MI College Water Treatment Plant - Executive Summary |
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Executive Summary for MI College Water Treatment Plant (October 1999) THIS IS A PREDICTIVE FILING AS CONSTRUCTION ON A NEW SITE WILL NOT BE COMPLETED UNTIL OCTOBER 1999. AT SUCH TIME THE PLAN WILL BE UPDATED. 1. Accidental Release Prevention and Emergency Response Policies We at the MI College Water Treatment Plant are 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 processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activity encompasses disinfection of drinking water. We will have one regulated substance present at our facility. This substance is chlorine. Chlorine will be used to disinfect the drinking water. The maximum inventory of Chlorine at our facility will be 8000.00 lb. 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 EPA's RMP*Comp(TM). The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from chlorination of water. In this scenario 8000 lb. of chlorine is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. The released quantity has been limited to 55 % of the maximum capacity of the source by a system of administrative controls. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 4.2 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. The alternative release scenario for chlorine involves a release from chlorination of water. The scenario involves the release of 400 lb. of chlorine. The toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 20 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.2 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility will take all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. The following sections briefly describe the elements of the release prevention program that will be in place at our stationary source. Process Safety Information The MI College Water Treatment Plant will maintain a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Operating Procedures For the purposes of safely conducting activities within our covered processes, the MI College Water Treatment Plant will maintain written operating procedures. These procedures will 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 will be regularly reviewed and made readily accessible to operators involved in the processes. Training The MI College Water Treatment Plant will institute a comprehensive training program to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refre sher training will be provided at least every two years and more frequently as needed. Mechanical Integrity The MI College Water Treatment Plant will carry out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks will include among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations will be carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel will be offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks will be corrected in a safe and timely manner. Management of Change Written procedures will be in place at the MI College Water Treatment Plant to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tas ks would be affected by a modification in process conditions will be made aware of the change 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 will be conducted as a regular practice at the MI College Water Treatment Plant. These reviews will be conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits The MI College Water Treatment Plant will conduct audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits will be carried out at least every 3 years and any corrective actions required as a result of the audits will be undertaken in a safe and prompt manner. Incident Investigation The MI College Water Treatment Plant will promptly investigate any incident that has resulted in, o r could reasonably result in a catastrophic release of a regulated substance. These investigations will identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports will be retained for a minimum of 5 years. Employee Participation The MI College Water Treatment Plant truly believes that process safety management and accident prevention is a team effort. Company employees will be strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees will 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 will be carried out. The MI College Water Treatment Plant will have a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors will be informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History The MI College Water Treatment Plant has no accident history as the plant has not been completed. 6. Emergency Response Plan The MI College Water Treatment Plant will develop a written emergency response plan to deal with accidental releases of hazardous materials. The plan will include all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment will be regularly inspected and serviced. In addition, the plan wi ll be updated promptly to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Clay County EPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan will be coordinated and verified. 7. Planned Changes to Improve Safety We will enhance our emergency response plan and coordinate closely with the CCEPC, the West Point Fire Department, and the Golden Triangle HazMat Team. |