Galveston Co. WCID No.1 Wastewater Treatment Plant - Executive Summary |
|
EXECUTIVE SUMMARY FOR GALVESTON COUNTY WATER CONTROL & IMPROVEMENT DISTRICT NO. 1 RISK MANAGEMENT PLAN 1. Accidental Release Prevention and Emergency Response Policies Water Control & Improvement District No. 1 (WCID No. 1) is strongly committed to employee, public, and environmental safety. This commitment is demonstrated by WCID No. 1's comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at its facility. It is WCID No. 1's policy to implement appropriate controls to prevent possible releases of regulated substances. If such a release does occur unforeseeably, WCID No. 1 is completely coordinated with the Dickinson Volunteer Fire Department, which provides highly trained emergency response personnel to control and mitigate the effects of the release. 2. The Stationary Source and the Regulated Substances Handled The facility's primary activities encompass wastewater treatment. WCID No. 1 has one regulated substance present at its facility that exceeds the regulated quantity. This substance is chlorine and is used for disinfection of the wastewater. The maximum inventory of chlorine at the facility is 11,500 pounds. 3. The Worst-Case Release Scenario and the Alternative Release Scenario, Including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario. To perform the required off-site consequence analysis for its facility, WCID No. 1 has used EPA's RMP*Comp(tm). The following paragraphs provide details of the chosen scenarios. The worst-case release scenario submitted for Program 2 toxic substances as a class involves a catastrophic release from chlorine storage. The scenario involves the release of 2,000 pounds of chlorine in a gaseous form over a 10-minute period. Passive mitigation controls, such as being in a covered area, are also taken into account to calculate the scen ario. At Class F atmospheric stability and 1.5 m/s wind speed, the maximum distance of 1.3 miles is obtained, corresponding to a toxic endpoint of 0.0087 mg/L. One alternative release scenario has been submitted for each toxic substance present in Program 2. The alternative release scenario for chlorine involves a release from the chemical storage area. The scenario involves the release of 150 pounds of chlorine in a gaseous form over a 10-minute period. Passive mitigation controls, such as being in a covered area, are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of chlorine is 0.3 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps WCID No. 1 has taken all the necessary steps to comply with the accidental release prevention requirements mandated under 40 CFR part 68 of the EPA. The facility is also subject to EPCRA Section 302 notific ation requirements. The following sections briefly describe the elements of the release prevention program that is in place at WCID No. 1's stationary source. Process Safety Information WCID No. 1 maintains a detailed record of safety information that describes the chemical hazards, operating parameters, and equipment designs associated with all processes. Process Hazard Analysis WCID No. 1 conducts comprehensive studies to ensure that hazards associated with its processes are identified and controlled efficiently. The methodology used to carry out these analyses is going through a checklist prepared by the Chlorine Institute. The studies are undertaken by qualified personnel. Any findings related to the hazard analysis are addressed. Operating Procedures For the purposes of safely conducting activities within its covered processes, WCID No. 1 has adopted written operating procedures. These procedures address various modes of operation such as initial startup, normal operations , temporary operations, emergency shutdown, emergency operations, and normal shutdown. The information is readily accessible to operators involved in the processes. Training WCID No. 1 has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Training is provided as frequently as needed. Mechanical Integrity WCID No. 1 carries out 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, controls, and pumps. Maintenance operations are carried out by qualified personnel who have previous training in maintenance practices, and are offered further specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Manag ement of Change Procedures are in place at WCID No. 1 to manage changes in process chemicals, technology, equipment, and procedures. Process operators, maintenance personnel, or any other employee whose jobs tasks are affected by a modification in process conditions are promptly made aware of the modification. Pre-Startup Reviews Pre-startup safety reviews related to new processes and to modifications in established process are conducted at WCID No. 1. These reviews are conducted to confirm that construction, equipment, and operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Incidental Investigation WCID No. 1 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 reta ined for a minimum of five years. Employee Participation WCID No. 1 truly believes that process safety management and accident prevention is a team effort. Employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, WCID No. 1's employees have access to all information created as part of the facility's implementation of the RMP rule. Contractors On occasion, WCID No. 1 hires contractors to conduct specialized maintenance and construction activities. The facility has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response in the event of an accidental release of a regulated substance. 5. Five-Year Accident History WCID No. 1 has had an excellent record of preventing accidental releases over the last five years. Due to the facility's stringent release-preventi on policies, there have been no accidental releases during this period. 6. Emergency Response Plan WCID No. 1 is coordinated to deal with accidental releases of hazardous materials. As part of this coordination, the facility has a written community emergency response plan that address all aspects of emergency response, including adequate first aid and medical treatment, evacuations, and notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. Galveston County LEPC No. 2 is the Local Emergency Planning Committee (LEPC) with which WCID No. 1's emergency plan has been coordinated and verified. |