Roberto R. Bustamante Wastewater Treatment Plant - Executive Summary |
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EXECUTIVE SUMMARY 1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The El Paso Water Utilities - Public Service Board (EPWU- PSB) has prepared this Risk Management Plan (RMP) for the chlorination process at the Roberto R. Bustamante Wastewater Treatment Plant, in compliance with 40 CFR 68. The main objectives of this RMP are to: (1) Communicate the extent of a possible chlorine release and identify possible receptors (Hazard Assessment), The Hazard Assessment communicates the possible extent of a worst case release and an alternative `more likely' release. The Hazard Assessment also identifies potential public and environmental receptors that may be affected in the event of a chlorine release. (2) Develop strategies to prevent an accidental release (Prevention Program), The goal of the Prevention Program is to integrate technologies, procedures, and management practices to minimize the probability of an accidental chlorine release. The Prevention P rogram incorporates safety information, hazard review, operating procedures, training, maintenance, compliance audits, and incident investigations. (3) Formulate contingency planning in the case of an accidental release (Emergency Response Program). The Emergency Response Program is modeled after the EPWU- PSB's `Emergency Response Action Plan' and the Chlorine Institute's `Emergency Response Plans for Chlorine Plans for Chlorine Facilities.' The Emergency Response Program incorporates an emergency response plan, emergency response equipment procedures, training in relevant procedures for employees involved in the chlorination process, and procedures to review and update, as appropriate, the emergency response plan to reflect changes and ensure that employees are informed of changes. 2 STATIONARY SOURCE AND REGULATED SUBSTANCE HANDLED The Roberto R. Bustamante Wastewater Treatment Plant is located in east El Paso on Southside Road approximately two miles east of Americ as Avenue. The regulated substance handled at this facility is chlorine. The chlorination process building at this plant is located near the entrance of the facility. The enclosed chlorination process building includes a chlorine container storage area and a chlorination process room. The chlorine storage area contains twenty-two (22) one-ton pressurized liquid chlorine containers, scales and manifolds, a monorail hoist system, and chlorine gas sensors and alarms. Typically, eleven (11) chlorine containers are used in the chlorination process at a time. The chlorination process room contains the chlorinators, injectors, pumps, residual analyzers, and the chlorine leak detectors. The leak detection system is capable of alarming when the chlorine levels reach or exceed 3.0 parts per million(ppm). The audible and visual alarm system alerts personnel in case of a chlorine release. The level of concern or `toxic endpoint' for chlorine is 3.0 ppm (40 CFR 68.22). An accident al release of a regulated substance is considered to result in no adverse impact to public health at distances, from the point of release, extending beyond the toxic endpoint. 3 WORST CASE RELEASE SCENARIO(S) AND ALTERNATIVE RELEASE SCENARIO(S) The RMP rule requires the EPWU-PSB to conduct offsite consequence analyses for two chlorine release scenarios, identified as `worst case release' and `alternative release' scenarios. The worst case release scenario is defined by the RMP rule as `the release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to [the toxic] endpoint' (40 CFR 68.3). The alternative release scenario is defined as a release more likely to occur than the worst case scenario. The release scenarios were modeled using the air dispersion model Areal Locations of Hazardous Atmospheres (ALOHA). The worst case release scenario is the release of the entire contents of a one-ton cont ainer under the conditions prescribed by the RMP rule. The distance to the toxic endpoint for the worst case release scenario is 2.5 miles. The alternative release scenario is the release of chlorine from a pipe leak with a hole diameter of 1/8 inch. The distance to the toxic endpoint for the alternative release scenario is 0.2 miles. 4 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS The EPWU-PSB accidental release prevention program is based on the following elements: (1) Preventive maintenance program; (2) Use of accurate and effective operating procedures; (3) Performance of a hazard review of equipment and procedures; and (4) Implementation of an auditing and inspection program. Chemical-specific prevention steps include availability of self-contained breathing apparatus (SCBA), worn by the operators during connection/disconnection of chlorine supply, awareness of the hazardous and toxic properties of chlorine, and presence of c hlorine detectors. 5 FIVE YEAR ACCIDENT HISTORY No accidental releases have occurred at the facility in the past five years (June 1994 - June 1999). 6 EMERGENCY RESPONSE PROGRAM The Emergency Response Program for this facility is based upon the EPWU-PSB's `Emergency Response Action Plan' and the Chlorine Institute's `Emergency Response Plans for Chlorine Facilities.' The Emergency Response Program has been coordinated with the El Paso County Local Emergency Planning Committee (LEPC) and the El Paso Fire Department Hazardous Materials Division. This program is in compliance with the RMP Emergency Response Program requirements. 7 PLANNED CHANGES TO IMPROVE SAFETY The EPWU-PSB plans to review and revise, as necessary, the chlorination process operating procedures in order to make certain that the operators understand the human factors that may lead to accidental releases. |