Soldier Canyon Filter Plant - Executive Summary |
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Executive Summary 1. Accidental release prevention and Emergency Response policies We at Soldier Canyon Filter Plant are committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also completely coordinated with Poudre Valley Fire Authority which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled We have 1 regulated substance present at our facility which is Chlorine. The maximum inventory of Chlorine at our facility is 120 00 lbs. 3. The Worst Case Release Scenario and the Alternative Release Scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario To perform the required offsite consequence analysis for our facility, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. Toxic Worst-Case Analysis The Worst Case scenario involves a catastrophic release from the Chlorine room. The scenario involves the release of 2000 lb. of Chlorine in a gaseous form over 10 minutes. The Release rate (lbs/min) is calculated to be 200. A distance to endpoint of 5.4 miles is obtained which affects a residential population of 21078 within this distance. Toxic Alternative-Case Analysis The Alternative Case scenario involves a release from the Chlorine room. The scenario involves the release of 16.2 lb. of Chlorine in a gaseous form over 60 minutes. The Release rate (lbs/min) is calculated to be 0.27; this is the usual flowrate through the piping. A distance to endpoint of 0.07 miles is obtained which affects a residential population of approximately 3. Flammables Worst-Case Analysis None applicable Flammables Alternative-Case Analysis None applicable 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Soldier Canyon Filter Plant maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts co mprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is What-If/Checklist. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated periodically. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Soldier Canyon Filter Plant maintains written 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 is readily accessible to operators involved in the processes. Training Soldier Canyon Filter Plant has a comprehensive training program in place to e nsure that employees who are operating processes are competent in the operating procedures associated with these processes. New employees receive basic on-the-job training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided periodically and more frequently as needed. Mechanical Integrity Soldier Canyon Filter Plant carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely ma nner. Compliance Audits Soldier Canyon Filter Plant conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Soldier Canyon Filter Plant 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. All reports are retained for a minimum of 5 years. Employee Participation Soldier Canyon Filter Plant truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. 5. Five-year Accident History Soldier Canyon Filter Plant has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Soldier Canyon Filter Plant has its own written ER Plan. The ER Plan includes specific actions to be taken in response to accidental releases of Chlorine. The ER Plan includes procedures for informing the public and local agencies for responding to accidental release. Date of most recent review/update of ER Plan: 5/5/99 Date of most recent ER training of employees: The Local agency coordinating ER Plan is Poudre Valley Fire Authority which has the phone number 970-221-6 581 7. Planned Changes to Improve Safety One development has resulted from the implementation of the various elements of our accidental release prevention program. Implementing additional Chlorine detection alarms is one step we want to take to improve safety at our facility. These changes are expected to be implemented by 12/31/1999. |