Pool Chlor of Tucson - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Pool Chlor of Tucson has an emergency response plan in effect. The Emergency Response Plan (Plan) is detailed in the Emergency Planning and Response section of this 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 of Tucson 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. STATION ARY SOURCE AND REGULATED SUBSTANCE Startup of the chlorine system occurred in 1967. The process is located at 3116 East Pennsylvania Ave., Tucson, Arizona 85714. The chlorine system for Pool Chlor of Tucson consists of chlorine one-ton containers which are the storage vessels. Chlorine gas is drawn from the ton container to 20 pound cylinders. Below is a list of the chlorine equipment. Chlorine Tanks (one ton containers) (5 - Operational Amount) (7 - Maximum that can be stored) Located at the south end of the facility Chlorine Tank (20 lb. container) (150 - Maximum that can be stored): Located on operators' trucks Filling Manifold: Located at the south end of the facility. Scrubber Sytem: Located at the south end of the facility. The maximum quantity of chlorine that can be stored on site is 14,000 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 poun ds 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. 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. This release reaches offsite and may affect public receptors. No environmental receptors were affected by this potential release. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Pool Chlor of Tucson 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 Management Programs, there is a scrubber system that is used in conjunction while transferring chlorine. FIVE YEAR ACCIDENT HISTORY There has been one reportable release of chlorine at the facility. A chlorine gas leak occurred at 10:30am on July 8, 1996. The leak originated as an operator was transferring chlorine from the ton container to the 20 pound cylinder. The fill valve was thought to have been closed (but was not) and the transfer cylinder was removed, and chlorine was released. The leak was isolated within twelve minutes and no injuries were reported. The Fire Department HazMat Team arrived to the scene where they use d the incident as a drill and evaluated the event. However, 4 people were brought to the hospital for surveillance but were not admitted. Approximately 30 to 40 pounds of chlorine gas was released to the atmosphere. A staff meeting was held to generate future suggestions for areas of weakness or changes needed to operational procedures. From this meeting, the chlorine sensor interlocked to a motorized valve on the ton container was installed, as well as two shut off buttons that are also interlocked to the motorized valve. Details of this release are included in Section 6 of the RMP*Submit. EMERGENCY RESPONSE PROGRAM If a release of chlorine were to occur, Pool Chlor of Tuscon's response plan is for qualified and trained operators to don SCBAs and mitigate the release. Otherwise, if qualified and trained operators are not available Pool Chlor of Tucson will call 911 in order to reach the Tucson Fire Department's HAZMAT team. Pool Chlor of Tuscon has a B-kit available at the fa cility 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 Pool Chlor of Tucson. The PHA was comprised of one session that included a "What-if" analysis, and a series of checklists. These recommendations will be completed by June 2000: R01 Include in the Mechanical Integrity section the manufacturer's recommended testing for the chlorine sensors. R02 Label the fill and vent valves on the transfer station. R03 Insulate piping providing water to the eyewash/shower. R04 Consider feasibility of installing a wind sock. R05 List important emergency phone numbers near the telephone. |