Limestone County Water & Sewer Authority - Executive Summary |
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1. Accidental Release Prevention and Emergency Response Policies We at Limestone Co. Water & Sewer Authoritare 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 process at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. We have 1 regulated substance present at our facility. This substance is chlorine. The use of chlorine is involved only in the disenfection of water. THE MAXIMUM INVENTORY AT OUR FACILITY IS 4000.00 lbs. 3. The Worst Case Scenario(s) ans The Alternative Release Scenario(s), incluuding administrative controls and mitigation measures to limit the distances for each reported scenario To perform the required offsite consequences analysis for our facility, we have used the look-up tables and equations provided by the EPA. The following paragraphs provide details of chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from potable water. The scenario involves the release of 2000 lbs of Chlorine in a gaseous form over 10 minutes. Passive mitigation controls such as enclosures are also taken into account to calculate the scenario. At class F atmospheric stability and 1.5 m/s windspeed, the distance of 4.8 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. One alternative release scenario has been submitted for each toxic substance present in Program 2 ans Program 3 processes cumulatively. The alternative release scenario for Chlorine involves a release from a 2000lb cylinder in the potable water process. The scenario involves the release of 600.oo lb of Chlorine in a gaseous form over 30 minutes. Passive mitigation controls such as enclosures are t aken into account to calculate the scenario. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.25 miles. 4. The General Accidental Reiease 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. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Limestone County Water & Sewer Authority maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controled efficiently. The methodology used to carry out these analyses is (METHODOLOG Y). 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 (time period). Any fidings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purpose of safety conduction activities within our covered processes, Limestone Co. Water & Sewer Auth. maintains written operation procedures. These procedures address various modes of operation such as iniyial startup, normal operations, temporary operations,emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is reguiariy reviewed and is readily accessible to operators involved in the process. Training Limestone Co. Water & Sewer Auth. has a comprehensive training program in place to ensure that employees who are operating procedures associated with these processes. Refresher training is provided at lease once every year and more frequently as needed. Mechanical Integrity Limestone CO. Water & Sewer Auth. carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks include 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 to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job task 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- startup safety reviews related to new processes and to modifications in established processes are conducted as a regular practice L.C.W.&S.A. 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 Limestone Co. Water & Sewer Auth. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried at least every 3 years and any corrective actions required as a result of these audits are undertaken in a safe and prompt manner. Incident Investigation Limestone Co. Water & Sewer Auth. 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 reoccu rring. All reports are retained for 5 years. Employee Participation Limestone Co. Water & Sewer Auth. 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 improvments. In addition, our employees have access to all information created as part of the facilitys implementation of the RMP rule, including information resulting from process hazard analyses in particular. 5. Five-Year Accident History Limestone Co. Water & Sewer Auth. has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Limestone Co. Water & Sewer Auth. carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including ade quate first aid and medical treatment, evacuations, notifications of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergencr response equipment is regularly inspected and serviced. In addition, the plan is promply updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 7. Planed Changes to Improve Safety At this time there are no planed changes. Our safety record is excellent, and all operatore are up to date on the latest equipment. 8. Certification Statement The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonably inquiry, the information submitted is true, accurate and complete. Name: Terry Shapiro Signature: Title: Treatment & Production Manager Date signed: 7/23/99 |