Port Isabel Water Treatment Plant - Executive Summary

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           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.
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