Wallace R. Knox Wastewater Treatment Plant - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY REPSPONSE POLICIES Chlorine is the regulated chemical used at this facility. It is our policy to adhere to all applicable Federal and State regulations concerning the safe handling and usage of chlorine. With the proper use, handling and storage of chlorine this facility will prevent unnecessary human and environmental exposure, reduce the risk to our own employees, and to protect the City of Texas City and its citizens. This will be accomplished through continuous training of our employees, the safety and detection devices that we have installed within this facility, an aggressive preventive maintenance program, and through the manner that we handle the chemical. Emergency response to this facility is through the City of Texas City Fire Department's Hazardous Materials Team. These dedicated individuals are trained to respond quickly to any release of hazardous chemicals in the area. STATIONARY SOURCE AND REGULATED SUBSTANCE HANDLED The purpose of this facility is to treat all of the domestic wastewater coming from the City of Texas City. Chlorine is received by this facility in one ton cylinders and is housed in a secure building where it is utilized for disinfection of the discharge waters of the facility. The total inventory of Chlorine in this facility is 24,000 pounds. The facility is City owned and operated, but access to the property is limited. All visitors to the property must check into the administration building. WORST CASE AND ALTERNATE RELEASE SCENERIOS Worst Case Scenerio- If the gas valve assembly on a one ton cylinder is broken off while and operator is tightening on a yoke assembly. This would result in one ton of chlorine gas escaping from the cylinder into the chlorine building. Because the gas is escaping into a building, the building acts as a passive mitigator and slows the chlorine release into the environment. Using the US EPA OCA Guidance and factoring in the gas being released inside a building, the distance to the toxic endpoint of 0.0087 mg/L (3 ppm) would be 5.7 miles. This type of release would have effect offsite receptors. This type of release would have a very low probablity of occuring. In house procedures on safely attaching yoke assemblies to one ton cylinders are in place. Alternate Release Scenerio- If a transfer line from the yoke assembly to the manifold header should develop a 1/4 in hole, the gas released would be approximately 1579 pounds. This gas would be released into the chlorine building. Again, the building is acting as a passive mitigator and slowing the gas released to the environment. Using the US EPA OCA Guidance, factoring in a twenty minute response time, and knowing that the release is occuring in a building, the distance to the toxic endpoint of 0.0087 (3 ppm) would be .99 miles. The transfer lines from the yoke assemblies to the manifold headers are the most common component of the chlorine system that is handled. Each time a new cylinder is hooked up the transfer line is moved and worked with. Maintenance procedures and checks are in place to prevent this occurance. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS The City of Texas City falls under the State EPCRA rules and regulations. This facility complies with those regulations and all applicable state and federal codes and standards. Through our procedures and training program, the employees of this facility insure the accidental releases of chlorine gas are prevented. In our process area, chlorine gas detectors are installed to alert plant personnel and the emergency dispatchers at the Police Department of any gas release. With early detection comes early mitigation of any problem which may occur. FIVE YEAR ACCIDENT HISTORY The City of Texas City Wallace R. Knox Wastewater Treatment facility have had no accidental releases of chlorine gas within the last five years. EMERGENCY RESPONSE TO CHEM ICAL RELEASES The Texas City Fire Department HAZMAT team will handle all emergency responses to chlorine leaks at this facility. The Fire Department had a chlorine release drill at this facility on May 12, 1998. PLANNED CHANGES TO IMPROVE SAFETY This facility will be installing an exterior audible warning device to alert plant personnel of a gas release. We are continuously evaluating our operational procedures to make the use and handling of chlorine at this facility as safe as possible. |