S Pump Station - Executive Summary

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Facility Description 
The S Pump Station is located near Bastrop, Texas. The facility is owned and operated by the Aqua Water Supply Corporation.  This facility produces ground water for distribution to residential and commercial customers.  Chlorine is used at the facility to disinfect the ground water prior to storage and distribution.  Currently, a maximum of 4,000 pounds of chlorine is maintained on the site.  No other toxic or flammable substances, as listed in 40 CFR 68, are store or utilized at the facility.  Chlorine is stored under pressure in one-ton containers. 
Safety Policies 
The Aqua Water Supply Corporation is fully committed to safety at the S Pump Station.  As a result of the risk management rules, Aqua is working to coordinate with the Bastrop Fire Department to establish a viable emergency response procedure.  The Bastrop Fire Department is capable of responding to accidental releases of chlorine or anhydrous ammonia, should a release occur.  Aqua Water Supply Corpora 
tion is committed to a process of continual improvement in its risk management program at the S Pump Station.  
Five Year Accident History 
The commitment to managing risks associated with chlorine is demonstrated by the excellent track record at the S Pump Station with respect to chlorine handling.  The S Pump Station has not experienced an accident related to chlorine within the past five years.  
Offsite Consequence Analysis 
As required by the risk management regulations, the offsite consequence analysis required development of worst-case release and alternative-release scenarios for chlorine.  Realistic potential alternatives were modeled, with consideration toward actual conditions at the site.  The resulting radii of impact are therefore useful tools for emergency response teams in planning for and responding to emergency situations.  
Prevention Program Description 
The prevention program represents the core of the day-to-day means by which accidental releases of regulated substan 
ces into the air will be minimized.  This component will be used primarily by plant personnel responsible for the operation and maintenance of regulated processes at the facility.  The prevention program will also become a useful tool in ongoing training of plant personnel.  
The Program 3 Prevention Program includes twelve primary components: 
7 Process Safety Information: Up-to-date safety information has been compiled relating to regulated substances, processes, and equipment. Safety information will also be updated any time a major change occurs that would make the safety information inaccurate. 
7 Process Hazard Analysis: Regulated processes at the facility have been reviewed to identify potential hazards.  The results have been documented in a hazard review report.  Problems identified by the hazard analysis are being resolved in a timely manner.   
7 Operating Procedures: Written operating procedures have been prepared providing instructions for safely conducting activities asso 
ciated with regulated processes.  These procedures will also be updated should a major change in the handling or storage of regulated substances occur. 
7 Training:  Plant personnel responsible for operating regulated processes receive training in the processes.  Periodic refresher training is required. 
7 Mechanical Integrity:  Procedures have been implemented to ensure that the mechanical integrity of the process equipment is maintained.  Ongoing training of personnel responsible for maintenance is also required.  Inspection and testing of regulated process equipment is a requirement as well. 
7 Management of Change: Procedures have been implemented to manage changes to the chlorine process in order to ensure that employees are aware of the changes and have been trained in the modified system. 
7 Pre-Startup Review: Procedures have been implemented to perform an audit of modified chlorine processes to ensure that appropriate modifications to the RMProgram have been made as a result o 
f the process change. 
7 Compliance Audits: The prevention program will be audited at least once every three years to evaluate compliance with the risk management rules.  The results of the audit will be documented, and deficiencies corrected. 
7 Incident Investigation: Should an incident involving a release, or near release, of a regulated substance occur, it will be investigated promptly.  The findings of any such incident investigation will be used to improve the safety of the process. 
7 Employee Participation:  The prevention program has been designed to incorporate the knowledge and experience of the employees by providing for their participation in RMProgram reviews, investigations of incidents, audits of the program, training, and other important aspects of the RMProgram. 
7 Hot Work Permits:  The maintenance procedures include provisions for hot-work permits to reduce hazards that could be caused by performing such work near chlorine processes. 
7 Contractors: Procedures have  
been implemented that clearly identify the risk management responsibilities of contractors who perform chlorine related work on the facility site. 
Emergency Response Program 
The Aqua Water Supply Corporation has determined that the S Pump Station will assume a non-responder status with respect to accidental releases of chlorine or anhydrous ammonia.  The Bastrop Fire Department will instead be the appropriate local emergency response agency in such cases.  The Bastrop Fire Department has the necessary training to respond to chlorine and anhydrous ammonia leaks.   Aqua Water Supply Corporation has coordinated with the Fire Department to ensure that the facility is included in the community emergency response plan regarding response to a potential release. 
Even though the S Pump Station will be a non-responding facility, its employees still have a significant role in the event of a release of chlorine or anhydrous ammonia.  Should a release occur or be suspected when employees are at t 
he facility, employees responsible for working with chlorine and anhydrous ammonia will follow procedures for assessing the situation and attempting to safely stop the release using normal shutdown procedures.  Facility personnel will receive ongoing training in identification of potential releases, and in how to determine when emergency response personnel should be involved. 
Aqua Water Supply Corporation will continue to work closely with the Bastrop Fire Department to ensure that emergency response, should it become necessary, is efficiently and safely carried out.  Coordination may include: 
7 periodic meetings between operators and Fire Department emergency responders to discuss emergency response measures 
7 periodic inspections of the facility by Fire Department emergency responders to ensure their familiarity with routes to the facility, ingress and egress routes at the facility, and layout of the chlorine and anhydrous ammonia process areas 
7 periodic practice drills utilizin 
g both Aqua and Fire Department personnel. 
Employees responsible for working with chlorine will receive periodic training, as detailed in the Procedures Manual of the RMProgram. 
Improving Safety 
Aqua Water Supply Corporation will continue to improve its risk management program for the S Pump Station by responding to the recommended changes outlined in the Hazard Review, by ongoing training of personnel, and by continued coordination with emergency response officials.  As the S Pump Station grows to meet the growing demands of the Aqua's service area, future plant expansions will consider further improvements in the chlorination process to manage risks associated with this regulated substance.
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