VJLV Processing, Inc. - Executive Summary |
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EXECUTIVE SUMMARY 1. Accidental Release Prevention and Emergency Response Policies This facility handles chlorine which is considered a hazardous material. 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 facility provides chlorination services to swimming pools. Chlorine is repackaged at the facility from one ton containers to 20 pound capacity service cylinders. The 20 pound service cylinders are used by the subject facility staff to service customer swimming pools. The chlorine is purch ased from and delivered by commercial chlorine suppliers. Chlorine is repackaged as a liquid from the one ton containers to the twenty pound cylinders. Any residual chlorine in the small diameter and short length piping of the repackaging system is directed to an absorption scrubber with no release to the atmosphere. Filling is done by trained and qualified personnel during daylight hours. Filling procedures are strictly followed. The one ton container in the repackaging system is inside of a containment vessel. In the unlikely event of any chlorine release, the release would be retained within the containment vessel and subsequently utilized in the repackaging process. There would be no chlorine release exterior to the containment vessel from the one ton container in the repackaging system. A possible, though not probable, release from one of the one ton containers in storage is mitigated by the application of the Emergency B Kit and/or the placement of the leaking one ton contai ner in the containment vessel of the repackaging system. The chlorine release will be contained in the containment vessel for subsequent use of the chlorine in the repackaging system. 3a. Worst Case Release Scenario The largest storage vessel is a one ton container of chlorine. Failure of this container will release 2,000 lb of chlorine as required by the RMP guidelines. Such a failure can't physically occur and definitely not from a one ton container in the containment vessel of the repackaging system. However, as per the guidelines, it will be assumed that the entire 2,000 lb is released as gas in ten minutes from one of the one ton containers in storage. The assumption is made that the gas release from the one ton container is directly to the surrounding atmosphere external to the building. The distance to the endpoint of 3 ppm for the Worst Case scenario will extend beyond the boundaries of the stationary source. 3b. Alternative Release Scenario The largest s torage vessel is a one ton container of chlorine. The Alternative Release scenario for the one ton container is a small leak in the packing material around the valve stem of the vapor phase valve located on the one ton container. If this occurred in the repackaging system, there can't be a release outside of the repackaging system because the release will be contained within the containment vessel. Such a release is possible, although not probable, for a one ton container in storage. In actuality, such a leaking container can be sealed with the Emergency B Kit or placed within the containment vessel to mitigate and contain the release. Here it will be assumed that no active or passive mitigation measures that would reduce the amount of chlorine released or contain the release are utilized. It is assumed that the release of 2 Ib/min would 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 for the Alternative Release scenario 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 the amount of chlorine released to a minimum, if a release were to occur; and preferably to not have a release occur. This administrative control is inherent in the operational procedures for the chlorine system and the training provided to the chlorine system operators. 3d. Mitigation Measures Mitigation measures to limit the distances for each reported scenario exists to restrict the amount of chlorine released to a minimum, if a release were to occur; and preferably to not have a release occur. The mitigation measures are based upon the design, inspection, testing, and maintenance of the chlorine system and its related equipment and components. 4. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The facility complies with a ll 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 related activities and equipment represents one of the facility's main active commitments to an accidental release prevention program. 5. Five Year Accident History There have been no accidental releases within the last five years. 6. Emergency Response Program The Emergency Response Program is based upon the alerting of personnel at the facility to evacuate the facility and await the arrival of responders from outside the facility at the evacuation assembly location if a release occurs that causes the evacuation to be initiated. This response can be incorporated into the Area Plan for the Local Emergency Planning Committee. 7. Planned Changes To Improve Safety Any commitments made for scheduled mitigation actions are listed in element (e) (i.e. Process Hazard Analysis) of the Process Safety Management (PSM) document. These mitigation actions are being implemented at this time for the next year. Current applicable codes and regulations are being reviewed to determine if other commitments need to be made to achieve increased operational safety for the chlorine system. |