Louisiana Water Company (Eunice) - Executive Summary |
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A. Louisiana Department of Environmental Quality Facility Identification Number #19478 LDEQ B. Accident release prevention and emergency response policies at the stationary source. Prevention Management System: LAWCO chlorine operations, maintenance, training and accident prevention follow guidelines established by the American Water Works Association (AWWA), more particularly, AWWA Manual 20, "Water Chlorination Principles and Practices, AWWA B301-59, "Standard for Liquid Chlorine", AWWA C601-81, "Forms of Chlorine for Disinfection". LAWCO chlorine operations equipment and processes follow guidelines established by the American Water Works Association, more particularly, AWWA Manual M20, "Chlorination Equipment" and those set forth by the manufacturers of such equipment. LAWCO chlorine operations follow guidelines set forth by the manufacturer's Material Safety Data Sheets (MSDS). LAWCO's annual hazard review identifies any and all hazards associated with the process, opport unities for equipment malfunctions or human error, safeguards needed to control the hazards or prevent equipment malfunction or human error, and any steps used or needed to detect or monitor releases. LAWCO's annual review of all operating procedures assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to stationary sources. LAWCO provides initial, thorough training for each new employee involved in operating a process that emphasizes specific safety and health hazards, emergency operations including shutdown, and safe working practices. Training program includes annual refresher training for all employees involved with activities in the chlorination process. LAWCO's maintenance program ensures mechanical integrity of process equipment. Our maintenance program procedures are in writing, training is provided for all employees involved in maintenance activities, and regularly sche duled inspections and testing is performed on process equipment. LAWCO's compliance audits ensure compliance with the provisions of the risk management plan. LAWCO conducts thorough incident investigations for any incident that resulted in, or could reasonably have resulted in a catastrophic release of chlorine. LAWCO continually monitors the Accident Prevention Management program for improvements in safety, hazard assessment, operating and maintenance procedures and training. Emergency Response Plan: LAWCO has a detailed written emergency response plan. The plan includes specific actions that should be taken in response to an accidental release of chlorine. The plan includes procedures for the following: Notification Procedures, First Aid Procedures for Exposure, Emergency Response Procedures After a Release, Procedures for Use of Equipment, Training for Employees in Procedures, Review and Update Plan, Emergency Response Plan Regulatory Agencies. C. The stationary source and regulated substance handled. Primary activity - drinking water treatment plant Use of regulated substance - chlorine used to disinfect drinking water Quantities handled or stored - maximum of two (2) one-ton cylinders or 4,000 pounds, usually no more than 3,000 pounds at any given time. D. The worst-case scenario and alternative release scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario. Worst-case scenario - Failure of the one ton cylinder containing 2,000 pounds of chlorine, 200 pounds/minute release rate, for a period of ten minutes. Under the worst-case weather, the substance could travel 1.3 miles before dispersing enough to no longer pose a hazard to the public. Alternative release scenario - A leak in a one ton cylinder of approximately 15 pounds of chlorine, .25 pounds/minute release rate, for a period of sixty minutes before repairs are completed. Under the worst-case weather, the substance could t ravel .1 miles before dispersing enough to no longer pose a hazard to the public. E. The general accidental release prevention program and chemical-specific prevention steps. LAWCO is in compliance with AWWA Manual M20, "Water Chlorination Principles and Practices" which outlines specific procedures in Shipping Containers for Chlorine Compressed Gases, Handling Shipping Containers, Storing Shipping Containers, Emptying Containers, Connecting and Disconnecting Containers, Engineering Controls of Hazards, Finding Gas Leaks, Handling Emergencies, Personnel Protective Equipment, Personnel Training, Special Care and use of Hypochlorites. LAWCO is in compliance with AWWA B301-59, "Liquid Chlorine Standard", which defines liquid chlorine and explains characteristics of liquid chlorine, shipping requirements for liquid chlorine and inspection requirements for liquid chlorine containers. F. The five-year accident history. Louisiana Water Company has not had any accidents involving any chlorine releases at this facility over the past five years, and in fact, since we purchased and assumed responsibility of operations and maintenance at the Eunice plant in February of 1983, there have been no reportable releases or accidents involving chlorine at the facility. G. The emergency response program. LAWCO has a detailed written emergency response plan. Our plan includes specific actions that should be taken in response to an accidental release of a regulated substance. The plan includes procedures for public information, notification to agencies responsible for responding to accidental releases, notification to agencies requiring such notice, information on emergency health care, emergency response after a release, use of equipment, training requirements and annual reviews and updates. |