GREN Inc. 12920 Imperial Hwy - Executive Summary
1. Accidental Release Prevention and Emegency Response Policies. |
GREN Inc. stores and repackages chlorine which is considered a hazardous material that is a regulated subtance and is considered in the Risk Management Plan (RMP). The properties of chlorine make it necessary to observe safety precautions in handling chlorine to prevent human exposure, and to reduce the threat to the facility's workers and nearby members of the community. It is the facility's policy to adhere to all applicable Federal and State rules and regulations. Safety depends upon the safe procedures used to handle chlorine; the safety devices and systems designed and constructed into the facility; and the training of the pertinent personnel.
2. Stationary Source and Regulated Substances Handled
GREN Inc. provides chlorination services to swimming pools. Chlorine is repackaged at the facility
from one- ton chlorine containers to 20 pound capacity service cylinders. The 20 pound service cylinders are used by GREN
Inc. service staff to chlorine customer swimming pools. The facility operates five
days per week (M-F), ten hours per day for fifty weeks per year.
The facility consists of two separate buildings. One building is a dedicated office building and the other building is used exclusively for the re-packaging of chlorine.
The amount of chlorine repackaged per month is seasonally dependent. The summer months, for
obvious reasons, are the busiest time of the year. Consequently, the quantity of chlorine on site is
highest during this period. GREN Inc. stores a maximum of 26,000 pounds of chlorine.
This amount includes the contents of 9 one- ton containers, 300 twenty pound cylinders, and the one-
ton container in the repackaging process.
Chlorine is purchased from and delivered by commercial chlorine suppliers. Delivery of one- ton containers is during normal working hours. The one- ton containers, up to a maximum of 10 are stored in the Chemical Building (Fill Yard).
Chlorine is repac
kaged as a liquid from one- ton containers into twenty pound net capacity, D.O.T. approved, cylinders. Any residual chlorine in small diameter, short length piping is directed to a
Liquid caustic absorption scrubber. The twenty- pound cylinders are transported by company services
personnel to customers' swimming pools where the services personnel dispense the chlorine as a gas
into the pool. The twenty pound cylinders are owned by the company and maintenance is performed in
accordance with the Chlorine Institute's Pamphlet 17 Cylinder and Ton Container Procedures for
Off-loading of the one ton chlorine containers from the commercial delivery vehicle is accomplished with
a hoist. The one- ton containers are placed on the rails in the chlorine building (Fill Yard). The one- ton
container are then manually rolled to the desired rail location and chocked to prevent movement.
Empty and full twenty pound cylinders are segregated and are chained or strapped in place
in an upright
position. The company has administrative procedures in place that limits the amount of chlorine at the
facility to no more than 10 one- ton containers and 300 twenty pound cylinders for a total of 26,000 pounds. The procedure, in part requires, the owner/operator to verify existing chlorine inventory to ensure that an order and delivery of a one- ton container will not cause the aggregate quantity to exceed 26,000 pounds.
The driveway and yard area provides adequate room for the delivery and parking of delivery vehicles during the off-loading of full one-ton containers and the loading of the empty one-ton containers.The entire facility is fenced with a locking gate. The Chemical Building (Fill Yard) is not exposed to vehicular traffic. The chemical building houses all of the chlorine containers and is locked after normal working hours. Company policy dose not allow unauthorized personnel entry into the building. Container storage and handling is per Sections 2.6, 2.7,
and 2.8 of the Chlorine Institute's Chlorine Manual.
The Major repackaging system components are the D.O.T. approved one- ton chlorine container,the proprietary tranfer piping assembly, the twenty- pound capacity D.O.T. approved cylinders, the pan scale for weighing the cylinders during the filling operation, and the chlorine adsorption system.
A proprietary tranfer tube assembly is attached to the lower (liquid level) angle valve on the operating
one- ton container and an empty services cylinder is brought into place on a pan scale and attached to the other end of the transfer assembly. Filling commences by opening the one- ton container liquid valve,
the cylinder valve, and the other in-line valves in the tranfer assembly. After filling, which is indicated by
weight on the scale reaching the desired weight. The cylinder valve and the liquid chlorine valve on the
transfer assembly are closed. And the transfer tubing is evacuated by means of the eductor in the chlorine
system prior to disconnecting the full service cylinder. The caustic solution, comprising the
absorption medium, is prevented from being sucked back into the system by the unique design of the
proprietary and confidential part of the chlorine packaging system.
