City of Poway - Community Swim Center - Executive Summary |
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES City of Poway - Community Swim Center has an emergency response plan in effect. The Emergency Response Plan (Plan) is detailed in the Emergency Planning and Response section of the City of Poway - Community Swim Center's 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. City of Poway - Community Swim Center 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 will be reviewed and updated to ensure compliance with th e PSM, RMP, and CalARP regulations, and to ensure that the plan is kept current. STATIONARY SOURCE AND REGULATED SUBSTANCE Startup of the chlorine system occurred in 1989. The process is located at 13094 Bowron Road, Poway, California 92064. The chlorine system for City of Poway - Community Swim Center consists of chlorine one-ton containers which are the storage vessels. Chlorine gas leaves the one ton container and passes through a vacuum regulator to the chlorinator. Still under vacuum from the chlorinator, the gas is drawn to an injector and mixed with recycled pool water. The maximum quantity of chlorine that can be stored on site is 4,000 pounds. HAZARD ASSESSMENT SUMMARY Worst Case Release Result Summary Scenario Description: Release of the maximum quantity of chlorine that can be stored in a vessel - 2,000 pounds in 10 minutes. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed, and F stability. A reference table from the EPA's R MP Guidance for Wastewater Treatment Plants, was used to determine the distance to the toxic endpoint of 3 ppm. This scenario reaches off-site and may affect population receptors. No environmental receptors were affected by this potential scenario. Alternative Release Result Summary Scenario Description: A release of chlorine gas from 1/4 inch diameter leak. The release rate of chlorine due to the pressure of the tank is 9.5 pounds per minute over a 60 minute period. The total quantity released is 570 lbs. However, passive mitigation measures were incorporated since the chlorine system is stored in an enclosure and the release rate to the outside air will be considerably less than if it was stored outside. Consequently, the release rate after this measure was calculated to be 5.2 pounds per minute, where the quantity to the atmosphere is 312 lbs. The meteorological conditions used were 3 meters per second wind speed, and D stability. A reference table from the EPA's RMP Guidan ce for Wastewater Treatment Plants was used to determine the distance to the toxic endpoint of 3 ppm. This scenario reaches off-site and may affect population receptors. No environmental receptors were affected by this potential scenario. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS City of Poway - Community Swim Center 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. In addition to the Management Programs, there is a chlorine gas detector in the storage room that is set at 1 ppm and will activate the visual/audible alarm. FIVE YEAR ACCIDENT HISTORY There has been no reportable releases of chlorine at the facility within the last five years. EMERGENCY RESPONSE PROGRAM If a release of chlorine were to occur, the City o f Poway - Community Swim Cetner's response plan is to call 911 in order to reach the Fire Department's HAZMAT team. Employees will evacuate the facility to a point that is upwind of the hazard. Evacuation drills are performed annually. The emergency response plan provides the response organization and notification procedures, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility. This plan will be reviewed and updated to ensure compliance with the PSM and RMP regulations, and to ensure that the plan is kept current. PLANNED CHANGES TO IMPROVE SAFETY The Process Hazard Analysis (PHA) provided the mitigation measures outlined below to improve safety at the City of Poway - Community Swim Center. The PHA was comprised of one session that included a HAZOP study, a Plant Walkthrough, a "What-if" analysis, and a series of checklists. Changes will be completed by August 1999. Verify concentration setpoint of chlorine sensor. City of Poway - Community Swim Center would like to note that a new chlorine sensor was installed and this recommendation is complete. Ensure that chlorine sensor is calibrated and maintenanced per manufacturer's specifications. City of Poway - Community Swim Center would like to note that this recommendation is complete. Install a digital readout of the internal chlorine concentration on the exterior of the chlorine building. City of Poway - Community Swim Center would like to note that this recommendation is in progress. Consider installing a caustic scrubber system triggered by the sensor in the chlorine room. City of Poway - Community Swim Center would like to note that a new chlorine sensor was installed and the consideration of installing a scrubber system will not be persued. City of Poway - Community Swim Center is currently planning to change the chlorine system to a sodium hypochlorite process which is safer for the community. This will eliminate t he chlorine process completely, in which no chlorine will be stored on-site. In which case, the scrubber system will not be necessary. This change is expected to be complete by November 1999. Interlock the high residual chlorine concentration alarm to shut down the water pumps. City of Poway - Community Swim Center would like to note that this recommendation is not applicable because the water pumps cycle on/off only when staff is present and shut down during off-hours. Implement a valve numbering system and tag the important valves. Also, label chlorine piping to show contents and flow direction. City of Poway - Community Swim Center would like to note that this recommendation is complete. Include the operating procedures and training information for the City of Poway - Community Swim Center in the Water Treatment Plant operations manual. City of Poway - Community Swim Center would like to note that this recommendation is in progress. Establish a procedure to regularly h old emergency evacuation drills for the entire Community Swim Center facility. City of Poway - Community Swim Center would like to note that this recommendation is in progress. |