East Moline Wastewater - Executive Summary |
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General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 1. Accidental release prevention and Emergency Response policies We at East Moline Wastewater are 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. Unforeseeably, if such a release does occur, we are completely coordinated with Rock Island Emergency & Disaster which provides highly trained emergency response personnel to control and mitigate the effects of the release. 2. The Stationary Source and the Regulated Substances Handled We have 1 regulated substance present at our facility which is Chlorine. The maximum inventory of Chlorine at our facil ity is 8000 lbs. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To perform the required offsite consequence analysis for our facility, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. Toxic Worst-case analyses The Worst Case scenario involves a catastrophic release from Disinfection. The scenario involves the release of 2000 lb. of Chlorine in a gaseous form over 10 minutes. The Release rate (lbs/min) is calculated to be 200. A distance to endpoint of 5.4 miles is obtained which affects a residential population of 9164 within this distance. Toxic Alternative-case analyses The Alternative Case scenario involves a catastrophic release from Disinfection. The scenario involves the release of 2000 lb. of Chlori ne in a gaseous form over 15 minutes. The Release rate (lbs/min) is calculated to be 133 and a Distance to endpoint of 1.5 miles is obtained which affects a residential population of 707. Flammables Worst-case analyses None applicable Flammables Alternative-case analyses None applicable 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information East Moline Wastewater maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard An alysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is the what if/checklist, fault tree analysis, and the failure mode and effects analysis. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of three years or sooner if there are any equipment changes made. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, East Moline Wastewater 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 East Moline Wastewater 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. New employees receive basic classroom training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided at least every three years and more frequently as needed. Mechanical Integrity East Moline Wastewater carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. 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 East Moline Wastewater 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. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at East Moline Wastewater. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits East Moline Wastewater conducts audits on a regular basis to determine whether the provisions set ou t 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 East Moline Wastewater 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. Employee Participation East Moline Wastewater truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, inclu ding information resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. East Moline Wastewater has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History East Moline Wastewater 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 The Local agency coordinating ER Plan is Rock Island Emergency & Disaster which has the phone number 309-794-9111 7. Planned Chang es to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. A review of the overall safety program has begun and notations of necessary areas of improvement are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by 8/1/99. |