California Pool Chem. - Executive Summary
EXECUTIVE SUMMARY FOR RMP |
1. Accidental Release Prevention and Emergency Response Policies
California Pool Chemical stores and repackages chlorine, which is considered a hazardous material and 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
California Pool Chemical provides chlorination services to swimming pools. Chlorine is repackaged at the facility from one-ton chlorine containers to twenty-pound capacity s
ervice cylinders. The twenty-pound service cylinders are used by California Pool Chemical service staff to chlorinate customer swimming pools. The amount of chlorine repackaged per month is seasonally dependent. The summer months, for obvious reasons, are the busiest time of the year. Consequently, the quantity of chlorine on site is highest during this period. California Pool Chemical stores a maximum of 10,000 pounds of chlorine. This amount includes the contents of 4 one-ton containers in storage, 160 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 made during normal working hours.
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 to a chlorine absorption scrubber. The twenty-pound cylinders are t
ransported by company services personnel to customers' swimming pools where the services 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 Procedures for Chlorine Packaging.
Off-loading of the one-ton chlorine containers from the commercial delivery vehicle is accomplished with a lift gate on the delivery vehicle. The one-ton containers are placed in the Fill Yard. The one-ton containers are then manually rolled to the desired rail location and restrained to prevent movement. Empty and full twenty-pound cylinders are segregated and are restrained in place in an upright position. The company has administrative procedures in place that limit the amount of chlorine at the facility. The procedure, in part, requires the owner/operator to verify existing chlorine inventory to ensure than an order and delivery of a one
-ton container will not cause the aggregate quantity to exceed the maximum quantity of chlorine in the Fill Yard.
The driveway and yard area provides adequate room for the delivery vehicles during the off-loading of full one-ton containers and the loading of the empty one-ton containers. The Fill Yard is not exposed to passing vehicular traffic and is locked after normal working hours. Company policy does not allow unauthorized entry into the Fill Yard. Container storage and handling is per Sections 2.6, 2.7 and 2.8 of the Chlorine Institute's Chlorine Manual.
The major repackaging system components are the D.O.T. approved one-ton chlorine container, the proprietary transfer piping assembly, the twenty-pound capacity D.O.T. approved cylinders, the pan scales for weighing the cylinders during the filling operation, the chlorine absorption system and the containment system for the one-ton container. The containment system eliminates the possibility of any release of chlorine once t
he one-ton container is enclosed within the containment system.
Batch filling of cylinders is accomplished by placing up to two cylinders on separated pan scales and 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 filling for the day, the valves on the cylinder are closed, the in-line valves to the manifold are closed, and the very small amount of residual chlorine in the line is routed to the chlorine absorption 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 particularly with the containment system for the one-ton container. Ful
l twenty-pound cylinders are stored in the repackaging area until loaded onto delivery trucks. Transport and loading of the cylinders adheres to the Chlorine Institute's Guidelines for Transportation of Chlorine Cylinders, Pamphlet 76. Filling is done by trained and 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.
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 repackaging system. The one-ton container is, at most, filled with 2,000 lbs of liquid chlorine. The Worst Case release scenario for the one-ton container of chlorine is t
he release of the 2,000 lbs of chlorine at the rate of 200 lb/min for 10 minutes. The distance to the endpoint of 3 ppm for the Worst Case scenario release would extend beyond the boundaries of the stationary source.
3b. Alternative Release Scenario
The Alternative Release scenario for the one-ton container of chlorine is a small leak of 2 lb/min occurring in the packing material around the valve stem of the vapor phase valve located on the one-ton container. There are no active or passive mitigation measures that would reduce the amount of chlorine released or treatment system to which the released chlorine would be directed. It is assumed that the release would continue for a period of sixty minutes. During that time, a total of 120 pounds of chlorine would be released. In this scenario, the distance to the 3 ppm endpoint would extend beyond the boundaries of the stationary source.
3c. Administrative Controls
Administrative controls to limit the distance for each report sc
enario exist to restrict to a minimum the amount of chlorine lost from a one-ton container if an accidental release were to occur. This administrative control is inherent in the operational procedures for the chlorine process system and the training provided to the operators of the process system.
3d. Mitigation Measures
Mitigation measures to limit the distances for each reported scenario exist to restrict the amount of chlorine released to a minimum if a release were to occur. The mitigation measures are based upon the design, inspection, testing, and maintenance of the chlorine process systems; their related equipment and components; and the treatment system.
4. General Accidental Release Prevention Program and Chemical Specific Prevention Steps
The facility complies with all applicable federal and state codes and regulations. There are safety meetings and safety training. The Process Safety Management (PSM) program being implemented at the f
acility for the chlorine process system and the related activities and equipment represent the facility's main active commitments to an accidental prevention program.
5. Five-Year Accident History
There have been no accidental releases of chlorine at the facility in the past five years.
6. Emergency Response Program
The Emergency Response Program is based upon alerting personnel at the facility to evacuate the facility and await the arrival of responders from the Fire Department at the evacuation assembly location, if a release occurs that causes the evacuation to be initiated. The County of San Bernardino - Fire Department can incorporate this response into the Area Plan for the Local Emergency Planning Committee.
7. Planned Changes to Improve Safety
There are commitments made under the Process Hazard Analysis element of the Process Safety Management (PSM) program that are to be implemented over the next year. Current applicable codes and regulations are reviewed as part of
the PSM to determine if other commitments need to be made to achieve increased operational safety for the regulated chlorine process system. These commitments will be prevention and mitigation measures for the accidental releases of the regulated substance.