South Parkway Water Treatment Plant - Executive Summary |
|
Accidental Release Prevention and Emergency Response Policies We at Huntsville Utilities are strongly committed to employee, public, and environmental safety and health. This commitment is inherent to a comprehensive accidental release prevention program that includes procedures for the operation, maintenance, emergency response, and employee training associated with the regulated process at this facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances and adhere to all applicable Federal and state rules and regulations. The Stationary Source and the Regulated Substances Handled The regulated substance present at Huntsville Utilities is chlorine. The maximum inventory of chlorine stored at Huntsville Utilities is 28,000 pounds. A maximum of 4,000 pounds will be involved in the process at any given time. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s) To evaluate the worst case and alternative rel ease scenarios associated with this process, we employed the RMP*Comp program and EPA's RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios as required by 40 CFR Part 68.1 - 68.33. The worst case release scenario submitted for Program 2 toxic substances involves a release from two one-ton cylinders at the facility. The scenario involves the release of 4,000 lbs. of chlorine instantaneously. Under worst case weather conditions, the distance to the endpoint is 3.0 miles from the Chlorine Storage Room. The alternative release scenario submitted for Program 2 toxic substances also involves a release of chlorine at the facility. The scenario involves the release of 2,000 lb. of chlorine over a ten-minute duration. Under neutral weather conditions, the maximum distance to the toxic endpoint of 1 psi overpressure is 0.60 miles. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps The Huntsvi lle Utilities facility is in compliance with EPAs Accident Release Prevention Rule set out under 40 CFR Part 68 and all applicable state codes and regulations. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Safety Information Huntsville Utilities maintains the applicable Material Safety Data Sheets related to this process. The facility also maintains detailed records of safety information that describes the chemical hazards, operating parameters, and equipment designs associated with this process. Hazard Review Huntsville Utilities conducts comprehensive reviews to ensure that the hazards associated with the process are identified and controlled efficiently. The studies are undertaken by qualified personnel who are experienced in engineering and process operations. The reviews are revalidated every year. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures In order to ensure safe operation of the covered process, Huntsville Utilities maintains written standard operating procedures. These procedures 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 is regularly reviewed and readily accessible to operators involved in the processes. Training Huntsville Utilities ensures that employees who are operating this process are competent in the operating procedures associated with this process. Refresher training is provided at least every three years and more frequently as needed. Maintenance Huntsville Utilities carries out maintenance checks to maintain the mechanical integrity of the process equipment. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, contr ols, and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Compliance Audits Huntsville Utilities conducts audits on a regular basis to determine whether the provisions set out under 40 CFR Part 68 are being implemented and reviewed. These audits are performed by qualified personnel and are carried out at least every 3 years. Any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. The most recent two audits are kept on-site. Incident Investigation Huntsville Utilities promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. Any investigation findings are resolved promptly and the corresponding resolutions or corrective measures are documented. All reports are retained for a minimum of 5 years. Five-year Accident History Huntsville Utilities has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, no accidental releases resulting in significant onsite or off-site impacts have occurred. Emergency Response Plan Huntsville Utilities has an Emergency Response Plan in place which dictates the procedures necessary to mitigate an accidental release of chlorine from the facility and protect human health and the environment. |