East Moline Water Filtration Plant - Executive Summary |
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Executive Summary City of East Moline, Illinois Water Filtration Plant 901 12th Avenue 1. Accidental release prevention and Emergency Response policies We at East Moline Water Filtration Plant 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, our trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also completely coordinated with Rock Island County LEPC which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled We have 1 regulated substance present at our facility w hich is Chlorine. The maximum inventory of Chlorine at our facility is 12000 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 CompuTerra Co. software program wich in turn used 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 chlorination. 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 126384 within this distance. Toxic Alternative-case analyses The Alternative Case scenario involves a catastrophic release from chlorination. The scenario involves the release of 3.3 lb. of Chlorine in a gaseous form over 10 minutes. The Release rate (lbs/min) is calculated to be 0.33 and a Distance to endpoint of 0.08 miles is obtained which affects a residential population of 0. 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. The chlorination process at our facility is the only process subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety In formation East Moline Water Filtration Plant 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 controlled efficiently. The methodology used to carry out these analyses is the What-If Checklist. 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 every 3 years or whenever their is a change in the process. 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 Water Filtration Plant 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 Water Filtration Plant 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 safety orientation within the first week and on-the-job supervision until they are deemed competent to work independently. Refresher training is provided at least every year and more frequently as needed. Mechanical Integrity East Moline Water Filtration Plant carries out a computer documented preventative maintenance program on process equipment to ensure proper operations. Process equipment examined by this program includes among others; chlorine leak minitors, storage tanks, piping systems, relief and vent s ystems, automatic switch over systems, ejectors and chlorinators. 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 Water Filtration Plant 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 Water Filtration Plant. These reviews are conducted to confirm that construction, eq uipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits East Moline Water Filtration Plant conducts audits on a regular basis to determine whether the provisions set out 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 Water Filtration Plant 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 Water Filtration Plant truly believes that process safety management and accident prevention is a t eam effort. Plant 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, including 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 Water Filtration Plant 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 An accident occurred in chlorination on 7/17/97. The release duration was 000:05 minutes. The On-site property damage was around $0.00 while there were 0 on-site deaths. There were 2 on-site injuries and no Off-site deaths. The number of off-site hospitalizations were 0 and 2 people were given medical treatment. 0 people were evacuated and 0 were sheltered-in-place. The Off-site property damaged is estimated at $0.00. Chlorine was the only chemical involved in the accident. The initiating event for the accident was human error. An accident occurred in chlorination on 8/11/97. The release duration was 000:01 minutes. The On-site property damage was around $0.00 while there were 0 on-site deaths. There were 1 on-site injuries and no Off-site deaths. The number of off-site hospitalizations were 0 and 1 person was given medical treatment.0 people were evacuated and 0 were sheltered-in-place. The Off-site property damaged is estimated at $0.00. Chlorine was the only chemical involved in the accident. The initiating event for the accident was human error. 6. Emergency Response Plan Facility is included in written Community ER Plan. Facility has its own written ER Plan. The ER Plan includes specific actions to be taken in response to accidental releases of regulated substances. The ER Plan includes procedures for informing the public and local agencies for responding to accidental release. The ER Plan includes information on emergency health care. Date of most recent review/update of ER Plan: 5/20/99 Date of most recent ER training of employees: 7/22/97 The Local agency coordinating ER Plan is Rock Island County LEPC which has the phone number 309-794-9111 The East Moline Fire Department is considered to be the first response team and is contacted by dialing 911 in the case of ahazardous material release. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Improved safety training and documentation are some of the maj or steps we want to take to improve safety at our facility. These changes are expected to be implemented by 11/1/99. |