Wastewater Treatment Plant - Executive Summary

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Executive Summary for the Wastewater Treatment Plant, Big Spring, Texas 
 
1.    Accidental Release Prevention and Emergency Response Policies 
We at Wastewater Treatment Plant, Big Spring, Texas, are strongly committed to employee, public and environmental safety.  This commitment is inherent to a comprehensive accidental release prevention program in place 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 
Wastewater Treatment Plant's primary activities encompass wastewater treatment for the City of Big Spring, Texas.  We have two regulated substances present at our facility, Chlorine and Sulfur Dioxide.  The regulated substances at our facility are used to treat (disinfect and de-chlorinate) wastewater for our customers. 
 
 
The maximum inventory of Chlorine at our facility is 16,000 pounds.  The maximum inventory of Sulfur Dioxide is 12,000 pounds. 
 
3.    The Worst Case Release Scenario(s) and the Alternative Release Scenario(s) 
To perform the required offsite consequence analysis for our facility, we used RMP*Comp.  RMP*Comp is a free program used to perform the offsite consequence.  RMP*Comp was developed by the CAMEO Team at the Hazardous Materials Response and Assessment Division, NOAA, and the Chemical Emergency Prevention and Preparedness Office of the EPA.  For additional guidance, we used EPA's Risk Management Program Guidance for Wastewater Treatment Plants (40 CRF Part 68).  The following paragraphs provide details of the chosen scenarios. 
 
Chlorine: 
' Worst case release scenario:  Failure of one of the 2000-pound storage tanks would release 2000 pounds of chlorine in a liquid spill and vaporization over 10 minutes.  No passive mitigation considered.  At Class F atmospheric stability and 1.5 m/s wi 
ndspeed, the maximum distance of 0.9 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. 
' Alternative Scenario 1:  Tubing failure, bad connection, or valve failure resulting in the release of gas through the 5/16-inch- diameter opening (CLA-3) would release 317 pounds of chlorine in a gaseous form over 60 minutes.  Passive mitigation considered is a building enclosure.  At Class D atmospheric stability and 3.0 m/s windspeed, the maximum distance of 0.1 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. 
' Alternative Scenario 2:  Failure of a 1-inch schedule 80 pipe connected to four 1-ton containers (CLA-6) would release 1268 pounds of chlorine in a gaseous form over 27.1 minutes.  Passive mitigation considered is a building enclosure.  At Class D atmospheric stability and 3.0 m/s windspeed, the maximum distance of 0.1 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. 
 
Sulfur Dioxide: 
' Worst case release scenario:  Failure of one of  
the 2000-pound storage tanks would release 2000 pounds of sulfur dioxide in a liquid spill and vaporization over 10 minutes.  No passive mitigation considered.  At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 0.9 miles is obtained corresponding to a toxic endpoint of 0.0078 mg/L. 
' Alternative Scenario 1:  A one-half inch hole in the storage tank would release 14,010 pounds of sulfur dioxide in a liquid form over 60 minutes.  No passive mitigation considered.  At Class D atmospheric stability and 3.0 m/s windspeed, the maximum distance of 0.9 miles is obtained corresponding to a toxic endpoint of 0.0078 mg/L. 
' Alternative Scenario 2:  A one-half inch hole in the storage tank would release 1080 pounds of sulfur dioxide in a gaseous form over 60 minutes.  No passive mitigation considered.  At Class D atmospheric stability and 3.0 m/s windspeed, the maximum distance of 0.1 miles is obtained corresponding to a toxic endpoint of 0.0078 mg/L. 
 
4.    The General  
Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
Wastewater Treatment Plant has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA.    The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. 
 
Safety Information 
Wastewater Treatment Plant maintains a detailed record of safety information that includes the management system, major hazards summary, MSDS data sheets, safe upper and lower temperatures, pressures, flows and compositions, equipment specifications, and codes and standards. 
 
Hazard Review 
Wastewater Treatment Plant conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently.  The methodology used to carry out these analyses is a Hazard Review Checklist for Chlorine and Sulfur Dioxide.  The checklists are undertaken by a team of q 
ualified personnel with expertise in process operations and are revalidated at a regular interval of five years.  Any findings related to the hazard analysis are addressed in a timely manner. 
 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, Wastewater 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 
Wastewater Treatment Plant has a training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes.  Training includes both formal classroom training and one-on-one on the job training.  Formal classroom training is provided at s 
hort courses to comply with operator certification requirements.  Employees complete a 20-hour safety course. 
 
Management 
Wastewater Treatment Plant carries out 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 and controls.  Qualified personnel carry out maintenance operations 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 
Wastewater Treatment Plant conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented.  These audits are carried out at least every three years and any corrective actions required as a result of the audits are un 
dertaken in a safe and prompt manner. 
 
Incident Investigation 
Wastewater 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 five years. 
 
5.    Five-year Accident History 
Wastewater Treatment Plant has had an excellent record of preventing accidental releases over the last five years.  There has been no accidental release during this period. 
 
6.    Emergency Response Plan 
Wastewater Treatment Plant carries a written emergency response plan to deal with accidental releases of hazardous materials.  The plan includes an emergency evacuation plan and emergency contact numbers.  The Wastewater Treatment Plant is included in the Howard County LEPC. 
 
7.    Planned Changes to Improve Safety 
Wastewater T 
reatment Plant does not anticipate changes to the facility. 
 
8. Certification Statement 
The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. 
 
Name:  Kenny Scott 
 
Signature:____________________________ 
Title:  Water and Wastewater Superintendent 
 
Date signed:__________________________ 
 
 
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