Aqua Chlor - Executive Summary |
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Swim Chem has instituted a Risk Management Program for their swimming pool maintenance facility, Aqua Chlor, as required by Federal Accidental Release Prevention (ARP) Program regulations at 40 CFR Part 68. The Risk Management Program identifies the equipment, procedures, maintenance, inspection, and training associated with Regulated Substances (RS's) handled at this facility in excess of Federal threshold quantities; describes the structured assessment of hazards which was conducted to assess possible effects on employees and offsite public and environmental receptors; provides the results of an offsite consequences analysis; defines a prevention program, emergency response program, and mitigation measures to reduce the probability and magnitude of accidental releases of RS's; and establishes a schedule and responsibilities for implementation of mitigation measures and auditing of program elements. This Risk Management Plan (RMP) is being filed as required by ARP regulations in ord er to report the elements of the current Risk Management Program and to describe further measures planned to mitigate or prevent accidental releases of RS's. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED Swim Chem's swimming pool maintenance facility, Aqua Chlor, is located at 15885 Altamont Pass Rd., Tracy, CA in Alameda County, and maintains an inventory of chlorine for repackaging in quantities greater than the Federal threshold quantity for this RS. The facility is located in a rural, hilly area just off Interstate 580 between Tracy and Livermore. There are 6 full-time employees at this site. Chlorine is received in ton containers by truck and stored on a concrete slab with hold-down chains. Liquid chlorine is withdrawn under pressure from a ton container to fill 20-lb. capacity transfer cylinders which are transported by Aqua Clor employees to private swimming pools where the employees inject gaseous chlorine into the pools for maintenance of pool water quality. ACCI DENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES It is the policy of Swim Chem that the receipt, storage and handling of chlorine at its facility be done in a manner which meets regulatory requirements and minimizes the probability and severity of accidental releases of chlorine to the atmosphere, in order to protect the health and safety of its workers, the public, and the environment. In order to accomplish this goal, Swim Chem has gathered safety information on chlorine and on the process, equipment and procedures involving chlorine; performed a structured assessment of hazards of the process and external events which might affect the process; performed an offsite consequences analysis of defined release scenarios; established a written program for prevention and mitigation of accidental releases; and established a written emergency response program coordinated with emergency response agencies. WORST CASE RELEASE SCENARIO A single "worst case" release scenario is requir ed to be considered for each stationary source, resulting in the maximum distance to an endpoint for all toxic RS's contained on site above the threshold quantity. The worst case release scenario for toxic chemicals is defined in the ARP regulations as the release of the contents of the largest single container of RS (in this case chlorine) over a period of 10 minutes. The scenario considered the release of the contents of the largest container of chlorine on site, in this case 2,000 lb. This release scenario is not physically possible, due to the characteristics of chlorine. ALTERNATIVE CASE RELEASE SCENARIO An "alternative case" release scenario is required to be considered for each toxic RS handled in quantities greater than the threshold quantity at the site. The "alternative case" scenario is described in the ARP regulations as a likely release resulting in offsite effects, considering administrative controls and mitigation measures in place, and is to be determined by the faci lity operators as part of the Process Hazard Analysis required to be performed during RMP development. The "alternative case" considered for this facility is the release of chlorine from the liquid chlorine piping due to an operator error, with the release secured by an employee wearing appropriate personal protective equipment and closing a valve to stop the release after 5 minutes. ADMINISTRATIVE CONTROLS Administrative controls in effect at Swim Chem which were considered to mitigate the severity of the Worst Case and Alternative Case release scenarios include Swim Chem's written policies and procedures for training of operators and maintenance personnel, written procedures for control of the inventory of chlorine at the facility, and policies regarding quality level of replacement materials and components for the chlorine system. MITIGATION MEASURES No mitigation measures were considered to limit the severity of the Worst Case scenario. No passive mitigation measures were con sidered to limit the severity of the Alternative Case scenario. Active mitigation was considered for the Alternative Case, in the form of employee response in a timely manner. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAMS General accidental release prevention programs instituted by Swim Chem are categorized as administrative (management) programs; procedures, training, and engineering controls; and emergency response programs. Swim Chem has instituted a Process Safety Management (PSM) Program meeting OSHA requirements at 29 CFR 1910.119 covering its repackaging process. This constitutes the general accidental release prevention program for Swim Chem's operations. The program and document management procedures included in the PSM Program will be used as the management system for the Risk Management Program. CHEMICAL-SPECIFIC RELEASE PREVENTION STEPS Release prevention steps specific to chlorine have been identified and implemented. These include, among other things, installing seismic hold-down chains for the ton containers. FIVE YEAR ACCIDENT HISTORY There have been no accidents involving chlorine at this facility within the past five years resulting in injuries or offsite consequences. EMERGENCY RESPONSE PROGRAM Swim Chem's Emergency Response Program applicable to chlorine has been coordinated with Alameda County Department of Environmental Health, the local agency responsible for hazardous materials inventory reporting and release response coordination. It consists of notification of the public agency assigned responsibility for First Response to hazardous materials release emergencies. First Responders have participated with Swim Chem personnel in response drills. PLANNED CHANGES TO IMPROVE SAFETY All of the improvements and mitigation measures identified in the process hazard analysis which Swim Chem committed to accomplish have been completed or are in progress. Any other measures identified by employees during workplace hazard surveys, or as a result of audit activities, will be thoroughly reviewed and considered for implementation. |