Raw Water Disinfection Facility - Executive Summary |
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Raw Water Disinfection Facility Risk Management Plan Executive Summary This Risk Management Plan has been compiled to meet Environmental Protection Agency Clean Air Act requirements as delineated in 40 CFR Part 68. The regulation requires procedures to protect the public and employees from the risk of accidental emissions of certain hazardous chemicals. The following facility meets the criteria for a Program 2 category as defined in 40 CFR Part 68: 7 Raw Water Disinfection Facility 6902 Cherokee Circle Abilene, TX This Risk Management Plan offers a systematic process for design, operation, and maintenance of a water treatment plant in such a way as to minimize risks associated with storage and use of 12,000 lbs. of chlorine utilized in the disinfection process. In the development of this plan, existing operational and safety policies and procedures were evaluated and, in some areas, enhanced to assure compliance with the law and optimum safety for public and employees. Various staff levels were involved in the development of this plan including management, supervisory, operations, and maintenance. The City of Abilene's Risk Management Plan will be incorporated as an element in the Water Utilities' overall health and safety program. The City of Abilene conducted a release analysis utilizing the EPA's RMP Comp Model to determine the off-site consequence of a worst case release for chlorine. The criterion used, and the results of this modeling are as delineated: Chlorine - 2000 lbs. released across 10 minutes duration, in an enclosed structure vented to atmosphere, in a rural environment, with a wind speed of 1.5 meters/second, and with an atmospheric stability class "F". Administrative controls at this facility dictate that no more than 2000 lbs. of chlorine are utilized in the process at any one time. The distance to the toxic end point was determined to be 4.8 miles. Additionally, the City of Abilene conducted an alternative release scenario utilizing the EPA's RMP Comp Model to determine the off-site consequence of a release that is more likely to occur than the worst case scenario for chlorine. The criterion used, and the results of this modeling are as delineated: Chlorine - 1.7 lbs. released from a pipe across 10 minutes duration, in a rural environment, in an enclosed structure vented to atmosphere, with a wind speed of 3.0 meters/second, and with an atmospheric stability class "D". Mitigation measures for this analysis include chlorine detectors in process area, visual and audio alarms, written operating procedures, vacuum regulators, manual and automatic shutoffs, and no history of a release. The distance to the toxic end point was determined to be 0.11 miles. In addition to the mitigation measures delineated in the off-site consequence analysis the City of Abilene has implemented a Prevention Program that consists of; updated safety information on all process chemicals; designing, constructing and operating all processe s in accordance with regulatory and industry-specific codes and standards; conducted an initial hazard review that will be updated at least every five years by a registered professional engineer; established written operating procedures; fine tuned operational, safety and maintenance training; a preventative and corrective maintenance program to ensure the integrity of all process equipment; established a formal incident investigation process; and a compliance audit process, to evaluate compliance with the Risk Management Program every three years. This facility is included in the Taylor County Local Emergency Planning Committee's Emergency Response Plan. The emergency responder for this facility will be the City of Abilene Fire Department. The Fire Dept. conducts annual inspections and requires procurement of a hazardous materials permit of this facility. The plant personnel will initiate immediate response to any chemical release by shutting down and isolating the source. |