Carson County Pump Station - Executive Summary |
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EXECUTIVE SUMMARY CARSON COUNTY PUMP STATION General Facility Information The Carson County Pump Station, located approximately 20 miles northeast of downtown Amarillo in southwestern Carson County, is a City of Amarillo groundwater pumping station having a present pumping capacity of approximately 45 million gallons of water per day (mgd). The water is disinfected with chlorine gas (Cl2) as it is discharged into the transmission pipeline which carries it to selected out-of-city industries and into the City of Amarillo water treatment plant. A maximum of two city employees work at the pump station during normal business hours. The pump station is secured after business hours. A maximum of three one ton containers of chlorine gas are stored onsite, with all three one ton containers being connected to the header at any one time and one in use. Ongoing safety training programs cover all phases of plant operation from maintenance and operations safety to safe handling of chlorine. The Carson County facility also conducts formal training as well as onsite training during normal daily operations. Due to this safety training, this plant has had only one minor incident with no significant consequences in the last five years. Hazard Assessment Information 40 CFR Part 68, Subpart B - Hazard Assessment, outlines a specific set of criteria required to be used in the modeling of worst case and most probable case release scenarios. Worst case and most probable case scenario modeling was completed using Areal Locations of Hazardous Atmospheres (ALOHA) software. To complete most probable case and worst case scenario plume models, the default level of concern for chlorine was set at levels established in EPA and American Industrial Hygiene Association guidance. The resulting plume indicates a level where individuals would be able to take protective actions without suffering any serious health effects from a chemical exposure during a one hour or less period. Most prob able case and worst case scenario plume analysis results are conservative estimates based on the ALOHA software, using RMP release and meteorological requirements. Prevention Program Information The written Prevention Plan for the Osage Water Treatment Plant comprehensively deals with requirements of 40 CFR, part 68, sections 68.50 through 68.60. Safety data has been accumulated and made available to employees. The training program has been developed, operations and maintenance SOP's are written and have been implemented. The hazard review has been performed and suggestions resulting from it are being implemented. The compliance audit, which will be an internal audit, is in written procedural form; ready to be utilized and incident investigation forms are in place. All of the above elements of the Program 2 Prevention Program are kept in a unified binder format. Continuing requirements of the program will be carried out on the schedules required by the Risk Management Program R ule. Emergency Response Information A controlled release of chlorine product located on the pump station site shall be defined as the escape of gas to the atmosphere in small, non-reportable quantities, resulting from standard operating procedures to connect or disconnect chlorine containers and standard maintenance procedures on the pump station chlorine delivery system. Minor leaks in the system that can be promptly repaired or shut-off shall also be considered a controlled release. An uncontrolled release of chlorine which will require the implementation of emergency response procedures is defined as any release other than those examples defined as similar to controlled releases. Emergency responses to the pump station will be made by the Amarillo Fire Department, in accordance with the facility's emergency response plan and Carson County's Annex Q. If uncontrolled release conditions warrant such actions, shelter-in-place, evacuation and public warning will be implemented by em ergency management officials. Any uncontrolled release of chlorine shall be subject to an after action incident investigation by the City of Amarillo, exclusive of State and Federal agency regulatory review and oversight. |