North Bay Water Services, Inc. - Executive Summary |
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EXECUTIVE SUMMARY 1. Accidental Release Prevention and Emergency Response Policies The subject facility handles chlorine which is considered a hazardous material and 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 20 pound capacity service cylinders. The 20 pound servic e cylinders are used by the facility's service staff to chlorinate customer swimming pools. The amount of chlorine repackaged per month is seasonally dependent. The summer months, for obvious reasons, is the busiest time of the year. Consequently, the quantity of chlorine on site is highest during this period. The subject facility stores a maximum of 8,000 lb of chlorine. This amount includes the contents of three one ton containers in storage, 300 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 liquid caustic absorption scrubber. The twenty pound cylinders are transported by company service personnel to custome rs' 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. Off-loading of the one ton chlorine containers from the commercial delivery vehicle is accomplished with a hoist or lift gate. 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 limits the amount of chlorine at the facility. 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 th e 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. The Fill Yard houses all of the chlorine containers and is isolated after normal working hours. Company policy does not allow unauthorized personnel 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 DOT approved one ton chlorine container, the proprietary transfer piping assembly, the twenty pound capacity DOT approved cylinders, the pan scales for weighing the cylinders during the filling operation, and the chlorine absorption system. Batch filling of cylinders is accomplished by placing up to two cylinders on separate pan scales and attaching the cylinders to the app ropriate 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 the very small amount of residual chlorine in the 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 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, qualified personnel during dayl ight hours. Written filling procedures exist and are complied with. The entire system is evacuated and the 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 chlorine repackaging system. The one ton container is, at most, filled with 2,000 lb of liquid chlorine. The Worst Case release scenario for the one ton container of chlorine is the release of the 2,000 lb of chlorine at the rate of 200 lb/min for 10 minutes. The distance to the endpoint of 3 ppm will 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 lea k 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 are considered to reduce the amount of chlorine released or treatment system to which the released chlorine would be directed. It is assumed that the release of 2 lb/min will continue for a period of sixty minutes. During that time a total of 120.0 pounds of chlorine would be released. The distance to the endpoint of 3 ppm will extend beyond the boundaries of the stationary source. 3c. Administrative Controls Administrative control to limit the distances for each reported scenario exists 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 chlorine process system. 3d. Mitigation Measures Mitigat ion 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 implemented at the facility for the chlorine process system and the related activities and equipment represents the facility=s main active commitments to an accidental release prevention program. 5. Five Year Accident History There has been no accidental release of chlorine in the last five years. 6. Emergency Response Program The Emergency Response Program is based upon alerting personne l at the facility to evacuate the facility and await the arrival of local emergency responders at the evacuation assembly location if a release occurs that causes the evacuation to be initiated. The Certified Unified Program Agency (CUPA) 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) that are planned 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 accidental releases of the regulated substance. |