CITY OF SULPHUR REGIONAL WASTEWATER FACILITY - Executive Summary |
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General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 1. Accidental Release Prevention and Emergency Response Policies We at CITY OF SULPHUR REGIONAL WASTEWATER FACILITY are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, 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. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass TREATMENT OF WASTEWATER FROM THE CITES OF SULPHUR AND WESTLAKE AND THE COMMUNITY OF MOSSVILLE, CALCASIEU PARISH LOUISIANA. CONDUCT ROUTINE LAB. TESTS AS REQUIRED BY EPA PERMIT. . We have 2 regulated substances present at our facility. These substances include Chlorin e and Sulfur dioxide (anhydrous). Chlorine is used for DISINFECTANT FOR REMOVAL OF EXCESS BACTERIA. Sulfur dioxide (anhydrous) is used for REMOVAL OF CHLORINE FROM WASTEWATER BEFORE DISCHARGE INTO OUTFALL.. The maximum inventory of Chlorine at our facility is 4000.00 lb. while Sulfur dioxide (anhydrous) is present at our facility in a maximum quantity of 4000.00 lb.. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), 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 EPA's OCA Guidance Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from CHLORINE TREATMENT. In this scenario 2000 lb. of Chlorine is released. The toxic liquid released is assu med to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. The released quantity has been limited to 30% of the maximum capacity of the source by a system of administrative controls. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 5.4 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. The alternative release scenario for Chlorine involves a release from CHLORINE TREATMENT. The scenario involves the release of 800 lb. of chlorine. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 30 minutes. Passive mitigation controls such as OPEN PAVILION are taken into account to calculate the scenario, having the effect of a minimum gas leak due to the installation of a dual point gas monitor and a dual emergency shut-off system. The release is also assumed to be controlled by emergency shutdown system(s). These active mitigation systems have the effect of a minimum gas leak due to the installation of the abive mentioned equipment.. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.58 miles. 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. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition TEN STATES STANDARD. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information CITY OF SULPHUR REGIONAL WASTEWATER FACILITY 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 comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is testing and inspection of all equipment related to chemical injection . The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of once every twelve months. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 01/25/1999. Operating Procedures For the purposes of safely conducting activities within our covered processes, CITY OF SULPHUR REGIONAL WASTEWATER FACILITY 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 CITY OF SULPHUR REGIONAL WASTEWATER FACILITY has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least once a year and more frequently as needed. Mechanical Integrity CITY OF SULPHUR REGIONAL WASTEWATER FACILITY 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 defic iencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at CITY OF SULPHUR REGIONAL WASTEWATER FACILITY to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 01/11/1999. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at CITY OF SULPHUR REGIONAL WASTEWATER FACILITY. The most recent review was performed on 01/15/99. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operati on. Compliance Audits CITY OF SULPHUR REGIONAL WASTEWATER FACILITY conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on 01/15/99. 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 CITY OF SULPHUR REGIONAL WASTEWATER FACILITY 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 CITY OF SULPHUR REGIONAL WASTEWATER FACILITY truly believes that process safety management and accident prevention is a team effort. Company employe es 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. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. CITY OF SULPHUR REGIONAL WASTEWATER FACILITY has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History CITY OF SULPHUR REGIONAL WASTEWATER FACILITY has had an excellent record of preventing accidental releases o ver the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan CITY OF SULPHUR REGIONAL WASTEWATER FACILITY carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. CALCASIEU PARISH, LA. LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several devel opments and findings have resulted from the implementation of the various elements of our accidental release prevention program. are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by 09/15/99. |