Hays Aquatic Park - Executive Summary
a) The City of Hays has a contract with the Hays Recreation Commission to operate the Hays Aquatic Park and to join in an accidental release prevention policy that involves a unified approach that integrates technologies, procedures, and management practices. All applicable procedures of the U.S. Environmental Protection Agency (EPA) Prevention Program are adhered to. The City response policy involves the preparation of response plans which are tailored to the Hays swimming facility located at 4th and Main Streets and to the emergency response services available in the community, an in compliance with the EPA Emergency Response Program requirements. |
b) The water chlorination station has been installed to disinfect the water contained within the swimming facility. The chlorination system is located on the southeast corner of the intersection of 4th and Main Streets. The station includes a chlorination room, which contains a flow recorder, valving that regulates the flow of chlorine
, various electrical panels, filters, flow balancing tanks, and additional safety equipment.
The amount of chlorine handled is two one ton containers and four 150-pound containers. The chlorination station is not continuously manned during the operating season (May through September) and no chlorine will be stored during the off season period (January through April and October through December). However, the facility does have appropriate alarms to detect chlorine releases for prompt response. Additionally, during the operating season, pool management, City of Hays Water Softening Plant and the City of Hays Wastewater staff periodically visit the chlorination room and monitoring guage system to monitor conditions.
c) The off-site consequence analysis includes consideration of two chlorine release scenarios, identified as "worst case scenarios" and "alternative scenario". The first scenario is identified by EPA, which states that "the owner/operator shall assume that?the maximum q
uantity in the largest vessel ?is released as a gas over a 10 minute period," due to an unspecified failure. The alternative scenario is defined as "more likely to occur than the worst case scenario".
Atmospheric dispersion modeling has to be performed to determine the distance traveled by the chlorine released before its concentration decrease to the "toxic endpoint" selected by EPA of 3 ppm, which the Emergency Response Planning Guideline Level 2 (ERPG-2). The American Industrial Hygiene Association (AIHA) defines this as the "maximum airborne concentrations below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action". The residential population within a circle with a radius corresponding to the toxic endpoint distance has to be defined "to estimate the population potentially affected."
e general Hays Aquatic Park accidental release prevention program is based on the following key elements.
-High Level of training of the operators and pool management/staff
-Prevention maintenance program
-Use of state-of-the-art processes and safety equipment
-Use of accurate and effective operating procedures, written with participation of operators, staff, and management
-Performance of hazard review of equipment and procedures
-Implementation of an auditing and inspection program
Chemical specific prevention steps include the availability of self-contained breathing apparatus (SCBA), awareness of the hazardous and toxic properties of chlorine, and the presence of chlorine detectors.
e) This is a new facility and no accidental releases of chlorine have occurred within the past five years.
f) The facility has an emergency response program, which has been coordinated (reviewed) by the City of Hays Fire and Inspection Department, which are the first responders to a chlorine release
. The Hays Fire and Inspection Department is a member of the Local Emergency Response Planning Committee (LEPC). This program includes an emergency response decision tree and a notification plan. Emergency response drills and drill evacuations are conducted every six months; emergency operation and response procedures are reviewed at that time.
g) The State of Kansas has not reviewed this Risk Management Prevention Program.
h) During periods of non-operation of the swimming facility, all chlorine from the facility will be returned to the distributor for inspection of containers. All valving will be inspected and replaced as necessary prior to the operating season. Management will make every effort to schedule and change-out chlorine containers during the non-school periods.
i) Prior to the opening of the swimming facility, the Associated Pools will provide chlorine Risk Management training. The management staff of the swimming facility will participate in the monthly Risk Ma
nagement meetings held by the Risk Management Team. Training will be an ongoing component of risk management.