Holly Hill Water & Wastewater Treatment 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 Holly Hill Water & Wastewater Treatment 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 Processing of Water and Wastewater Treatment.  We have 3 regulated substances present at our facility.  These substances include Chlorine, Ammonia and Sulfur dioxide.  Chlorine is used for disinfection.  Ammonia is used for combating trihalomethanes(THM).  Sulfur dioxid 
e is used for dechlorination.                                         . 
 
The maximum inventory of Chlorine that is expected to be present in this facility based on process/operational  requirements is 16000.00 lb. while Ammonia  and Sulfur dioxide are expected to be present at our facility in quantities of 7000.00 lb. and 6000.00 lb. respectively. 
 
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 Water Treatment.  In this scenario 2000 lb. of Chlorine is released.  The toxic liquid released is assumed to form a 1 cm deep po 
ol from which evaporation takes place.  The entire pool is estimated to evaporate over 10 minutes.  The released quantity has been limited to  20% 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 Sulfur dioxide involves a release from Wastewater Treatment.  The scenario involves the release of 500 lb. of  
Sulfur Dioxide .  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 10 minutes.  The release is also assumed to be controlled by water curtain(s), neutralization and emergency shutdown system(s).  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0078 mg/L of Sulfur dioxide (anhydrous) is 0.81 miles. 
 
The alternative release scenario  
for Chlorine involves a release from Wastewater Treatment.  The scenario involves the release of 200 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 10 minutes.  The release is also assumed to be controlled by water curtain(s), neutralization and emergency shutdown system(s).  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.62 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, 1998 Edition.    The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. 
 
Pr 
ocess Safety Information 
Holly Hill Water & Wastewater Treatment 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 the "What If" questions & analysis.  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 onece per year.  Any findings related to the hazard analysis are addressed in a timely manner.  The most recent PHA/update was performed on 05/21/1999. 
 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, Holly Hill Water & Wastewater Treatment Facility maintains written operating procedures.  These pro 
cedures 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 
Holly Hill Water & Wastewater Treatment 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 annually, once a year, and more frequently as needed based on new equipment, new employees or any other changes in the operation. 
 
Mechanical Integrity 
Holly Hill Water & Wastewater Treatment 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 deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
 
Management of Change 
Written procedures are in place at Holly Hill Water & Wastewater Treatment Facility to manage changes in process chemicals, technology, equipment and procedures.  The most recent review/revision of maintenance procedures was performed on 05/21/1999.  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 Holly Hill Water & Wastewater Treatment Facility.  The most recent review was performed on05/21/99.  These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. 
 
Compliance Audits 
Holly Hill Water & Wastewater Treatment 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 05/21/1999.  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 
Holly Hill Water & Wastewater Treatment 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 
Holly Hill Water & Wastewater Treatment Facility 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. 
 
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.  Holly Hill Water & Wastewater Treatment Facility has a strict policy of informing the contractors of known potential hazards related the contractor's wor 
k 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 
Holly Hill Water & Wastewater Treatment Facility 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 
Holly Hill Water & Wastewater Treatment 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 r 
eflect any pertinent changes taking place within our processes that would require a modified emergency response. 
 
LEPC #6 is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 
 
7.    Planned Changes to Improve Safety 
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Improved training and increase details the equipment maintenance are some of the major steps we want to take to improve safety at our facility.  These changes are expected to be implemented by 08/01/99.
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