Prevention Program: A comprehensive "Prevention Program" has been instituted to insure hazardous chemicals are safely handled and the risk of an accident or release are minimized. A "Process Hazards Analysis" was performed to review the design and operation of the chlorine filling and storage area. This evaluation identified potential accident scenarios which are addressed in the design of the equipment and incorporated in the training and operating procedures. The program also provides for policies and procedures for contractors, maintenance, and any future modifications to the system. Planned Safety Improvements: Chlorine handling equipment and procedures have been refined many years ago and have proven to be highly successful. The "Process Safety Analysis" indicated that the system and procedures are adequate . However, based on potential hazards identified in this detailed analysis, training and operating procedures are being revised to more thoroughly address these items. |