City of Edinburg Dechlorination Injection Station - Executive Summary |
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EXCUTIVE SUMMARY The City of Edinburg Declorination Injection Station 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 Declorination Injection Station is located at 516 So. Raul Longoria, in Edinburg, Hidalgo County, Texas. The dechlorination building at the injection station consists of a three walled canopy structure facing west. Six 1-ton cylinders of sulfur dioxide are stored at the facility. Only two 1-ton containers are connected to the system at one time. These are located inside the walled canopy structure. One 1-ton cylinder is operationa l and the other one is used as backup. The sulfur dioxide containers have manual shutoff valves in case of an emergency and a alarm will be triggered if a release occurs. Emergency air supply and power are available. The facility is unmanned however, operators check the dechlorination station twice per shift. Self-Contained- Breathing-Apparatus (SCBA) is stored in the control room. The offsite consequence analysis for the Dechlorination Injection Station includes consideration of two different release scenarios for each of the parameters of concern (sulfur dioxide): 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 m odeling has to be performed to determine the distance traveled by a parameter of concern before its concentration decreases to the "toxic endpoint". The toxic endpoint for sulfur dioxide is 0.0078 mg/l. These values correspond 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 Dechlorination Injection Station was defined by the following conditions: Failure of 2 one-ton contai ners resulting in the total release of 4,000 pounds of sulfur dioxide, 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 sulfur dioxide toxic endpoint distance of 1.3 miles and an estimated residential population potentially affected of 6,716, the calculations were performed with the CAMEO and RMPComp32 models as provided by USEPA and NOAA. The affected population was estimated through Tiger and Landview III information. The Alternative Release Scenario at the Dechlorination Injection Station was defined by the following conditions: Failure of flexible connection s (pigtails) connected to 2 one-ton containers resulting in the total release of 4,000 pounds of sulfur dioxide, respectively; Release of the entire amount as a gas in 30 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 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 sulfur dioxide toxic endpoint distance of 0.4 miles and an estimated residential population potentially affected of 465. In both cases, the calculations were performed with the CAMEO and RMPComp32 models as provided by USEPA and NOAA. The affected population was estimated through Tiger and Landview III information. The accidental release prevention program for the Dechlorination Injection Station is bas ed 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 the chemical supply, awareness of the hazardous and toxic properties of sulfur dioxide and the presence of a chemical detector. No accidental releases of sulfur dioxide 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). T he 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. |