All American Pools - Executive Summary |
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Federal Mandated RMP Submission Executive Summary 1. Accidental release Prevention and Emergency Response Policies The subject facility stores and repackages chlorine, which is considered a hazardous material that is a regulated substance and is considered in this Risk Management Plan (RMP) The properties of chlorine make it necessary to observe safety precautions in handling chlorine to prevent human exposure, and to reduce the threat to the facility's workers and nearby members of the community. It is the facility's policy to adhere to all applicable Federal and State rules and regulations. Safety depends upon the safe procedures used to handle chlorine; the safety devices and systems designed and constructed into the facility; and the training of the pertinent personnel. 2. Stationary Source and Regulated Substances Handled The subject facility provides chlorination service to swimming pools. Chlorine is repackaged at the facility from one-ton chlorine containers to twenty pound capacity service cylinders. The twenty pound service cylinders are used by the facility's service staff to chlorinate customer swimming pools. The facility operates five days a week (M-F), ten hours a day, and fifty weeks a year. The Fill Yard is used exclusively for the storage and repackaging of chlorine. The yard area provides adequate room for the delivery and parking of chlorine delivery vehicles during the off-loading of full one-ton containers and the loading of empty one-ton containers. The Fill Yard is not exposed to vehicular traffic. The Fill Yard houses all of the chlorine containers and is locked after normal working hours. Company policy does not allow unauthorized personnel entry into the building. Container handling and storage is per Sections 2.6, 2.7, and 2.8 of the Chlorine Institute's Chlorine Manual. The amount of chlorine packaged per month is seasonally dependent. The summer months, for obvious reasons, are the busiest times of the year. Consequently, the qua ntity of chlorine on site is highest during this period. The subject facility stores a maximum of _____ pounds of chlorine. This amount includes the content of _____ one-ton containers, _____twenty pound cylinders, and the one-ton container in the repackaging process. Chlorine is purchased from and delivered by commercial chlorine suppliers. Delivery of one-ton containers is during normal working hours. The one-ton containers, up to a maximum of _____, are stored in the Fill Yard. Off-loading of the one-ton containers from the commercial delivery vehicle is accomplished with a hoist or a lift gate. The one-ton containers are placed on the rails in the Fill Yard. The one-ton containers are manually rolled to the desired location and chocked to prevent movement. Empty and full twenty pound cylinders are segregated and are chained or strapped into place in an upright position. The company has administrative procedures in place that limits the amount of chlorine at the facility to no mor e than _____ one-ton containers and _____ each twenty pound cylinders for a total of _____ pounds. The procedure,in part, requires the owner\operator to verify existing chlorine inventory to ensure that an order and delivery of a one-ton container will not cause the aggregate quantity to exceed _____ pounds. Chlorine is repackaged as a liquid from one-ton containers into twenty pound net capacity, D.O.T. approved, cylinders. Any residual chlorine in small diameter, short length piping is directed into a liquid caustic absorption scrubber. The twenty pound cylinders are transported by company service to customer's swimming pools where the service personnel dispense the chlorine as a gas into the pool. The twenty pound cylinders are owned by the company and maintenance is performed in accordance with the Chlorine Institute's Pamphlet 17 Cylinder and Ton Container Procedure for Chlorine Packaging. The receipt, storage, and repackaging of chlorine is considered a single process. The majo r components of the chlorine system are: the one-ton D.O.T. approved cylinders, the proprietary transfer piping assembly, the twenty pound capacity D.O.T. approved cylinders, the pan scale for weighing the cylinders during the filling operation, and the chlorine absorption system. A proprietary tube assembly is attached toe the lower (liquid level) angle valve on the operating one-ton container and an empty service cylinder is brought into place on a pn scale and attached to the other end of the transfer assembly. Filling commences by opening the one-ton container liquid valve, the cylinder valve, and the other in-line valves in the transfer assembly. After filling, which is indicated by weight on the pan scale reaching the desired value, the cylinder valve and liquid chlorine valve on the transfer assembly are closed, and the transfer tubing is evacuated by means of the educator in the chlorine absorption system, prior to disconnecting the full service cylinder. The caustic solution comprising the absorption medium is prevented from being sucked back into the system using the unique design of the proprietary and confidential part of the chlorine packaging system. Batch filling is accomplished by placing up to two cylinders on separate pan scales attaching the cylinders to the appropriate transfer assembly connectors. The repackaging system is operated under pressure from the chlorine container. The portion of the system on the scrubber side of the normally closed in line valve is under vacuum at all times. At the end of a batch fill, the valves on the cylinders are closed, the in line valve to the manifold is closed, and a very small amount of residual chlorine in the in line is routed to the caustic scrubber by opening the normally closed in line valve between the manifold and the scrubber. Operational and test procedures are in place which ensure that the scrubber system is operating correctly. Chlorine is not vented to the atmosphere under any circumstances. Full twenty pound cylinders are stores in the repackaging area until loaded onto delivery trucks. Transport and loading of the cylinders adheres to the Chlorine Institute's Guidelines for Chlorine Cylinders, Pamphlet 76. Filling is done by trained, qualified personnel during daylight hours. Written filling procedures exist and are complied with. The entire system is evacuated and the one-ton container liquid valve is shut during non-working hours. Filling personnel wear escape type respirators. An emergency drench shower\eyewash unit is located at the Fill Yard. 3a. Worst Case Release Scenario The worst case release scenario must consider the largest quantity of a regulated substance handled on site in a single vessel at any time, taking into account administrative controls on the vessel's contents and usage as per 40 CFR Part 68 Section 68.25. A one-ton container of chlorine is the largest vessel in the chlorine repackaging system. The one-ton container is, at most, filled with 2000 lbs of liquid chlorine. The worst case release scenario for the one ton container of chlorine is the release of the 2000 lbs. Of chlorine at the rate of 200 lbs. per minute, for 10 minutes. The distance to the endpoint of 3 ppm for the worst case scenario release will extend beyond the boundaries of the stationary source. 3b. Alternative Release Scenario The alternative release scenario for the one-ton containers of chlorine is a small leak occurring in the packing material around the valve stem of the vapor phase valve located on the one-ton container. There are no passive or active mitigation measures that would reduce the amount of chlorine released. |