Batch filling of cylinders is accomplished by placing up to two cylinders on separated pan scales and
attaching the cylinders to the appropiate transfer assembly connectors. The repackaging system is operated under pressure from the chlorine container. The portion of the system on the scrubber side of
the normally closed in-line valve is under vacuum at all times. At the end of a batch fill the valves on the
cylinder are closed, the in-line valves to the manifold is closed, and the very small amount of residual
chlorine in the line is routed to the caustic scrubber by opening the normally closed in-line valve between
the manifold and the scrubber. Operational and test procedures are in place which ensure that the
system is operating correctly. Chlorine is not vented to the atmosphere under any circumstances.
Full twenty pound cylinders are stored in the repackaging area until loaded onto delivery trucks.
Transport and loading of the cylinders adheres to the Chlorine Institute's Guigelines for Transportation of
Chlorine Cylinders, Pamphlet 76.
Filling is done by trained, qualified personnel during daylight hours. Written filling procedures exist and are
complied with. The entire system is evacuated and the one-ton container liquid valve is shut during non-working hours. Filling personnel wear escape type respirators. An emergency drench shower/eyewash unit is located at the Chlorine Building.
3a. Worst Case Release Scenario
The Worst Case release scenario must consider the largest quantity of a regulated substance handled on
site in a single vessel at any time, taking into account administrative controls on the vessel's contents and
usage as per 40 CFR Part 68 Section 68.25.
A one ton con
tainer of chlorine is the largest vessel in the repackaging system. The one- ton container is,
at most, filled with 2,000 lbs of liquid chlorine. The Worst Case release scenario for the one- ton container
of chlorine is the release of the 2,000 lbs of chlorine at the rate of 200 lb/min for 10 minutes.
The distance to the endpoint of 3 ppm for the Worst Case scenario release would extend beyond the boundaries of the stationary source.
3b. Alternative Release Scenario
The Alternative Release scenario for the one ton container of chlorine is a small leak occurring in the
packing material around the valve stem of the vapor phase valve located on the one ton container.
There are no active or passive mitigation measures that would reduce the amount of chlorine released or
treatment system to which that released chlorine would be dircted. It is assumed that the release would
continue for a period of sixty minutes. During that the time a total of 442.2 pounds of chlorine would be
d. In this scenario, the distance to the 3 ppm endpoint would extend beyond the boundaries of the stationary source.
3c. Administrative Controls
Administrative controls to limit the distance for each report scenario exists to restrict to a minimum, the
amount of chlorine lost from a one-ton container if accidental release were to occur. This administrative
control is inherent in the operational procedures for the chlorine process system and the training provided
to the operators of the process system.
3d. Mitigation Measures
Mitigation measures to limit the distances for each reported scenario exist to restrict the amount of
chlorine released to a minimum if released were to occur. The mitigation measures are based upon the
design, inspection, testing, and maintenance of the chlorine process systems; their related equipment and
components; and the treatment system.
4. General Accidental Release Prevention Program and Chemical Specific Prevention Steps
The facility complies wit
h all applicable federal and state codes and regulations. There are safety
meetings and safety training. The Process Safety Management (PSM.) program implemented at the facility
for the chlorine process system and the related activities and equipment represents the facility's main
active commitments to an accidental prevention program.
5. Five Year Accident History
There has been no accidental release of chlorine in the last five years.
6. Emergency Response Program
The Emergency Response Program is based upon altering personnel at the facility to evacuate the facility
and await the arrival of responders from the Fire Department at the evacuation assembly location if a
release occurs that causes the evacuation to be initiated. Los Angles County Environmental Heath
incorporates this response into the Area Plan for the Local Emergency Planning Committee.
7. Planned Changes to Improve Safety
There are commitments made under the Process Hazard Analysis element of the Process Safe
Management (PSM) that are planned to be implemented over the next year. Current applicable codes and
regulations are reviewed as part of the PSM to determine if the other commitments need to be made to
achieve increased operational safety for the regulated chlorine process system. These commitments will
be prevention and mitigation measures for the accidental releases of the regulted substance.