Port Isabel Water Treatment Plant - Executive Summary |
|
Port Isabel Water Treatment Facility General Executive Summary 1. Accidental Release Prevention and Emergency Response Policies We at Port Isabel Water Treatment Plant 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 surface water treatment. We have one (1) regulated substance present at our facility. This substance includes Chlorine. Chlorine is used for Disinfection. The maximum inventory of chlorine at this facility is 8000.00 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 this 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 toxic substances as a class involves a catastrophic release from the chlorine room. In this scenario 2000 lbs of chlorine are released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. 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 the chlorine room. The scenario involves the release of 2000 lbs of chlorine through a leak in a corroded plug valve. The entire amount is estimated to have been released after 120 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.30 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps This 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 TNRCC Chapter 290 - Rules and Regulations for Public Water Systems. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Port Isabel Water Treatment Plant maintains a detailed record of safety infor mation that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Operating Procedures For the purposes of safely conducting activities within our covered processes, Port Isabel Water Treatment Plant 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 Port Isabel Water Treatment Plant 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 every year and more frequently as needed. Maintenance Port Isabel Water Treatment Plant 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. Compliance Audits Port Isabel Water Treatment Plant conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted on 04/26/1999. 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 Port Isabel Water Treatment Plant 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. 5. Five-year Accident History Port Isabel Water Treatment Plant 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 Port Isabel Water Treatment Plant employees will not respond to releases of regulated substances. This facility is included in the community emergency response plan. This facility carries a written emergency response action plan to minimize the duration and effects of an accidental release of hazardous materials. The employees will take actions only on incidental responses such as small chlorine leaks. Our employees are aware of the limits of an incidental response and have been trained on the proper steps to follow for emergency notification and employee evacuation procedures in case of a release of a regulated substance. Appropriate procedures are in place to notify emergency responders such as the Local Fire Department who will then notify the Cameron County LEPC. The Fire Department Emergency Response Plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public. 7. Planned Changes to Improve Safety A finding that resulted from the implementation of the various elements of our accidental release prevention program was an upgrade to the chlorination system which will include an interface between the chlorine detector and the SCADA System which will immediately notify personnel of a possible chlorine leak. These changes are expected to be implemented by June 14, 2000. |