Wellfield Pump Station - Executive Summary |
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Executive Summary This document was developed to comply with the U. S. Environmental Protection Agency's Risk Management Program as directed under Section 112(r) of the Clean Air Act Amendments of 1990, 40CFR, Part 68. The use and storage of chlorine in excess 2500 pounds at this facility is the process that is covered under this regulation. 1. Accidental Release Prevention and Emergency Response Policies Texas A&M University is strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Any release or potential release of chlorine will be addressed promptly with qualified personnel and procedures. Texas A&M University Utility emp loyees are responsible for operation and maintenance at this facility. The employees are qualified and trained to handle routine equipment failures and leaks. Uncontrolled releases of chlorine will be handled by the Texas A&M University Hazardous Materials Response Team. This team is part of the University's Environmental Health and Safety Department and is trained to handle various hazardous material and waste spills associated with University activities. The HazMat Response Team also works in association with the City of Bryan Fire Department (who also have response capabilities at the facility) on various on- and off-campus scenarios. Texas A&M University actively participates in the Brazos County Local Emergency Planning Committee. 2. The Facility and the Regulated Substances Wellfield Pump Station's primary activities include the initial booster pump station, storage and chlorination for consumable water delivered to the Texas A&M University Main Campus. There is one reg ulated substances present at our facility. That substance is chlorine. Chlorine is used for disinfection of consumable water. The maximum inventory of chlorine at the Wellfield Pump Station is 20000.00 lb. 3. The Worst Case Release Scenario and the Alternative Release Scenario. To perform the required offsite consequence analysis for the Wellfield Pump Station, we have used the EPA's RMP*Comp(TM). The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from chlorine storage and feed. In this scenario 2000 lb. of chlorine is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 3.o miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. Depending upon wind direction the 3.0 mile radius could include single family residences and university offices and classrooms. The alternative release scenario for chlorine involves a release from chlorine storage and feed. The scenario involves the release of 2000 lb. of chlorine. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of chlorine is 0.6 miles. Depending on wind direction the 0.6 mile radius could include single family residences. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Texas A&M University has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The following sections briefly describe the elements of the release prevention program that is in place at our facility. Process Safety Information Wellfield Pump Station maintains a detailed record of safety information that describes the hazards of chlorine, operating parameters and equipment designs associated with the chlorine feed processes. Operating Procedures For the purposes of safely conducting activities within our covered processes, Texas A&M University maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Texas A&M University has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Texas A&M U niversity also maintains the training of personnel responsible for emergency response. Mechanical Integrity Texas A&M University carries out documented maintenance checks on process equipment to ensure proper operations. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Wellfield Pump Station to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Compliance Audits Texas A&M University conducts audits on a regular basis to determine whether the provisions se t out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Wellfield Pump Station promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Contractors Texas A&M University utilizes contractors on a regular basis to address specific and sensitive processes or equipment. The chlorination equipment is an area where this expertise is utilized for installation, maintenance and troubleshooting. Contractors are briefed on potential safety issues and procedures prior to commencing assigned tasks. 5. Five-year Accident History Wellf ield Pump Station has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Texas A&M university maintains a written emergency response plan to deal with accidental releases of chlorine. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. The University HazMat Team maintains the necessary emergency response equipment to respond to chlorine releases from the Wellfield Pump Station. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Texas A&M University actively participates in the Brazos County Local Emergency Planning Committee in dealing with both campus and local emergency situations. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Recently we installed a fail safe (vacuum) system for feeding chlorine and installed new leak detection equipment. In the very near future we will have the entire chlorine supply and feed system automated and that will greatly improve safety and response time. |