Northeast Station - Executive Summary

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EXECUTIVE SUMMARY 
 
1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE  
POLICIES 
 
The El Paso Water Utilities - Public Service Board (EPWU- 
PSB) has prepared this Risk Management Plan (RMP) for the  
chlorination process at the Northeast Station, in compliance  
with 40 CFR 68.  
 
The main objectives of this RMP are to:  
 
(1) Communicate the extent of a possible chlorine release  
and identify possible receptors (Hazard Assessment),  
 
The Hazard Assessment communicates the possible extent of a  
worst case release and an alternative `more likely' release.  
The Hazard Assessment also identifies potential public and  
environmental receptors that may be affected in the event of  
a chlorine release. 
 
(2) Develop strategies to prevent an accidental release  
(Prevention Program),  
 
The goal of the Prevention Program is to integrate  
technologies, procedures, and management practices to  
minimize the probability of an accidental chlorine release.  
The Prevention Program incorporates safety info 
rmation,  
hazard review, operating procedures, training, maintenance,  
compliance audits, and incident investigations. 
 
(3) Formulate contingency planning in the case of an  
accidental release (Emergency Response Program). 
 
The Emergency Response Program is modeled after the EPWU- 
PSB's `Emergency Response Action Plan' and the Chlorine  
Institute's `Emergency Response Plans for Chlorine Plans for  
Chlorine Facilities.' The Emergency Response Program  
incorporates an emergency response plan, emergency response  
equipment procedures, training in relevant procedures for  
employees involved in the chlorination process, and  
procedures to review and update, as appropriate, the  
emergency response plan to reflect changes and ensure that  
employees are informed of changes. 
 
2 STATIONARY SOURCE AND REGULATED SUBSTANCE HANDLED 
 
The Northeast Station is located in northeast El Paso at the  
intersection of McCombs Road and Sean Haggerty Drive. The  
regulated substance handled at this facility is  
chlorine.  
The enclosed chlorination process room at this facility is  
located at the south end of the pump station. The  
chlorination process room houses two (2) one-ton pressurized  
liquid chlorine containers, gas dispensers, ejectors,  
residual analyzers, and a chlorine leak detector. The leak  
detection system is capable of alarming when the chlorine  
levels reach or exceed 3.0 parts per million(ppm). The  
audible and visual alarm system alerts personnel in case of  
a chlorine release. 
 
The level of concern or `toxic endpoint' for chlorine is 3.0  
ppm (40 CFR 68.22).  An accidental release of a regulated  
substance is considered to result in no adverse impact to  
public health at distances, from the point of release,  
extending beyond the toxic endpoint. 
 
3 WORST CASE RELEASE SCENARIO(S) AND ALTERNATIVE RELEASE  
SCENARIO(S) 
 
The RMP rule requires the EPWU-PSB to conduct offsite  
consequence analyses for two chlorine release scenarios,  
identified as `worst case release' and `altern 
ative release'  
scenarios. The worst case release scenario is defined by the  
RMP rule as `the release of the largest quantity of a  
regulated substance from a vessel or process line failure  
that results in the greatest distance to [the toxic]  
endpoint' (40 CFR 68.3). The alternative release scenario is  
defined as a release more likely to occur than the worst  
case scenario.   
 
The release scenarios were modeled using the air dispersion  
model Areal Locations of Hazardous Atmospheres (ALOHA). The  
worst case release scenario is the release of the entire  
contents of a one-ton container under the conditions  
prescribed by the RMP rule. The distance to the toxic  
endpoint for the worst case release scenario is 2.5 miles.  
The alternative release scenario is the release of chlorine  
from a pipe leak with a hole diameter of 1/8 inch. The  
distance to the toxic endpoint for the alternative release  
scenario is 150 yards (0.09 mi.). 
 
4 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHE 
MICAL  
SPECIFIC PREVENTION STEPS 
 
The EPWU-PSB accidental release prevention program is based  
on the following elements: 
 
(1) Preventive maintenance program; 
(2) Use of accurate and effective operating procedures; 
(3) Performance of a hazard review of equipment and  
procedures; and 
(4) Implementation of an auditing and inspection program. 
 
Chemical-specific prevention steps include availability of  
self-contained breathing apparatus (SCBA), worn by the  
operators during connection/disconnection of chlorine  
supply, awareness of the hazardous and toxic properties of  
chlorine, and presence of chlorine detectors. 
 
5 FIVE YEAR ACCIDENT HISTORY 
 
No accidental releases have occurred at the facility in the  
past five years (June 1994 - June 1999). 
 
6 EMERGENCY RESPONSE PROGRAM 
 
The Emergency Response Program for this facility is based  
upon the EPWU-PSB's `Emergency Response Action Plan' and the  
Chlorine Institute's `Emergency Response Plans for Chlorine  
Facilities.' The Emergency Respons 
e Program has been  
coordinated with the El Paso County Local Emergency Planning  
Committee (LEPC) and the El Paso Fire Department Hazardous  
Materials Division. This program is in compliance with the  
RMP Emergency Response Program requirements.  
 
7 PLANNED CHANGES TO IMPROVE SAFETY 
 
The EPWU-PSB plans to review and revise, as necessary, the  
chlorination process operating procedures in order to make  
certain that the operators understand the human factors that  
may lead to accidental releases.
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