Wilkesboro Water Treatment Plant - Executive Summary

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The accidental release prevention and emergency response policies at your facility: 
This facility handles chlorine, which is considered to be a regulated toxic substance by EPA.  We observe all necessary safety precautions in handling chlorine to prevent unnecessary human exposure, to reduce the threat to our own personal health and to reduce the threat to nearby members of the community.  It is our policy to adhere to all applicable federal, state and local rules and regulations.  Safety depends upon the manner in which we handle chlorine, the safety devices inherent to the design of this facility, the safe handling procedures that we use and the training of our personnel.  This facility is subject to Program 3 of the Risk Management Program because it is also subject to OSHA's Process Safety Management regulations.   If an emergency were to occur, it is our policy to notify the local emergency response agency. 
A description of your facility and the regulated subs 
tances handled: 
The primary purpose of this facility is water treatment.  We receive chlorine in 1-ton cylinders.  These cylinders inject chlorine into to the water for disinfection purposes.  Access to the process is restricted to authorized employees and contractors.  The maximum amount of chlorine that can be stored at this facility is 10,000 pounds (5 cylinders).  
The worst case and alternative release scenarios: 
The worst-case release scenario for chlorine is failure of a 1-ton chlorine cylinder when filled to its maximum allowable capacity.  The distance to the endpoint of 0.0087 mg/l is 0.9 miles, based on the results of RMP Comp, EPA's consequence analysis software.  This distance extends beyond the facility boundary and there are estimated to be 520 residents, schools, recreation areas, businesses, churches and a daycare within the distance to endpoint. 
The alternative release scenario for chlorine is failure of a pipe or hose.  Five-hundred pounds of chlorine are released 
over a period of ten minutes.  The distance to the endpoint of 0.0087 mg/l is 0.1 miles, based on the results of RMP Comp, EPA's consequence analysis software.  This distance extends beyond the facility boundary and there are estimated to be 30 residents, businesses and a daycare within the distance to endpoint. 
The general accidental release prevention program and chemical-specific prevention steps: 
This facility complies with EPA's accident prevention rule and all applicable state and local codes and regulations.  The chlorine system is designed, installed, and maintained in accordance with industry standards. 
Process Safety Information 
We maintain safety information that describes the chemical hazards, operating parameters and equipment designs associated with our chlorine storage facilities. 
Process Hazard Analysis 
We conduct reviews to ensure that hazards associated with our processes are identified and controlled efficiently. These activities are undertaken by a team of qua 
lified personnel with expertise in process operations and are revalidated at a regular interval.  Any findings related to the hazard analysis are addressed in a timely manner. 
Operating Procedures 
We maintain written operating procedures for operation of the chlorine facility.  These procedures address various modes of operation including initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround.  The information is readily accessible to operators. 
We have 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 three years. 
Mechanical Integrity 
We perform annual maintenance inspections on process equipment to ensure proper operations.  Basic visual inspections are performed by facility operators on a more frequent basis.  Proces 
s equipment examined by these checks includes: pressure vessels, storage tanks, piping systems, relief and vent systems.  Maintenance operations are performed by qualified personnel that have been trained in safe maintenance practices.  Any equipment deficiencies are corrected in a safe and timely manner. 
Management of Change 
Whenever a change in process occurs, our management of change procedures ensure that we evaluate the impact on health and safety, modify the operating procedures and safety information as necessary, and inform and train our employees. 
Pre-Startup Review 
Whenever a process change is significant enough to require a change in safety information under the management of change procedures, we will perform a pre-startup review prior to initiating the process.  The pre-startup review includes a confirmation of design specifications, operating procedures, process hazard analysis and employee training. 
Compliance Audits 
We conduct compliance audits on a regular basis to 
confirm that the provisions set out under the RMP rule are being implemented.  These audits are performed at least every 3 years and any corrective actions required as a result of the audits are undertaken in a timely manner. 
Incident Investigation 
We promptly investigate any incident that has resulted in, or could reasonably result in, a catastrophic release of chlorine.  These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the incident from reoccurring.  All reports are retained for a minimum of 5 years. 
Employee Participation 
We have consulted with employees and their representatives regarding development of the Process Hazard Analysis and other elements of process safety management to ensure that they have access to all information to be developed under this rule. 
Hot Work Permit 
We have a Hot Work Permit program in place to meet the requirements of OSHA 29CFR1910.252(a).  This program minimizes the l 
ikelihood of an accidental fire by requiring planning and preparation for hot work conducted on or near a covered process. 
In order to ensure a safe facility, we check the safety performance of all contractors that work on our facility.  Contractors are trained in the hazards associated with the covered processes and are trained in safe working practices. 
Five-year accident history: 
Due to our comprehensive safety program, this facility has never had an accident involving chlorine that caused deaths, injuries, property or environmental damage, evacuations, or shelterings in place.
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