Pasadena Water & Power City Yards Facility - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES City of Pasadena Water & Power Department (PWP) 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, which is maintained at the facility and updated as necessary. 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. 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, as well as to incorporate facility changes. PWP has coordinated emergency resp onse efforts with the local fire department, Pasadena Fire Department. In the case of a chlorine-related emergency, it is the policy of PWP to evacuate the employees and to allow the fire department to respond to the emergency (potentially with the assistance of trained facility personnel). PWP also plans to contract a private company to be available for chlorine emergency response situations. STATIONARY SOURCE AND REGULATED SUBSTANCE The City of Pasadena Water & Power Department City Yards facility is located at 311 W. Mountain Street, California 91103. The facility is located just east of the Interstate 210 freeway at Mountain Street. The area surrounding the facility is primarily light commercial and residential. The City Yards serves primarily as a storage location for the Pasadena Water & Power Department. Other departments located at the facility include General Services, Public Works, and Solid Waste. The facility is surrounded by a chain link fence with primary acces s through a driveway supervised by a guard shack. Visitors are required to sign in with the guard prior to gaining entry. Chlorine is stored as a liquefied compressed gas in typical 150 pound cylinders at the City Yards. A maximum of fifty (50) 150-pound cylinders may be stored at the facility at any one time for a total of 7,500 pounds. Note that during the previous years, the facility has handled less than the listed threshold quantity of 2500 pounds. In anticipation of Y2K, the facility will now exceed the threshold. These cylinders are stored on a raised, covered concrete island in a metal three-sided corral which allows for the cylinders to be chained in place. The corral is divided into used and full cylinder areas. Vendor deliveries are made to the full cylinder area and these cylinders are transported by PWP operators as needed to remote chlorination stations. Used (empty) chlorine cylinders from these facilities are then returned to the used section of the corral and are picked up by the chlorine cylinder vendor at regular intervals. All cylinders are stored with a secure threaded cap in place. Chlorine is only stored at the City Yards facility. There is no chlorine process piping or equipment at the facility. HAZARD ASSESSMENT SUMMARY * Worst Case Release Result Summary Scenario Description: Release of the maximum quantity of chlorine that can be stored in a vessel (150-pound cylinders) - 150 pounds in 10 minutes. The most pessimistic meteorological conditions were used: 1.5 meters per second wind speed, and F stability. The Risk Management Program Guidance for Waste Water Treatment Plants reference tables were used to determine the maximum distance to the toxic endpoint of 3 ppm in urban conditions. This release reaches off site and may impact population receptors. No environmental receptors were affected by this potential release. * Alternative Release Result Summary Scenario Description: A release of chlorine resulti ng from a 1/4 inch diameter hole. The release rate of chlorine due to the pressure of the tank is 9.5 pounds per minute. The meteorological conditions used were 3 meters per second wind speed, and D stability. The Risk Management Program Guidance for Waste Water Treatment Plants reference tables were used to determine the maximum distance to the toxic endpoint of 3 ppm. This release reaches off site and may impact population receptors. No environmental receptors were affected by this potential release. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS The storage of chlorine cylinders at the PWP City Yards is governed by many safety features. Much of the safety of the process is inherent in the policies and procedures that govern the operation of the process. For example, the PWP City Yards operates in accordance with OSHA's Process Safety Management regulation and the California Accidental Release Prevention (CalARP) Program. The chlorine cylinder s are checked by operators on a daily basis. Cylinders with any notable defect are immediately returned to the vendor. The chlorine cylinders would not be affected by a power outage in any way. There is not a history of failure of chlorine cylinders. To mitigate a potential release scenario due to fusible plugs installed in the cylinders, flammable materials are not stored near the chlorine storage area. In addition, common industry standards, policies, and procedures are utilized to ensure safe practices are being performed. This includes common practices recommended by the Chlorine Institute. FIVE YEAR ACCIDENT HISTORY In the previous five years (since December 1994), there have been no chlorine accidents at the facility. Note that during these previous years, the facility has handled less than the listed threshold quantity of 2500 pounds. In anticipation of Y2K, the facility will now exceed the threshold. EMERGENCY RESPONSE PROGRAM PWP has an emergency action plan in e ffect. The Emergency Action Plan (Plan) is detailed in the Emergency Planning and Response section of the PSM/RMP document, which is maintained at the facility and updated as necessary. 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. 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, as well as to incorporate facility changes due to personnel turnover. PWP has coordinated emergency response efforts with the local fire department, Pasadena Fire Department. In the case of a chlorine-related emergency, i t is the policy of PWP to evacuate the employees via the Public Address system and to allow the fire department to respond to the emergency (potentially with the assistance of trained facility personnel). PWP also plans to contract a private company to be available for chlorine emergency response situations. The facility is also part of a city-wide emergency protocol called the Emergency Operations Center, or EOC. Developed by the State of California, standardized operating procedures have been established to deal with large-scale emergencies. These methods include financial accountability, mutual aid agreements, decision-making strategies, etc. PLANNED CHANGES TO IMPROVE SAFETY In addition to coordinating with the Pasadena Fire Department, PWP also plans to contract with a private company to assist with emergency response activities. The Process Hazard Analysis (PHA) and the Seismic Assessment provided mitigation measures to improve safety at the City of Pasadena Water & Power Department City Yards facility located at 311 W. Mountain Street, Pasadena, California 91103. The recommendations are scheduled to be complete by December 1, 2000. * Process Hazard Analysis R01 Develop a policy for operators to inspect chlorine cylinders prior to connection to ensure the integrity of delivered cylinders. Include a verification of the currency of the hydrostatic test date on each cylinder. Return any cylinders to the vendor based on operator discretion. R02 Assuming that the chlorine storage area remains on the east end of the raised island, consider installing crash posts on the north side of the storage area. R03 Ensure that flammable materials are not kept in the near vicinity of the chlorine storage area. R04 Post chlorine warning signs near the chlorine storage area. R05 For security purposes, consider enclosing the storage area with a chain link fence and gates that are kept locked. R06 Maintain ammonia solution bottles near the ch lorine storage area or on operators' trucks to assist in detecting minor chlorine leaks. R07 Ensure that all employees at the City Yards are provided awareness training regarding the presence of chlorine at the facility. R08 Ensure that all employees at the City Yards know what they are expected to do in case of a chlorine emergency. R09 Establish a procedure for the delivery driver to check in with warehouse personnel prior to unloading chlorine cylinders. R10 Develop an Emergency Response Plan that is compatible with the existing disaster plan for the facility. R11 Consider installing and maintaining wind socks or other wind direction indicators at the facility. * Seismic Assessment 1. The existing steel corral is not adequate to provide lateral restraint for site-specific seismic loads. Design and construction provisions of the Uniform Building Code, 1997 Edition should be used for the new cylinder storage restraint structure. 2. If the current storage configuration is maintained, the nest of cylinders shall be supported for lateral loads at a minimum of two levels, one level near the top and bottom of each perimeter cylinder. 3. Consider installing dividers as part of the new corral structure so that cylinders are stored in single rows. If this design is implemented, establish procedures to properly rotate cylinders in and out of storage. |