Roy C. Hester Water Treatment Plant - Executive Summary |
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Executive Summary for the Roy C. Hester Water Treatment Plant, Big Spring, Texas 1. Accidental Release Prevention and Emergency Response Policies We at Roy C. Hester Water 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 Roy C. Hester Water Treatment Plant's primary activities encompass water treatment for the City of Big Spring, Texas. We have two regulated substances present at our facility, Chlorine and Ammonia (Anhydrous). The regulated substances at our facility are used to treat (disinfect) potable water for our customers. The maximum inventory of Chlorine at our facility is 16,000 pounds. The maximum inventory of Ammonia (Anhydrous) is 14,010 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 have used primarily 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 the AWWA Compliance Guidance and Model Risk Management Program for Water Treatment Plants. 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 at mospheric stability and 1.5 m/s windspeed, 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. Ammonia (Anhydrous): ' Worst cas e release scenario: Written administrative policy limits the maximum inventory of the 6,000-gallon tank to 3,000 gallons. Failure of the storage tank would release 14,010 pounds of ammonia 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 1.5 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. ' Alternative Scenario 1: A one-half inch hole in the storage tank (Reference Table ANAA-1) would release 14,010 pounds of ammonia in a gaseous form over 42 minutes (337 pounds per minute). No passive mitigation considered. At Class D atmospheric stability and 3.0 m/s windspeed, the maximum distance of 0.6 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. ' Alternative Scenario 2: A ruptured disk or failure of the relief valve would release 1080 pounds of ammonia in a gaseous form over 60 minutes. No passive mitigation considered. At Class D a tmospheric stability and 3.0 m/s windspeed, the maximum distance of 0.1 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Roy C. Hester Water 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 Roy C. Hester Water 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 Roy C. Hester Water 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 Ammonia. The checklists are undertaken by a team of qualified 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, Roy C. Hester 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 Roy C. Hester Water Treatment Plant has a training program in place to ensure that employees who are operating processes are competen t 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 short courses to comply with operator certification requirements. Employees complete a 20-hour safety course. Management Roy C. Hester Water 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 Roy C. Hester Water Treatment Plant conducts audits on a regular basis t o 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 undertaken in a safe and prompt manner. Incident Investigation Roy C. Hester 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 five years. 5. Five-year Accident History Roy C. Hester Water 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 Roy C. Hester Water Treatment Plant carries a written emergency response plan to deal with acciden tal releases of hazardous materials. The plan includes an emergency evacuation plan and emergency contact numbers. The Roy C. Hester Water Treatment Plant is included in the Howard County LEPC. 7. Planned Changes to Improve Safety Roy C. Hester Treatment 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:__________________________ \\lub1\data\projects\1999\0302.99\CIVIL\wtp exec summary.doc |