Jonathan W. Rogers Water Treatment Plant - Executive Summary
EXECUTIVE SUMMARY |
1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE
The El Paso Water Utilities - Public Service Board (EPWU-
PSB) has prepared this Risk Management Plan (RMP) for the
chlorination process at the Jonathan W. Rogers Water
Treatment Plant, 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
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 i
ncorporates safety information,
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 Jonathan W. Rogers Water Treatment Plant is located in
east El Paso on Southside Road approximately two miles east
of Americas Avenue. The r
egulated substance handled at this
facility is chlorine. The chlorination process building at
this plant is located at the east end of the facility. The
enclosed chlorination process building includes a chlorine
container storage area and a chlorination process room. The
chlorine storage area contains ten (10) one-ton pressurized
liquid chlorine containers, scales and manifolds, a monorail
hoist system, and chlorine gas sensors and alarms.
Typically, ten (10) chlorine containers are used in the
chlorination process at a time. The chlorination process
room contains the chlorinators, injectors, pumps, residual
analyzers, and the chlorine leak detectors. 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
ubstance 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
The RMP rule requires the EPWU-PSB to conduct offsite
consequence analyses for two chlorine release scenarios,
identified as `worst case release' and `alternative 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
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. Since the
facility is equipped with a scrubber with a capacity to
neutralize 25 tons of chlorine, the distance to the toxic
endpoint for the alternative release scenario is 0 miles.
4 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL
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
(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
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 Response 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.