City of Alice (South) - Executive Summary |
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The City of Alice is dedicated to protecting it's employees, the community, and the environment from chemicals accidents through safely operating our Southside Wastewater Treatment Plant (SSWWTP). To ensure efficient and effective management of our operations, we have developed a risk management program. Our risk management program manual, in its entirety, describes the specific responsibilities and activities for implementing the risk management program. The SSWWTP stores and uses chlorine to disinfect the wastewater. The SSWWTP maintains approximately 4,000 pounds (two 1-ton containers) of chlorine on-site for use in its chlorination process. The SSWWTP has not had any accidental releases of chlorine since it began operation in 1986. The SSWWTP regularly conducts safety meetings to review and reinforce the proper management of our chlorine and chlorination system. Worst-case release scenarios and alternate release scenarios were evaluated and distances to endpoints were determ ined, public and environmental receptors were identified, and potentially affect populations were estimated. The SSWWTP used the EPA's Offsite Consequence Analysis Guidance to determine the distances to endpoints. The worst-case release scenario involves the catastrophic release of the entire contents of the two 1-ton containers on-site. For this to occur, the 1-ton containers would literally have to burst and instantaneously vaporize all of the liquid chlorine. This worst-case release scenario is extremely unlikely. Catastrophic vessel failure is a rare event. In the event a worst-case release occurred, the release would potentially affect residences, businesses, schools hospitals and parks in the surrounding community. The alternate release scenario was selected based on past history, probability of occurrence, and the ability to impact public and environmental receptors off-site. While the SSWWTP does not have any history of accidents, the most likely cause of chlorine le aks is container valve leaks and piping leak. The most likely alternate release scenario for the SSWWTP involves a chlorine container valve leak. While this is not as unlikely of a release scenario as the worst-case release scenario, the SSWWTP takes precautions to minimize the occurrence of chlorine leaks. Container valve leaks occur as a result of faulty container valves or poorly mated connections. The SSWWTP examines all chlorine containers upon arrival for leaking valves and has procedures in-place for repairing the valve packing, which is typically the cause of leaking vales. Poor connections are typically a result of deteriorated gaskets, which cause the connection to improperly seat. To minimize poor connections, every time a container connection is made, the SSWWTP uses new lead gaskets. In the event that a container valve leaks occurs, the release would potentially affect residences and the surrounding community within 0.2 miles of the SSWWTP. The City of Alice beli eves that a comprehensive prevention program is essential to the prevention of accidental releases of hazardous chemicals. The SSWWTP includes seven basic elements in its prevention program: a safety program, a hazard review program, written operating and maintenance procedures, a training program, incident investigation procedures, and a compliance audit program to ensure effectiveness of the risk management program. The SSWWTP maintains complete and accurate written information concerning process chemicals, process technology, and process equipment, which is essential to an effective RMP. The safety program consists of written information complied for the chlorination process and up-to-date safety information, enabling the SSWWTP operators to identify and understand the potential hazards involved in the covered process. The City of Alice believes that a thorough hazard review is key to understanding how to operate safely on a continual basis. The SSWWTP has a hazard review proc ess is to determine, identify, and evaluate the types of hazards or potential failures associated with the chlorination process. The chlorination process is carefully managed and consistently conducted in a safe manner. Written operating procedures developed for the SSWWTP provide the safest and most appropriate step-by-step method for conducting safe operations. The written operating procedures give operator clear instructions for safely conducting activities involving the chlorination process. These operating procedures include guidance from manufacturers, suppliers, and vendors of the chlorination process equipment. In addition, the SSWWTP has implemented a maintenance procedures program that includes written procedures and schedules for maintenance and equipment inspections and tests to ensure that maintenance operations are conducted in a safe manner and implemented to maintain the mechanical integrity of the chlorination equipment. Preventative maintenance and inspection o f equipment is critical to safe operations. The SSWWTP's training program is in-place to ensure that its operators understand how to safely operate the chlorination equipment and to understand why safe operations are necessary. The objective of this training is to train operators so that fewer accidents occur, equipment damage is minimized, and operational efficiency is improved. The City of Alice believes that its training program is the key to ensuring that the rest of the Prevention Program is effective. Every employee working with the chlorine will be adequately trained to ensure safe handling, storage, and use of the chlorine. All personnel working at the SSWWTP receive training on the operation and maintenance procedures of the chlorination process. Training consists of one-on-one training, on-the-job training, and classroom training. Competency tests are used to ensure that each operator trained has understood the training and is competent to operate the process safely. The SSWWTP has developed incident investigation procedures to investigate major and minor accidents that occur within the plant or across the fenceline that resulted in or could have resulted in a chemical release, personnel injury, property damage, or environmental damage. Incident investigation procedures are used to assist in understanding the obvious incident causes, as well as the underlying causes, which provides valuable information identifying and solving the problem and preventing similar incidents from occurring. The SSWWTP has implemented a compliance audit program to periodically assess compliance with its risk management program, monitor the risk management program and respond promptly to any deviations. The SSWWTP uses the compliance audit program to verify that the practices and procedures developed are adequate and are being followed. The City of Alice's SSWWTP has an Emergency Action Plan to ensure that system for notifying employees, the surrounding community, a nd the proper response authorities of in the event of an accidental releases of hazardous chemicals in effective and in-place. The SSWWTP operators are not trained nor equipped to respond, other than minor response, to a hazardous chemical release. However, in the event that a release occurs that requires any response other than a minor response, which can be safely performed by the City of Alice operators, the proper emergency response crews will be contacted. The SSWWTP has implemented a management program, which describes the management responsibilities for implementing the risk management program. The management program was developed to ensures that the elements of the risk management plan are integrated, implemented, continuously improved, and that the responsibility for the overall program and for each RMP requirement is clearly defined. The City of Alice's SSWWTP takes a very responsible attitude towards safety. The SSWWTP has rigorously implemented the risk management pr ogram. The SSWWTP has continued its commitment to ongoing safety through the implementation of revised and updated operating and maintenance procedures, increased training schedules, and installation of updated release detection equipment and emergency response equipment. |