Anderson Pumping Station - Executive Summary |
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Executive Summary The Anderson Primary Pumping Station is one of multiple pumping stations operated by the San Antonio Water System (SAWS) where chlorine, stored in ton containers, is used to provide disinfection for the potable water system. Chlorine is stored at the site in a quantity greater than 2,500 pounds, the applicability threshold for the Accidental Release Prevention Rules set forth in 40 CFR Part 68. SAWS designed this Risk Management Program to achieve the following objectives: X Reduce the potential of an accidental release of chlorine, X Minimize the impacts should a release occur, and X Comply with the environmental regulations The Compliance Guidance and Model Risk Management Program for Water Treatment Plants, prepared by the American Water Works Association and the AWWA Research Foundation, and sponsored by EPA and the AWWA Research Foundation, provided the backbone of this Risk Management Plan. SAWS has determined that the chlorine storage and handling operati on at the pumping station is a Program 2 process. The results of a Hazards Assessment (or Off-Site Consequence Analysis) of chlorine conducted for the site suggests that public receptors could be impacted in the event of a "worst-case" release of chlorine. The facility is not subject to OSHA's process safety management plan rule and does not operate under one of the SIC codes listed in 40 CFR 68.10(d)(1). The Risk Management Plan contains an management program that details the persons responsible for implementing and updating the RMP and the results of a Hazards Assessment, which was conducted to estimate the potential environmental and public receptors that could be impacted by a worst-case and alternative release scenarios. A Program 2 Prevention Program was prepared that documents a management program, safety information on the chlorine process, the results of a hazards review, written operating and maintenance procedures and descriptions of SAWS training, compliance audit and incident investigation procedures. SAWS has determined that it will rely on local emergency response personnel to coordinate off-site activities in the event of a significant release of chlorine. SAWS has an emergency response program to train employees to identify the source of the chlorine leak and to implement emergency notification procedures. SAWS works closely with the San Antonio Fire Department to ensure that proper emergency response procedures are in-place to quickly and effectively respond should a chlorine release occur. |