Aqua Clear Pool Chemical Inc. - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Aqua Clear has an emergency action plan in effect. The Emergency Action Plan (Plan) is detailed in the Emergency Planning and Response section of the PSM/RMP document, which is maintained at the facility. 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. Aqua Clear 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 (call 911) 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 Startup of the chlorine system occurred in 1997. The process is located at 3901 S. 28th Street, Phoenix, Arizona 85040. The chlorine system for Aqua Clear consists of chlorine one-ton containers which are the storage vessels. Chlorine gas is drawn from the ton container to 20 pound cylinders. Below provides a list of the chlorine equipment. Chlorine Tanks (one ton containers) (2 - Operational Amount) (3 - Maximum that can be stored) Located in the building. Chlorine Tank (20 lb. container) (35 - Operational Amount): Located in the building. Filling Manifold: Located at the north end of the facility outside. Scrubber System: Located at the north end of the facility outside. The maximum quantity of chlorine that can be stored on site is 6,000 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 pound s in 10 minutes. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed, and F stability. The reference table from the EPA's RMP Guidance for Wastewater Treatment Plants was used to determine the distance to the toxic endpoint of 3 ppm for urban conditions. This release reaches offsite and may affect public receptors. No environmental receptors were affected by this potential release. Alternative Release Result Summary Scenario Description: A release of chlorine gas from 5/16 inch diameter leak. The release rate of chlorine due to the pressure of the tank is 72 pounds per minute. The meteorological conditions used were 3 meters per second wind speed, and D stability. The reference table from the EPA's RMP Guidance for Wastewater Treatment Plants was used to determine the distance to the toxic endpoint of 3 ppm for urban conditions. This release reaches offsite and may affect public receptors. No environmental receptors were affected by this po tential release. Based on visual observation of the area immediately surrounding Aqua Clear, it was determined that the residential population for this Alternative Release scenario was overpredicted (see item 3.12). The population was estimated using 1990 census tract data with the Landview. III Environmental Mapping Software. When calculating population densities for large areas which encompass many tracts, the accuracy is rated as good; however, for small areas that encompass only two or three partial tracts, the population data may be skewed due to the unequal distribution within the tract. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Aqua Clear 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 Manageme nt Programs, there is a scrubber system that is used in conjunction while transferring chlorine. FIVE YEAR ACCIDENT HISTORY There has been no reportable release of chlorine at the facility. EMERGENCY RESPONSE PROGRAM If a release of chlorine were to occur, Aqua Clear's response plan is to call 911 in order to reach the Fire Department's HAZMAT team. Aqua Clear has a B-kit available at the facility in order to mitigate a chlorine release. 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 was 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 Aqua Clear. The PHA was comprised of one session that included a "What-if" analysis, and a series of checklists. The recommendations are provided below and are scheduled to be complete by June 2000: R01 Coordinate with the HazMat team to ensure that they are trained in using the B-kit on the ton containers. R02 Place emergency phone numbers near phones, outside of warehouse, and to neighbors in case of a fire or chlorine release. R03 Check the back-up battery and calibrate the chlorine sensor according to the manufacturer's recommendations. R04 Install an eyewash that is accessible to an operator while working on the chlorine transfer system. R05 Verify that the Operating Procedure and Mechanical Integrity sections in the PSM/RMP are accurate and apply to your system. R06 Label the fill and vent valves on the chlorine manifold. R07 Provide an evacuation map of the building that shows the primary an d secondary assembly areas. R08 Place cones at the entry gate when loading/unloading ton containers from chlorine supplier's truck. R09 Verify where if drainage enter the sewer and if necessary, place the phone number to the wastewater facility as an emergency listing. R10 Provide annual testing of pressure in the SCBA tank. |