Blue Water Pool Chemical Company, Inc. - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Blue Water Pool Chemical Co., Inc. has an emergency response plan in effect. The Emergency Response Plan (Plan) is detailed in the Emergency Planning and Response section of this PSM/RMP document. 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. Blue Water Pool Chemical Co., Inc. maintains a safety committee whose members are the designated emergency coordinators for the facility. 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, and to ensure tha t the plan is kept current. STATIONARY SOURCE AND REGULATED SUBSTANCE Startup of the chlorine system occurred on 1976. The process is located at 7339 East Acoma Drive, Suite #1, Scottsdale, AZ 85260. The chlorine transfer process for Blue Water Pool Chemical Co., Inc. consists of chlorine one-ton containers which are the storage vessels. Chlorine liquid is dispensed from the one ton container through a filling manifold to a 20 pound cylinder. The maximum quantity of chlorine on site is 8000 pounds. HAZARD ASSESSMENT SUMMARY Worst Case Release Result Summary The worst cae release for this facility was that of the maximum quantity of chlorine that can be stored in the largest vessel in 10 minutes. The largest vessel at this facility is a one ton chlorine container which holds a maximum of 2,000 pounds of chlorine. This vessel is normally stored inside, however, the delivery truck is outside during unloading. No passive mitigation measures were used to determine the release rate for the worst case scenario. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed and F stability. The facility is locatd in an urban setting. The reference table, 4-4, from EPA's RMP Guidance for Wastewater Treatment Plants was used to find the potential downwind distance to 3 ppm as a result of this worst case release scenario. The release reaches off-site and may affect population receptors. No environmental receptors were affected by this potential release scenario. Alternative Release Result Summary The alternative release was that of a 5/16 inch diameter leak from a pipeline containing liquid chlorine. Based on the pressure in the tank, and the fact that the transfer process is located inside, the release rate was calculated to be 40 pounds/minute. Since there is no accident history at this facility, this release scenario was based on the possibility of a leak in the pipeline or a flange seal leak. The meteorological conditions used were 3 meters/second wind speed, and D stability. The facility is located in an urban setting. The reference table, 4-12, from EPA's RMP Guidance for Wastewater Treatment Plants was used to find the potential downwind distance to 3 ppm for the alternative release scenario. This release reaches off-site and may affect population receptors. No environmental receptors were affected by this potential release scenario. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Blue Water Pool Chemical Co., Inc. has a Process Safety Management program in place to manage the handling of chlorine. In addition, common industry standards, policies, and procedures are utilized to ensure safe practices are being performed. This includes common practices outlined by the Chlorine Institute and the National Association of Gas Chlorinators. FIVE YEAR ACCIDENT HISTORY There have been no reported releases of chlorine at this facility over the last five years since June 1994. EMERGENCY RESPONSE PROGRAM The Blue Water Pool Chemical Co., Inc. has an emergency action plan in effect at the facility. The Blue Water Pool Chemical Co., Inc. works closely with the local fire department and Hill Brothers Chemical, the chlorine supply company. The facility plans to contact 9-1-1 in the event of an emergency. In addition, Hill Brothers Chemical is available to respond to a release of chlorine. PLANNED CHANGES TO IMPROVE SAFETY The Hazard Analysis provided the mitigation measures outlined below to improve safety at Blue Water Pool Chemical Co., Inc. The recommendations are scheduled to be implemented on or before September 1999. R01: Prepare a call list to notify neighbors in the event of a chlorine release. R02: Verify and update the neighborhood emergency telephone list once per year. R03: Review the operating procedures to ensure that they are an accurate representation. Review the operating procedures annually and certify that they are accurate. Use th e operating procedures to train new route-men. R04: Add warning to operating procedures that the Vent Valve should be closed during transfer process. Also include instructions for how to proceed if Vent Valve is left open and liquid chlorine flows into the PVC pipeline. R05: Provide procedures for gravity bleed in Operating Procedures. R06: Document the chlorine monthly sensor calibration test. R07: Consider having the security company monitor the chlorine sensor during off-hours. R08: Review mechanical integrity forms and update as necessary. R09: Prepare a certification for the existing operators to satisfy the initial training requirements (Grandfather Clause). R10: Prepare training forms for on-the-job training certification for new operators. R11: Maintain equipment certificates for the life of the equipment. R12: Install a windsock on the roof, visible by employees. R13: Investigate the local regulations regarding containment for the caustic solution tank. R14: Post evacuation procedures in office. |