Fresno Pool Chlor, Inc. - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
Pool Chlor, Inc. has an emergency action plan outlined in their Injury Illness and Prevention Program. The Emergency Action Plan (Plan) is detailed in the Emergency Planning and Response section of the 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.
Pool Chlor, 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, RMP, and CalARP regulations, a
nd to ensure that the plan is kept current.
STATIONARY SOURCE AND REGULATED SUBSTANCE
Startup of the chlorine system occurred on 1966. The process is located at 3036 East Malaga Avenue, Fresno, CA 93725. The chlorine transfer process for Pool Chlor, 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 22 pound cylinder. These cylinders are used off-site to treat residential swimming pools.
The maximum quantity of chlorine on site is eight one ton containers (16,000 pounds).
The number of full time employees on site is 2; however, there are 19 route-men that may visit the site each morning to pick up supplies. These employees work off-site during business hours.
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. No passive mitigat
ion measures were used since the equipment is stored outside. 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 reference table, Exhibit 4-4, from EPA's RMP Guidance for Wastewater Treatment Plants, November 1998, was used to find the distance for the worst case release scenario. This potential release scenario reaches off site and may affect population receptors. No environmental receptors are affected by this potential release scenario.
Alternative Release Result Summary
Scenario Description: A release of chlorine gas from 5/16 inch diameter leak. This could be due to a leak in the piping, a flange seal leak, or a valve seat leak. There is no accident history at this facility; therefore, the scenario was postulated during the Process Hazard Analysis. The release rate of chlorine due to the pressure of the tank is 72 pounds/minute. The meteorological conditions used were
3 meters/second wind speed, and D stability. The facility is situated in an urban setting. The reference table, Exhibit 4-12, from EPA's RMP Guidance for Wastewater Treatment Plants, November 1998, was used to find the distance for the worst case release scenario. This potential release scenario reaches off site and may affect population receptors. No environmental receptors are affected by this potential release scenario.
ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
Pool Chlor, Inc. 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 and the National Association of Gas Chlorinators.
The filling procedure requires two trained personnel. Hours of filling vary; however, the average filling time is one
hour per day, five days per week. The chlorine transfer process is otherwise, non-operational. This may increase in the summer months.
The chlorine fill station is situated in a separate, fenced area, equipped with a roof, that is locked when not in use. There is a chlorine sensor in the area that will alarm in the office if a concentration of 3 ppm is detected. In the event that the release occurs during off-hours, the alarm company is notified. The alarm company will contact the on-call employee to investigate the alarm.
The transfer container is secured to the scale during the filling operation to prevent it from falling in the event it is knocked or there is an earthquake. In addition, flexible "pigtails" rated for liquid chlorine, are used to connect the one ton containers to the filling manifold. The use of Chlorine Institute approved materials in all piping, fittings, and transfer lines is required. The one ton containers are individually chalked t
o prevent movement and valve protection is in place at all times during storage, transportation, or handling of filled chlorine cylinders.
FIVE YEAR ACCIDENT HISTORY
There have been no reported releases of chlorine at this facility over the last five years (6/21/94 through 6/21/99).
EMERGENCY RESPONSE PROGRAM
The facility's emergency procedures, including notification, evacuation, response, cleanup, and training, are included in the Injury Illness and Prevention Program. In the event of a release of chlorine, employees have been trained to notify management. Management personnel will determine the nature of the incident and determine of outside agencies should be notified. In the event that the release is uncontrollable, outside agencies (9-1-1, Fresno County Environmental Health, and California Office of Emergency Services) will be notified. In addition to the outside agency telephone numbers, the Injury Illness and Prevention Program includes the telephone and location of
the nearest medical facility (Fresno Community Hospital) and neighboring businesses.
The facility uses neutralizing agents and/or copious amounts of water to dilute material to contain and clean up any small spill of a hazardous material. For larger spills, on-site personnel will dial 9-1-1. Neutralizing agents and fire extiguishers are kept in the work areas. Employees have been trained in how to use these items. Work areas are cleaned daily. Each employee knows where the emergency shut-off valves and power switches are located. Employees have also been instructed to turn off utilities (if necessary) during emergency situations.
The facility does not have a complete emergency response team; however, the company President and Vice President have completed 24 hour First Responder - Technician Level training. This includes the use of personal protective equipment including a Self Contained Breathing Apparatus (SCBA) with full face mask. They are prepared to assist the Fire Depar
tment and County Hazardous Materials Division in the event of a release.
Spill control and containment equipment available to responders include neutralizing agents, cylinder coffins, SCBAs, and a B-Kit. Other emergency response equipment includes personal protective equipment and portable fire extinguishers. While awaiting professional assistance, on-site responders who are trained in the proper use of emergency response equipment and supplies will contain the release as best as possible. Upon arrival of emergency response agencies, employees are to surrender cleanup control to emergency personnel, assisting as needed.
PLANNED CHANGES TO IMPROVE SAFETY
The Hazard Analysis provided the mitigation measures outlined below to improve safety at Pool Chlor, Inc. These mitigation measures are scheduled to be implemented on or before December 1, 1999.
R01: Add warning to operating procedures that the Vent Valve should be closed during transfer process. Also include instructions for h
ow to proceed if Vent Valve is left open and liquid chlorine flows into the PVC pipeline.
R02: Prepare a certification for the existing operators to satisfy the initial training requirements (Grandfather Clause).
R03: Prepare training forms for on-the-job training certification for new operators.
R04: Include inspecting containers for leakage, general condition, currency of hydrostatic test, and valve protective housing before accepting shipment
R05: Replace/repair windsock.