Moore Street Waste Water Treatment Plant - Executive Summary |
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City of Beeville Moore Street Waste Water Treatment Plant RISK MANAGEMENT PROGRAM PLAN Executive Summary Accidental Release Prevention and Emergency Response Policies The accidental release prevention and emergency response policies at the City of Beeville's Moore Street Waste Water Treatment Plant are engrained in the fundamentals of the prevention program. At the Moore Street Waste Water Treatment Plant, we have one chemical, chlorine, at a quantity which is considered hazardous by the Environmental Protection Agency (EPA). The same property that makes this chemical valuable for treating waste water also make it necessary to observe specific safety precautions. These safety precautions are exercised in the operation and maintenance or our chlorination system to control human and environmental exposure in an effort to reduce the overall threat to our workers as well as the surrounding community. It is the City of Beeville's policy to adhere to all applicable federal, state, and local rules and regulations. However, the safe handling of hazardous chemicals is paramount to Beeville and its citizens, and we often exceed standards and recommended practices governing the safe handling of hazardous chemicals to ensure that we have obtained a reasonable level of risk reduction. The City of Beeville believes that accountability for safety reaches throughout all level of city personnel. Senior management's commitment and dedication to continue safe-operating practices is clearly evident in our organization structure and employee empowerment. Facility Description and Regulated Substance Handled The Moore Street Waste Water Treatment Plant is located Southeast of the City of Beeville adjacent to Poesta creek, East of US Hwy 181 By Pass, and 3/4 mile North of State Hwy 202. This site is in Bee County, Texas. The Moore Street Waste Water Plant treats on average 3,000,000 gallons of waste water per day. There are eleven (11) full-time employees at the site. Th e principal purpose of the chlorine used on site is wastewater disinfection. The application of a chlorine solution to the treated effluent prior to its release to the receiving stream is one of the most important parts of the treatment scheme Chlorine is received by truck carrying one (1) ton chlorine cylinders. The cylinders are stored in a covered storage shed. One container can be connected at a time. A total of two (2) cylinders (4,000 lbs.) is kept at Moore Street Waste Water Treatment Plant. Offsite Consequence Analysis (Worst-case & Alternate-Case) The RMP rule requirements for identification and selection of a worst-case hazard scenario are prescriptive. These requirements negate most safety systems designed to mitigate an incidental release that would typically be in the event that an incident occurred. Based on EPA defined Offsite Consequence Analysis (OCA) Guidance, Moore Street Waste Water Treatment Plant has one worst-case hazard scenario for the toxic material ha ndled onsite. This scenario is estimated to create the greatest distance in any direction to an EPA defined concentration (endpoint) resulting from an accidental release. The chlorine used at our facility is stored under its own vapor pressure in standard one ton containers located under a protective open-sided shed. The worst-case scenario uses the EPA's theoretical assumption that a container may catastrophically fail and release chlorine to the atmosphere. It completely negates any mitigation attempts and assumes that all 2,000 pounds of chlorine can be dispersed within 10 minutes to form a toxic vapor cloud that drifts offsite into the surrounding community. Using the EPA's Offsite Consequence Analysis Document, dated October 1998, to determine the greatest downwind distance, it was determined that a chlorine vapor cloud may extend 1.30 miles from the site of release. This calculation was based on the EPA recommended guide for chlorine. The EPA rule also requires that an al ternate or more likely accident scenario be identified. In this alternate scenario, inadvertent mishandling of a chlorine shipping container during delivery results in complete separation of the container's valve. this failure assumes that 251 pounds per minute of chlorine is released. Dispersion of the chlorine gas could result in the formation of a vapor cloud extending 0.27 miles (1,426 feet) from the release site. Accidental Release Program and Chemical-Specific Prevention Steps The City of Beeville's More Street Waste Water Treatment Plant Prevention program was designed around mechanical integrity and training aspects. The primary objective is to ensure complete containment of chlorine through safe operation and maintenance of the water treatment systems. The prevention program has been designed with the following objectives: 1. Enhancement of the mechanical integrity of all chlorine equipment and piping. 2. Compilation of safety information to improve hazard awareness. 3. Training to increase hazard recognition. Five Year Accident History The City of Beeville's Moore Street Waste Water Treatment Plant has not had an accidental release of Chlorine during the past five (5) years. Emergency Response Program The City of Beeville has made a concise decision not to have Moore Street Waste Water Treatment Plant personnel respond to catastrophic releases of chlorine at the facility. Employees have been instructed to notify the Bee County LEPC and the Beeville Fire Department. Planned Improvements to Reduce Risk Investigation of inherently safer technologies, chemical inventory reduction through usage studies and administrative limits, and failsafe design applications are a few of the continuous improvements occuring at the Moore Street Waste Water Treatment Plant. Safety depends upon our management commitment, the manner in which we handle chlorine, the safety devices inherent to our waste water treatment system, operating procedures, and the philosoph ies and training of our employees. |