Link Street Plant - Executive Summary
EXECUTIVE SUMMARY |
City of Orange
Link Street Plant
1301 Link Street
Orange, TX 77630
Date:June 16, 1999
Compliance Officer: David Trahan
Phone Number: 409-988-7338
The following Executive Summary is provided in accordance with the requirements of Title 40 Code of Federal Regulations Part 68, Subpart G (40 CFR _ 68.155).
(a) Accidental release prevention and emergency response policies of the City of Orange Link Street Plant:
The City of Orange is committed to the protection of the health and safety of the general public, facility and response personnel, valuable environmentally sensitive areas, and business and commercial districts. Through on-the-job employee training, routine equipment testing, preventative maintenance, and coordination with the Fire and Police Departments, the City of Orange Water / Sewer Department has implemented all the elements of a Program 2 Federal Risk Management Plan (RMP) and is in full compliance with 40 CFR 68 - Chemical Accident Prevent
(b) The source and regulated substance handled:
This facility is a ground water production plant that treats water supplied by City of Orange water wells prior to storage and area-wide distribution for public consumption. The plant is completely automated and controlled remotely by a telemetry signal transmitted from the Turret Road Water Tower.
The plant has two treatment processes, Chlorination and Iron Sequestration. The iron sequestration process involves the addition of an iron sequestration agent to prevent a condition called "red water" that occurs when iron in the water oxidizes. Second, the ground water is treated with chlorine gas, which is added with a chlorine injection system. The chlorine gas is stored as a liquid in pressurized, one-ton cylinders. The plant is subject to the RMP because a maximum of 4,000 pounds of chlorine can be present at the site at any one time. The iron sequestration process does not involve chemicals that are subject to the
(c) The worst-case release scenario and the alternative release scenario:
The plant is located in the center of the City of Orange and has the potential to affect the densely populated metropolitan area. Several emergency situations involving the release of chlorine gas have been analyzed using EPA software (RMP*Comp) in order to review the aerial extent of chlorine gas that could impact surrounding populations and sensitive areas.
The worst-case release of chlorine gas would occur if one of the 1-ton pressurized chlorine cylinders was punctured, ruptured, or evacuated completely through a valve failure. EPA guidance for chlorine releases at water treatment facilities specifies that the entire contents of one 1-ton cylinder of chlorine gas are completely released over a period of 10 minutes (EPA CEPPO, Risk Management Program Guidance for Wastewater Treatment Plants, 11-98). In this scenario, a radius of 1.3 miles surrounding the facility would be exposed to
chlorine gas at concentration levels that meet or exceed the toxic endpoints.
Alternatively, a more plausible accidental release would be a failure of the compression fittings and a loss of vacuum in the chlorine feed lines. If the vacuum is lost, an automatic shut off system will stop the flow of chlorine, which will leave approximately one pound of chlorine in the piping. The chlorine in the piping would be released to the atmosphere within approximately one minute. The area that would most likely be exposed to chlorine gas at concentration levels that meet or exceed the toxic endpoints is expected to be less than 0.1 mile.
(d) The general accidental release prevention program:
Appropriate safety and precautionary measures, including cylinder handling and transport procedures as well as round the clock routine checks of cylinder connections and operational parameters, have been implemented at the site. Facility operators are trained to detect and repair any leaks or malfuncti
ons in the chlorine feed lines on their routine checks at the facility to minimize chlorine releases. Logs of inspections and repairs are kept to document the repairs and a chain of command has been established to ensure repairs are completed in a timely fashion. The preventative measures and response procedures have been implemented to ensure that potential hazards to the community and environment are as minimal as possible.
(e) The five-year accident history:
There have been no accidental releases or reportable incidents at the facility within the last five years.
(f) The emergency response program:
The Compliance Officer, the Manager, and the Chief Operator of the City of Orange Water/Sewer Department are responsible for the implementation of the risk management program as well as direction of facility employees and process maintenance. If an accidental release occurs, procedures for coordination with the City of Orange Fire Department have been established to quickly respon
d to and effectively limit exposure to surrounding areas. In the event of a release and depending on the response level, the Fire Department, the Police Department, or the Orange County Emergency Operating Center will initiate staff notification and public warning.
(g) Planned changes to improve safety:
Currently, a new employee-training program is being developed to increase the awareness of available documentation of the potential hazards associated with the handling and storage of chlorine. The City of Orange reviews and revises their community emergency response plan several times a year in order to remain current with federal, state, and local regulations.