Splish Splash Pool Chemicals, Inc. - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Splish Splash Pool Chemicals, Inc. has an emergency action plan in effect. The Emergency Action Plan (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. Splish Splash Pool Chemicals, 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 that the plan is kept current. STATIONARY SOURCE AND REGULATED SUBSTANCE The process is located at 519 West Lone Cactus Drive, #101, Phoenix, AZ 85027. The chlorine transfer process for Splish Splash Pool Chemicals, 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 12000 pounds. There are four full time employees on site; however, there are additional employees that pick up supplies in the morning and are on the road all day. They may stop back at the end of the day to unload the vehicle. HAZARD ASSESSMENT SUMMARY Worst Case Release Summary: The worst case release for this facility was that of the maximum quantity of chlorine that can be stored in a vessel. The largest vessel, one-ton container, has a maximum capacity of 2,000 pounds. This quantity was released in 10 minutes. The vessels are unloaded from the delivery truck and placed directly into the building; therefore, the enclosure was used as a pa ssive mitigation measure. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed, and F stability. The facility is located in an urban setting. The downwind distance to 3 ppm was determined using Exhibit 4-3 from the EPA "Risk Management Program Guidance for Wastewater Treatment Facilities", November 1998. The release reaches off-site and may affect population receptors. No environmental receptors are affected by this potential scenario. Alternative Release Result Summary: The alternative release scenario was that of a5/16" diameter two phase leak of chlorine until the one ton container was empty (28 minutes). This scenario was chosen because it is possible for a small hole this size to occur in piping. The piping is located inside the building so this passive mitigation measure was incorporated into the release rate to the outside atmosphere. The meteorological conditions used were 3 meters/second wind speed, and D stability. The facility is loc ated in an urban setting. The downwind distance to 3 ppm was determined using Exhibit 4-12 from the EPA "Risk Management Program Guidance for Wastewater Treatment Facilities", November 1998. The release reaches off-site and may affect population receptors. No environmental receptors are affected by this potential scenario. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Splish Splash Pool Chemicals, Inc. has a Process Safety Management program in place to manage the handling of chlorine. Splish Splash Pool Chemicals, Inc. does not use any outside contractors at the facility; therefore, they do not have a contractor safety program in place. In the event that they need to use outside contractors, a safety program will be prepared and implemented at that time. 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. All employees must complete a safety training program which includes materials published by the National Association of Gas Chlorinators and The Chlorine Institute. Only employees who have completed training certification for "Level 2 Technician" status may transfer chlorine to 20 pound cylinders. Additional safety equipment on site includes a ton container cradle device which allows ton containers to be rotated in place to assist in inspection and repair if ever needed. In addition, the facility is equipped with a ventilation system capable of providing an air exchange of up to 15,000 cubic feet per minute. The chlorine one ton containers, the transfer process equipment, and the transfer cylinders, are all located indoors providing security management for all containers. No filled containers are stored outside. This policy is in place to prevent vandalism, sabotage, and tampering. The facility produces no hazardous wastes. Every chemical by-product from the transfer process is reclaimed and used in swimming pool water treatment allowing no environmental wastes. This business eliminates our customers' need to buy, transport, handle, and dispose of hazardous materials required for swimming pool water treatment. This provides a major benefit to the environment. No firefighters, police, or emergency response personnel have ever had to respond to a hazardous material release from this facility. No firefighters, police, or emergency response personnel have ever been injured or hospitalized from a chlorine release from this facility or on the job site. FIVE YEAR ACCIDENT HISTORY There have been no reported releases of chlorine at this facility over the last five years (June 1994 through June 1999). In addition, there has not been a release of chlorine since the facility began operations in 1984. EMERGENCY RESPONSE PROGRAM Splish Splash Pool Chemicals, Inc. has an Emergency Action Plan that is coordinated w ith the City of Phoenix Fire Department. This plan outlines the personnel to contact in the event of a release. The facility plans to contact 9-1-1 and evacuate all employees in the event of a chlorine release. In addition, the facility can contact the chlorine supplier, Hill Brothers Chemicals in the event of an emergency. PLANNED CHANGES TO IMPROVE SAFETY A complete Process Hazard Analysis was recently completed at the facility to identify potential safety issues. In addition, the existing Process Safety Management programs and procedures were reviewed in May 1999. The facility has worked to address safety issues as they arise in a continued effort to ensure a safe work environment. The management is planning to continue with this program as follows: 1. Continued maintenance program for chlorine transfer equipment to ensure ongoing integrity. 2. Continue to train all employees in the Process Safety Management programs and procedures. 3. Continue to train employees in t he safe handling of chlorine. 4. Review existing operating procedures and update as necessary. |