City of Edinburg Pump Station No. 1 - Executive Summary

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The City of Edinburg Raw Water Pump Station No.1 accidental release prevention policy involves a unified approach that integrates technologies, procedures, and management practices.  The Edinburg emergency response policy involves the preparation of a response plan that is tailored to each facility and to the emergency response services available in the community.  The policy adheres to EPA Prevention Program procedures where applicable, and is in compliance with EPA Emergency Response Program requirements. 
 
The City of Edinburg Raw Water Pump Station #1 is located at 2100 West Sprague Street, in Edinburg, Hidalgo County, Texas.  A one 1-ton chlorine container with a tank mounted vacuum regulator is on continuous operation, while another 1-ton chlorine container is used as a backup.  The chlorine containers are situated outside, have manual shutoff valves in case of an emergency, and a chlorine alarm will trigger if a release occurs.  Emergency air supply and power are available for em 
ergency situations.  The facility is checked by plant operators six times per shift or every four hours per day.  A Self-Contained Breathing Apparatus (SCBA) is stored in the West Tower located approximately 65 feet from the chlorine containers. 
 
The offsite consequence analysis for the Pump Station includes consideration of two different release scenarios for each of the parameters of concern (chlorine): 1) A "Worst Case Release"; and 2) an "Alternative Scenario".  The "Worst Case Release" is defined by EPA guidance which states that "the owner or operator shall assume that the ... maximum quantity in the largest vessel... is released as a gas over 10 minutes," due to an unspecified failure.  The Alternative Scenario is defined as "more likely to occur than the worst-case release scenario."  
 
Atmospheric dispersion modeling has to be performed to determine the distance traveled by a parameter of concern before its concentration decreases to the "toxic endpoint".  The toxic endpoints a 
re defined by the EPA as 0.0087 ppm for chlorine. This value corresponds to the Emergency Response Planning Guidelines Level 2 (ERPG-2) concentrations which are defined by the American Industrial Hygiene Association (AIHA) as: 
 
" The maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one-hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protection action."   
 
The estimated population potentially affected by the release is defined as the residential population within a circle with a radius corresponding to the toxic endpoint distance. 
 
The Worst Case Release Scenario at the Edinburg Pump Station was defined by the following conditions: 
 
Failure of 1 one-ton container resulting in the total release of 2,000 pounds of chlorine, respectively; 
 
Release of the entire amount as a gas in 10 minutes; 
Use of the one-hour average ERPG-2 as 
the toxic endpoint; 
 
Consideration of the population residing within a full circle with radius corresponding to the toxic endpoint distance; and 
 
EPA mandated meteorological conditions, specifically an F atmospheric stability class, wind speed of 1.5 m/sec, and air temperature of 77:F. 
 
Atmospheric dispersion modeling for the Worst Case Release scenario resulted in a chlorine toxic endpoint distance of 1.3 miles and an estimated residential population potentially affected of 3,379.  The calculations were performed with the RMPComp32 model as provided by USEPA and NOAA.  The affected population was estimated through Tiger and Landview III information. 
 
The Alternative Release Scenario at the Pump Station was defined by the following conditions: 
 
Failure of flexible connections (pigtails) connected to 1 one ton container resulting in the 
total release of 2000 pounds of chlorine (Pump Station); 
 
Release of the entire amount as a gas in 30 minutes; 
 
Use of the one-hour average ERPG-2 as t 
he toxic endpoint; 
 
Consideration of the population residing within a full circle with radius corresponding to the  
toxic endpoint distance; and 
 
EPA mandated meteorological conditions, specifically a D atmospheric stability class, wind  
speed of 3 m/sec, and an air temperature of 77:F. 
 
Atmospheric dispersion modeling for the Alternative Release scenario resulted in a chlorine toxic endpoint distance of 0.5 miles and an estimated residential population potentially affected of 234.  
 
In both cases, the calculations were performed with the RMPComp32 model as provided by USEPA and NOAA.  The affected population was estimated through Tiger and Landview III information. 
 
No mitigation measures were considered. 
 
The accidental release prevention program for the Edinburg Pump Station is based on the following key elements. 
 
High level of training of the operators; 
 
Preventive maintenance program; 
 
Use of state of the art process and safety equipment; 
 
Use of accurate and effective operating  
procedures, written with the participation of the 
operators;  
 
Performance of a hazard review of equipment and procedures; 
 
Implementation of an audit and inspection program.   
 
Chemical specific prevention steps include availability of self-contained-breathing-apparatus (SCBA) worn by the operator during connection/disconnection of each chemical supply, awareness of the hazardous and toxic properties of chlorine and the presence of a chemical  detector.  
 
No accidental releases of chlorine have occurred in the past five years.  
 
The facility has an emergency response program which has been coordinated (reviewed) by the City of Edinburg's Fire and Police Departments.  Both of these entities are members of the Hidalgo County Local Emergency Planning Committee (LEPC).  The program includes an emergency response decision tree and a notification plan.  Emergency response drills and drill evaluations, and emergency operation and response procedures are reviewed annually.
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