Culebras Alto-Cayey-Filtration Plant - Executive Summary |
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Compaqma de Aguas de Puerto Rico (CAPR) as operator of the Puerto Rico Aqueduct & Sewer Authority (PRASA) system has developed a Risk Management Plan (RMP) for management and prevention of risks associated with the storage and use of chlorine, a regulated toxic substance, at the Culebras Alto-Cayey Water Filtration Plant. The RMP was prepared in compliance with 40 CFR Part 68 and Clean Air Act (CAA) Section 112(r)(1). The Prevention Program elements build upon the facility's Process Safety Management (PSM) system prepared in compliance with 29 CFR Part 1910.119. Accidental Release Prevention and Emergency Response Policies It is CAPR's policy to comply with applicable Federal and Puerto Rican requirements. The chlorination process at the Culebras Alto-Cayey Water Filtration Plant uses chlorine, a hazardous toxic substance regulated by EPA, OSHA, and PROSHO. Due to the hazardous characteristics of chlorine, the Culebras Alto-Cayey Water Filtration Plant observes various safety pr ecautions in the storage, conveyance and use of chlorine. The safety precautions are necessary to protect employees, contractors, and visitors at the Culebras Alto-Cayey Water Filtration Plant and the immediately surrounding areas. Safety precautions include procedures and equipment to minimize the potential for accidental release, as well as a written emergency response program for response to any chlorine release that may occur. The Stationary Source and Regulated Substances Handled The Culebras Alto-Cayey Water Filtration Plant supplies up to 0.14 million gallons per day of water to the surrounding community. Chlorine is used to disinfect the water, destroying microorganisms that could cause illness in humans. Chlorine is delivered to the facility via truck in 150 pound cylinders. The storage building has space for up to eleven full cylinders, a total of 1,650 pounds of chlorine. Chlorine cylinders are connected to vacuum chlorinators. The chlorinators regulate chlorine use . From the chlorinators, chlorine gas is distributed under vacuum to injectors. The injectors combine the gaseous chlorine with water. The chlorinated water is mixed with the water plant flow for disinfection. Worst-case and Alternative Release Scenarios The worst-case release scenario was determined following EPA's Risk Management Program Offsite Consequence Analysis Guidance. The worst-case release scenario is a vapor release of the entire contents of a 150 pound cylinder over an eighteen minute period (8.3 pounds of chlorine per minute). Other worst-case assumptions required by EPA include a low wind speed (1.5 meters per second), stable atmosphere (Class F), urban topography, and no active mitigation of the release. The storage room enclosure would provide passive mitigation of the release. EPA requires the determination of the area (zone of vulnerability) which may be exposed to a chlorine concentration of 3 ppm or greater. According to the American Industrial Hygiene As sociation, 3 ppm is the maximum concentration of chlorine in air below which nearly all people could be exposed for one hour without serious health effects. Based on the worst-case assumptions, the zone of vulnerability was determined to extend 0.3 miles from the chlorine storage area. The following are known to be within the zone of vulnerability for the worst-case release scenario: residences and recreation areas. Approximately 70 residents are located within a 0.3 mile radius of the chlorine storage area. Many of these residents would not actually be impacted in even a worst-case release, as the chlorine would travel in the direction of wind. No known environmental receptors (such as state parks or officially designated wildlife preserves) are located within the zone of vulnerability. The conditions and parameters for the worst-case scenario are specified by EPA. A more realistic alternative release scenario was examined, also following EPA's Risk Management Program Offsit e Consequence Analysis Guidance. The alternative release scenario is a vapor release of the entire contents of a 150 pound cylinder over an eighteen minute period (8.3 pounds of chlorine per minute). More typical weather conditions are used (wind speed of 3.0 meters per second, atmospheric stability Class D). Other conditions remain the same as in the worst-case scenario (urban topography, passive mitigation of the release by the storage room enclosure). The zone of vulnerability for the alternative release scenario is determined to extend 0.1 miles from the chlorine storage area. Approximately 8 residents and recreational area are located within a 0.1 miles radius of the chlorine storage area. These residents and recreational area could be impacted, depending on the direction of wind. No known environmental receptors are located within the zone of vulnerability. General Accidental Release Prevention Program and Chemical-specific Prevention Steps CAPR complies with PROSHO requ irements for Prevention Programs and for Process Safety Management. Operators, maintenance staff and contractors are informed of chlorine hazards, and hazard signs are posted in the chlorine storage area. Standard operating and maintenance procedures have been developed, and employees who work with chlorine are provided training. Emergency Response Program CAPR has an emergency response program. Chlorine gas detectors are located within the storage area for early detection and warning of any leak. Leak repair kits are maintained on site, and operators are trained in how to quickly stop any leak that may occur. The emergency response program is coordinated with Civil Defense for notification of the public. CAPR periodically conducts various training programs, including emergency response training. All CAPR facilities are scheduled to recieve refresher training by September 30, 1999. Five-year Accident History Within the past five years there have been no unplanned releases of chlorine in excess of 10 pounds resulting in injuries or significant property damage on site; or known offsite injuries, evacuations, sheltering in place, property damage, or environmental damage. Planned Changes to Improve Safety CAPR uses Process Hazard Analyses (PHA) to identify and recommend changes to ensure a high level of safety. Issues identified from a PHA are then addressed in CAPR's Prevention Program. Recommendations from the most recent PHA include more frequent training in operating and maintenance procedures, and an improved preventative maintenance program. An audit of the RMP and PSM programs will be conducted within three years to verify the effectiveness of the program. |