Coastal Water Authority (Red Bluff Plant) - Executive Summary |
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Coastal Water Authority Red Bluff Water Treatment Plant RISK MANAGEMENT PROGRAM PLAN Executive Summary Accidental Release Prevention and Emergency Response Policies The accidental release prevention and emergency response policies at Coastal Water Authority's Red Bluff facility are engrained in the fundamentals of our prevention program. At our Red Bluff water treatment facility, we presently handle one chemical, which is considered hazardous by the Environmental Protection Agency (EPA). The same properties that make this chemical valuable for making drinking water safe also make it necessary to observe specific safety precautions. These safety precautions are exercised in the operation and maintenance of our chlorination system to control human and environmental exposure in an effort to reduce the overall threat to our workers as well as the surrounding communities. It is Coastal Water Authority's policy to adhere to all applicable federal, state and local rules and regulat ions. However, the safe handling of hazardous chemicals is paramount at CWA and we often exceed standards and recommended practices governing the safe handling of hazardous chemicals to ensure that we have obtained a reasonable level of risk reduction We believe that accountability for safety reaches throughout all levels of management at CWA. Senior management's commitment and dedication to continued safe-operating practices is clearly evident in our organization structure and employee empowerment. Facility Description and regulated substances handled The Red Bluff plant site covers approximately 4 acres within the Pasadena City limits. It is located at 120 North Red Bluff, Pasadena, Texas in Harris County. Our facility treats approximately 3,000,000 gallons of water per day. There is a maximum of six (6) full-time employees at the plant site at any one time. We presently handle only one chemical, which is considered hazardous by the EPA. This substance is present in qua ntities greater than the threshold quantity identified by the RMP regulation and therefore is included in our risk management program. X Chlorine - Chlorine is used to as a water treatment chemical at the plant. It is received into the plant in one ton containers. These containers are standard DOT and Chlorine Institute specified containers. Deliveries of chlorine are received at the plant every three (3) months. The plant has a maximum inventory of 8,000 pounds of chlorine onsite, however, only one container (2,000 pounds) is being used at any one time. Offsite Consequence Analysis (worst-case & alternate-cases) The RMP rule requirements for identification and selection of a worst-case hazard scenario are prescriptive. These requirements negate most safety systems designed to mitigate an incidental release that would typically be used in the event that an incident occurred. Based on EPA defined Offsite Consequence Analysis (OCA) Guidance, CWA has one worst-case hazard sce nario for the toxic material handled onsite. This scenario is estimated to create the greatest distance in any direction to an EPA defined concentration (endpoint) resulting from an accidental release. Our worst-case toxic scenario involves chlorine. Chlorine is used as a water treatment chemical at the plant. It is stored under its own vapor pressure in standard one ton containers located under a protective open-sided shed. The scenario uses the EPA's theoretical assumption that a container may catastrophically fail and release chlorine to the atmosphere. It completely negates any mitigation attempts and assumes that all 2,000 pounds of chlorine can be dispersed within 10 minutes to form a toxic vapor cloud that drifts offsite into the surrounding community. Using the EPA's Offsite Consequence Analysis Guidance Document, dated October 1998, to determine the greatest downwind distance, it was determined that a chlorine vapor cloud may extend 1.30 miles from the plant. This calcul ation was based on the EPA recommended guide for chlorine. The EPA rule also requires that alternate or more likely accident scenarios involving regulated chemicals be identified. Other more likely chlorine incidents were assessed at CWA, using parameters prescribed in the RMP regulation. The analysis of the alternate scenarios could include mitigation affects from both passive and active safety systems. CWA conducted an iterative assessment of several alternate or more likely scenarios. From the various scenarios assessed, CWA selected the following as a representative example of an alternative scenario: X Inadvertent mishandling of a chlorine shipping container during delivery results in complete separation of the container's valve. This failure assumes that 251 pounds per minute of chlorine is released. Dispersion of the chlorine gas could result in the formation of a vapor cloud extending 0.27 miles (1,426 feet) from the plant. Accidental release program & chemical-spec ific prevention steps Coastal Water Authority contracted with an outside engineering firm to assist in the development of a prevention program tailored exclusively to water treatment operations. This prevention program was designed around mechanical integrity and training aspects. The primary objective being to ensure complete containment of chlorine through safe operation and maintenance of the chlorination system. Although newly developed, the prevention program has been designed with the following objectives: X Enhancement of the mechanical integrity of all chlorine equipment and piping, X Compilation of safety information to improve hazard awareness, and X Training to increase hazard recognition Five year accident history CWA has a very comprehensive Incident Reporting and Investigation procedural process. This process is defined and explained by CWA-008. Basically, an incident occurs when a deviation from expected performance is experienced. Formal investigations are required to be conducted by appointed teams knowledgeable in operations or equipment being investigated. Root cause and corrective actions are also required in order to determine incident prevention steps. Progress regarding corrective action on all investigated incidents is required to be tracked through to completion. Coastal Water Authority's Red Bluff plant has not had an accidental release of EPA regulated chemicals within the past five years that resulted in an onsite injury or affected the community adversely. Emergency response program At CWA we handle one regulated toxic substance (chlorine) over threshold quantities. We have made a concise decision to not respond to catastrophic releases of chlorine at the Red Bluff plant. Our employees have been instructed to notify the Pasadena Fire Department and LEPC and to evacuate in the event of such an incident. In accordance with the requirements of the Risk Management Program rule, CWA is included in the Pasadena, Texas l ocal emergency response plan under the Emergency Planning and Community Right-to-Know Act (EPCRA). Planned improvements to reduce risk Investigation of inherently safer technologies presented by the Chlorine Institute, chlorine inventory reduction studies, and fail safe design applications are a few of the continuous improvements occurring at CWA. Safety depends upon our management commitment, the manner in which we handle chlorine, the safety devices inherent to our chlorination system, our operating procedures and philosophies, and the training of our employees.Coastal Water Authority Red Bluff Water Treatment Plant |