Water Works & Industrial Supply Company - Executive Summary |
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EXECUTIVE SUMMARY Accident Release Prevention Program and Emergency Response Policy It is the policy of the Water Works & Industrial Supply Company (Water Works) Lexington, Kentucky facility management to implement the requirements of this Risk Management Program (RMP) in accordance with the USEPA regulations under 40 CFR Part 68 and with the corresponding regulations under OSHA's Process Safety Management (PSM) program. The objective is to minimize the risk of a release of a hazardous material and if a release occurs, to minimize the potential impact to Water Works employees, the public and the environment. This objective will be accomplished by utilizing general good operating procedures, providing appropriate training to all employees, and coordinating response activities, as necessary, with the local emergency response providers. Water Works management is committed to providing the resources necessary to implement this policy. Facility Description Water Works operates a water tre atment and industrial supply distribution center at this location. Chlorine and sulfur dioxide cylinders are received, stored and shipped to public and private wastewater treatment facilities. Two chemicals, chlorine and sulfur dioxide are stored at the facility in sufficient quantities to be subject to the requirements of 40 CFR Part 68. The facility stores 150-pound and 2,000-pound cylinders of chlorine and 150-pound cylinders of sulfur dioxide. Worst-Case and Alternative-Release Scenarios RMP regulations require that each facility identify worst-case and alternative case release scenarios. EPA has defined a worst-case release as the release of the entire contents of the largest vessel that contains a regulated substance in a 10-minute period. This release rate is then evaluated using modeling techniques and/or reference tables to define the distance to a specified endpoint (concentration or overpressure). The distance to the endpoint is affected by several factors including mol ecular weight, volatility, heat of combustion, and physical setting (urban or rural). The alternative release scenario must be one that is more likely to occur than the worst-case scenario and that reaches an endpoint offsite, unless no such scenario exists. The alternative release scenario is also evaluated to define the distance to the specified endpoint. Under 40 CFR 68 Subpart B '68.22(e), the RMP rule identifies surface roughness as a parameter to be used in the hazard assessment to determine the physical setting of the site, urban or rural. "Urban means there are many obstacles in the immediate area; obstacles include buildings or trees. Rural means there are no buildings in the immediate area and the terrain is generally flat and unobstructed." Due to the presence of trees, hills, and/or other structures in the immediate vicinity of the Lexington, Kentucky facility, an urban dispersion environment was assumed. Chlorine The data provided in the United States Environmental Prot ection Agency (USEPA) guidance document "Risk Management Program Guidance for Wastewater Treatment Plants" (October 1998) was used to estimate the toxic endpoint distance for the worst-case and alternative chlorine release scenarios. The worst-case release scenario for chlorine included a release of all the contents of the largest storage vessel (2,000-pound cylinder) in a 10-minute period. This release translates to a release rate of 200 lbs/min. Assumptions for the worst-case chlorine analysis include the chlorine is a liquefied gas; the 2,000-pound cylinder is not diked; no passive mitigation system (including buildings) are in place; the nearfield dispersion environment is characterized as urban; 10-minute averaging period; the windspeed is 1.5 meters/sec and the atmospheric stability is classified as F (stable). The results of the worst-case assessment for chlorine show that the regulatory defined endpoint of 3.0 ppm is found to occur at a distance of 1.3 miles from the release point. The selected alternative-release scenario for the chlorine system is a release resulting from a pinhole leak that leads to the release of the entire contents of the 2,000-pound chlorine cylinder. The release rate from a 1/16-inch diameter hole is 0.6 lb/min. Based on the release rate of 0.6 lbs/min, the duration of a 2,000-pound release is 3,333 minutes. Assuming no active or passive mitigation measures are currently in place; the meteorological data used for this alternative release scenario was a wind speed of 3 meter/sec, an atmospheric stability classification of D (neutral stability), and an urban dispersion environment in the nearfield. The results of the alternative-release scenario for a chlorine release indicate that the endpoint of 3.0 ppm is reached at a distance of 0.1 mile from the release point. Sulfur Dioxide The data provided in the USEPA guidance document "Risk Management Program Guidance for Wastewater Treatment Plants" (October 1998) was used to estimate the toxic endpoint distance for the worst-case and alternative sulfur dioxide release scenarios. The worst-case release scenario for sulfur dioxide included a release of all the contents of the largest storage vessel (150-pound cylinder) in a 10-minute period. This release translates to a release rate of 15 lbs/min. Assumptions for the worst-case sulfur dioxide analysis include the sulfur dioxide is a liquefied gas; the 150-pound cylinder is not diked; no passive mitigation system (including buildings) are in place; the nearfield dispersion environment is characterized as urban; 10-minute averaging period; the windspeed is 1.5 meters/sec and the atmospheric stability is classified as F (stable). The results of the worst-case assessment for sulfur dioxide show that the regulatory defined endpoint of 3.0 ppm is found to occur at a distance of 0.3 mile from the release point. The selected alternative-release scenario for the sulfur dioxide system is a release resulting from a pinhole l eak that leads to the release of the entire contents of the 150-pound sulfur dioxide cylinder. The release rate from a 1/16-inch diameter hole is 0.28 lb/min. Based on the release rate of 0.28 lbs/min, the duration of a 150-pound release is 535 minutes. Assuming no active or passive mitigation measures are currently in place; the meteorological data used for this alternative release scenario was a wind speed of 3 meter/sec, an atmospheric stability classification of D (neutral stability), and an urban dispersion environment in the nearfield. The results of the alternative-release scenario for a sulfur dioxide release indicate that the endpoint of 3.0 ppm is reached at a distance of 0.1 mile from the release point. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The Lexington, Kentucky facility is governed by a set of OSHA and USEPA regulations that require planning and facility activities intended to prevent a release of hazardous material, or i f a release inadvertently occurs, to minimize the consequences of a release to the employees of the facility, the public and to the environment. These regulations include: * 40 CFR Part 68, Accidental Release Prevention * 29 CFR Part 119, Process Safety Management * 40 CFR Part 302, Emergency Planning and Community Right-to-Know Act (EPCRA) The key concepts in Water Works' release prevention program are employee participation, appropriate maintenance of equipment, and appropriate training of all employees. Water Works is in the process of developing and documenting these elements in their process safety management plan (PSM). Employee participation in the release prevention program is encouraged and supported by Water Works management. Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for chlorine and sulfur dioxide storage. Water Works is committed to providing appropriate training to all employees regarding safety pro cedures. New employees are provided comprehensive safety training during their initial orientation for the facility. In addition, Water Works conducts regularly scheduled safety training for all employees each year. Five Year Accident History Water Works has not had a release of chlorine or sulfur dioxide from the Lexington, Kentucky facility that has caused on-site deaths, injuries, or significant property damage or known offsite deaths, injuries, property damage, evacuations, or sheltering in place. However, on June 27, 1997, the facility had a slow (pinhole) leak from a 150-pound chlorine cylinder that caused minor environmental damage. Emergency Response Program Water Works is currently developing a program for emergency response at the facility 24 hours per day, seven days per week. It is planned to complete this program by October 1, 1999. Planned Changes to Improve Safety Water Works completes a thorough review of the chlorine and sulfur dioxide storage areas each time a desig n change is implemented. Water Works is committed to using these methods to identify and implement ways to improve the safety of these areas. |