Ponderosa Joint Powers Agency WWTP - Executive Summary |
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The Risk Management Rule, codified in 40 Code of Fedral Regulation (CRF) Part 68, frequently is referred to as "112R" because it falls under that section of the Clean Air Act Amendment (CAAA) of 1990. The regulations are intended to help prevent accidental releases of toxic chemicals to the atmosphere and to minimize cosequences should a release occur. PJPA Risk Management Plan consists of the following: 1) Executive Summary 2) Registration Information 3) Toxics: Worste Case 4) Toxics: Alternative Release 5) Accident History 6) Prevention Program Level 3 7) Emergency Response. PJPA has no employees. PJPA Wastewater Treatment Plant is operated and maintained by S & W Water Maintenance, a contract operations company, which operates several wastewater treatment plants in Houston area. PJPA Plant stores and handles a maximum of 8,000 pounds of chlorine. Chlorine is a toxic substance used in the disinfecting wastewater effluent prior to discharge into receiving streams. PJPA has an E mergency Response Plan in place as part of its operational manual. The purpose of this procedure is to ensure that a complete written emergency action plan and effective response capabilities for the covered process. Comprehensive Emergency Action plan, when combined with emergency response training, can effectively minimize the impact of an accidental release by ensuring proper and quick response. Offsite Consequence Analysis were conducted by considering a worst-case release scenario and alternative release scenario. EPA's RMP* Comp(TM) was utilized in modeling offsite consequence release analysis. In modeling a worst- case scenario, 2,000 Ibs of chlorine was released in 10 minutes which leads to a release rate of 200.0 Ibs/min. of chlorine. Wind speed is 1.5 m/s as set by the EPA.The distance to endpoint is 1.3 miles. The estimated residential population within distance to endpoint is 5,500 people. The local topography is urban with many obstacles including buildings and trees. Pu blic receptors that may be exposed to toxic concentrations within the circle with a center at the point of the release and a radius of 1.3 miles to endpoint, as a result of the release, are including Schools, Residences, Hospital, and some comercial area. There are no Environmental Receptors within distance to endpoint that may be affected by a release. Passive mitigation measures that were considered in defining the release quantity, including dikes, berms, drains and sumps. Two alternative release scenarios were modeled, with endpoint distance of 0.3 miles and 0.2. respectively. 2000 Ibs and 1000 Ibs were released in 10 minutes, that leads to 200 Ibs/min. 100 Ibs/min. release rate. The estimatrd distance to endpoint is 0.3 miles and 0.2 miles. Population that may be affected by both scenarios is 2,000 and 1,400 people. Public receptors that may be exposed by a toxic release are basicly residences. No Environmental Receptors would be exposed to the release within distance to endpoint s. The passive mitigation measures that were considered in defining the release rate are dikes, berms, drains, and sumps. Both scenarios were modeled due to the fact that they may occur. The general accidental prevention program and chemical-specifics steps taken by PJPA are included in the Operation and Maintenace Manual. Personnel involved in operation of the Chlorination system are trained in chlorine use, health hazard associated with chlorine, chlorine cylinder use, equipment maintenance, medical aspects and emergency response procedures. "Clorine Manual" which is prepared by the Chlorine Institute is also available in the operation office. As preventive measures, all chlorine lines are checked to be free of cracks, leaks, or poor connections. Chlorinator is inspected for proper operations. Chlorine gas detector including two sensors are located in the chlorine building to detect gas leaks in the chlorination system. PJPA has an Emergency Action Plan in place. In the event of an emergency, response responsibility is coordinated with local response agencies. This is to ensure employee safety, rather than a full-fledged emergency response plan. Emergency Action plan is reviewed and updated, and emergency response training will be coordinated by the Risk Management Plan Manager. Training will be conducted by qualified in-house staff or outside resources. Emergency Action Plan will be reviewed annually to ensure that they are current and comply with EPA- RMP regulations. The facility will conduct awareness-level emergency response training of all personnel on-site. Refresher training will be provided annually to all response team personnel to ensure they have the required level of competency. The plant superintendent will provide all community responder organizations who will assist in major incidents with a copy of the EAP and updates. He also will arrange for one meeting, drill or exercise each year with local organizations to promote preparedness for effectiv e response in the event of an incident. Ponderosa Forest Volunteer Fire Department will respond if a chlorine leak is detected. The Risk Management Plan ( in a bound book ) is available in the control building at PJPA Plant. |