CCC Pool Services, Inc. - Executive Summary |
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1. Accidental Release Prevention and Emegency Response Policies. CCC Pool Services stores and repackages chlorine which is a hazardous material and a regulated subtance and is considered in the 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 CCC Pool Services provides chlorination services to swimming pools. Chlorine is repackaged at the facility from one ton chlorine containers to 20 pound capacity service cylinders. The 20 pound service cylinders are used by CCC P ool Services service staff to add chlorine into 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. CCC Pool Services stores a maximum of 8,000 pounds of chlorine. This amount includes the contents of 3 one- ton containers in storage, 96 twenty pound cylinders, and the 1 one ton container in the repackaging process. Chlorine is purchased from and delivered by a commercial chlorine supplier. Delivery of one- ton containers is during normal working hour. 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 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 and a forklift. The one- ton containers are placed in the Fill Yard. The one- ton containers are placed in the desired storage location and chocked to prevent movement. Empty and full twenty pound cylinders are segregated and are chained or strapped 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 the existing chlorine inventory to ensure that an order and delivery of one- ton containers of chlorine will not cause the aggregate quantity to exceed 8,000 pounds in the Fill Yard. The Fill Yard is not exposed to passing vehicular traffic. The Fill Yard c ontains all of the chlorine containers and is locked 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 repacking system components are the D.O.T. approved one- ton chlorine container,the proprietary tranfer piping assembly, the twenty pound capacity D.O.T. approved cylinders, the pan scales for weighing the cylinders during the filling operation, and the chlorine adsorption system. Batch filling of cylinders is accomplished by placing up to two cylinders on separated pan scales and attaching the cylinders to the appropiate 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 the batch filling for the day, the valves on the cyl inder are closed, the in-line valves 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 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 regu lated 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 the 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 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 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 re leased chlorine would be dircted. It is assumed that the release of 2 pounds per minute would continue for a period of sixty minutes. During that the time a total of 120 pounds of chlorine would be released. In this scenario, the distance to the endpoint of 3 ppm would extend beyond the boundaries of the stationary source. 3c. Administrative Controls Administrative controls to limit the distance for each report scenario exists to restrict to a minimum, the amount of chlorine lost from a one- ton container or 20 lb container if 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 released were to occur. The mitigation measures are based upon the design, inspection, testing, an d 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 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 altering personnel at the facility to evacuate the facility and await the arrival of responders from the Local Fire Department at the evacuation assembly location if a release occurs that causes the evacuation to be initiated. The San Diego County - Hazardous Materials Division 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 the 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. |