GQ Enterprises, Inc. dba Poolman - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
Poolman has an emergency response plan in effect. The Emergency Action 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.
Poolman 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 that the plan is kept current.
STATIONARY SOURCE AND REGULATED
Startup of the chlorine system occurred on 1964. The facility is located at 1444 North 26th Avenue, Phoenix, AZ 85009. The chlorine transfer process for Poolman 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 which is used off site to treat private swimming pools.
The maximum quantity of chlorine on site is 6000 pounds.
HAZARD ASSESSMENT SUMMARY
Worst Case Release Result Summary
The worst case 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 stored outside, therefore, no passive mitigation measures were used. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed and F stability. The facility is l
ocatd 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, the release rate was calculated to be 72 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 down
wind 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
Poolman 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.
There are only three trained operators responsible for transferring the chlorine from one ton containers to the 20 pound transfer cylinders. These operators are OSHA First Responder - Incident Commander Level trained to respond to a release of chlorine. The facility has regular training exercises with the local Fire Department as well as Hill Brothers Chemical, the delivery
Chlorine in the pipeline is bled to a scrubber and there is a chlorine sensor in the storage area that will alarm and alert the office in the event of a chlorine release.
FIVE YEAR ACCIDENT HISTORY
There have been no reported releases of chlorine at this facility over the last five years since March 1994.
EMERGENCY RESPONSE PROGRAM
Poolman has an emergency response plan in effect at the facility. The Emergency Action Plan (Plan) is detailed in the Emergency Planning and Response section of the PSM/RMP document. The facility has three trained operators that can assist the Fire Department in the event of a release of chlorine. These three individuals are OSHA certified Incident Commanders which requires 40 hours of First Responder training by a certified trainer and 8 hours of annual refresher training to maintain the certification. Poolman has periodic drills with the local Fire Department.
PLANNED CHANGES TO IMPROVE SAFETY
The Hazard Analysis provided the mitigatio
n measures outlined below to improve safety at Poolman. These recommendations are expected to be completed by October 1, 1999.
R01: Test/calibrate the chlorine sensor monthly. See Mechanical Integrity in the PSM/RMP Manual.
R02: Review the operating procedures to ensure that they are an accurate representation. Review the operating procedures annually and certify that they are accurate. See Operating Procedures section of the PSM/RMP Manual.
R03: Add warning to the operating procedures that increased ambient temperature increases the flow rate from the one ton to the 20 pound transfer cylinder.
R04: Add warning to operating procedures that the Vent Valve (#2) should be closed during transfer process. Also include instructions for how to proceed if Vent Valve (#2) is left open and liquid chlorine flows into the PVC pipeline.
R05: Provide procedures for gravity bleed in Operating Procedures.
R06: Consider installing a check valve upstream of the venturi injector on the v
R07: Add the chlorine fill station valves to the book for record keeping.
R08: Prepare a certification for the existing operators to satisfy the initial training requirements (Grandfather Clause).
R09: Prepare training forms for on-the-job training certification for new operators.
R10: Post the evacuation procedures/map and emergency telephone numbers throughout the facility.
R11: Consider compiling a list of nearest neighbors to alert in the event of a chlorine release.
R12: Document the results, date, and time of the evacuation drills.