White River M.W.D. Water Treatment Plant - Executive Summary |
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The following is an Executive Summary of the White River Municipal Water District Water Treatment Plant's (WRMWD WTP) 40 CFR 68 Risk Management Program. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The WRMWD WTP Accidental Release Prevention Policy requires training on chlorine safety, implementation of improvements identified in periodic process hazard analyses, operator training as required for treatment plant operators by the Texas Natrual Resource Conservation Commission (TNRCC), specific training on written operating procedures developed for the plant chlorination system, training in written maintenance procedures, investigation of chlorine leaks or situations that could cause the release of chlorine, and periodic audits of the WTP's Risk Management Program (RMP). The WRMWD WTP's Emergency Response Policy for a chlorine leak is to shut off the chlorine supply in the case of a minor leak and either correct the source of the leak or contact a contractor to correc t the source of the leak. WRMWD personnel will not attempt to stop a major chlorine leak. However, procedures have been established for notifying the Fire Department, Sheriff's Department, and Emergency Medical Services (if needed). Procedures have also been established for notifying all persons within 1/2 mile of the WTP concerning a major chlorine leak. Depending on the severity of the leak and prevailing wind conditions, people will be advised to either move immediately upwind of the leak or to remain indoors with windows closed and air conditioners and ventilation systems turned off. FACILITY DESCRIPTION/REGULATED SUBSTANCE HANDLED The WRMWD is a 4.5 MGD water treatment facility which provides treated water to the Cities of Crosbyton, Post, Ralls, and Spur, Texas. Both chlorine and propane are handled at the WTP. However, only chlorine is stored in quantities subject to the requirements of 40 CFR 68. WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS The worst-case release scen ario assumes a 2,000 pound release over ten minutes with a wind speed of 1.5 meters/second, an "F" stability class, and rural topography. Using the American Water Works Association Research Foundation's (AWWARF) Compliance Guidance and Model Risk Management Program for Water Treatment Plants results in a worst-case distance to toxic endpoint of 3.10 miles. The alternative release scenario assumed a valve or pipe failure resulting in a 5/16-inch diameter opening. Using the above-mentioned AWWARF Guidance Document, a wind speed of 3.0 meters/second, a "D" stability class, and rural topography resulted in a 0.57 mile distance to the toxic endpoint for chlorine. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM This was summarized above under Accidental Release Prevention and Emergency Response Policies. FIVE YEAR ACCIDENT HISTORY There have been no accidents subject to reporting under 40 CFR 68.42. EMERGENCY RESPONSE PROGRAM This was summarized above under Accidental Release Prevent ion and Emergency Response Policies. PLANNED CHANGES TO IMPROVE SAFETY As a result of the initial process hazard review conducted as part of this RMP, a number of changes are planned to improve safety. The most significant of these changes include: 1. Replacing exisiting chlorine feed system with a vacuum feed system; 2. Installation of a windsock in a visible location; 3. Purchase of chlorine leak detector; and 4. Requiring escape-type breathing units to be worn by two operators when changing chlorine containers. |