Wildwood Lower WTF - Executive Summary |
|
The Accidental Release Prevention and Emergency Response Policies The Cape May County Municipal Utilities Authority (CMCMUA) is committed to the safe use of Chlorine at the Wildwood/Lower Wastewater Treatment Facility (WW/L). Chlorine safety procedures at the WW/L facility have been developed in accordance with the New Jersey Toxic Catastrophe Prevention Act program (TCPA). This includes employee training, specific written procedures for all operational and maintenance tasks, emergency response planning and training, auditing, and risk assessment. Facility TCPA procedures require certified Chlorine Operators for all operations and maintenance activities involving Chlorine. The CMCMUA employs a full time Safety Officer who assists facility personnel to maintain a safe work place. The Facility and The Regulated Substance Handled Located 1.5 miles west of the Wildwoods on Route 47 in Middle Township NJ, the Wildwood/Lower Wastewater Treatment Facility (WW/L) treats and disinfects 3 to 10 million gallons of wastewater a day. This secondary treatment facility utilizes "Rotating Biological Contacters" for treatment, and gaseous chlorine stored in ton containers for disinfection. Since the startup of this facility in 1988, management and staff have been committed to maintaining the chlorine system as safely and efficiently as possible. There has never been a chlorine accident at the WW/L Facility. In 1989 the NJ Department of Environmental Protection (NJDEP) required the facility to develop a comprehensive "Risk Management Plan" (RMP) to Comply with the federal "Toxic Catastrophe Prevention Act" (TCPA). The Facility RMP requires strict adherence to specific requirements for chlorination equipment operation and maintenance, operator training, and emergency response procedures. Compliance with (TCPA) regulations has been audited annually by an internal audit team and by Chemical Safety Engineers from the NJDEP. The WW/L Facility has passed every NJDEP audit and ha s been commended for the excellence of it chlorine safety program. In an ongoing effort to reduce the risk to health and the environment many changes have evolved over the years. The most substantial modification was switching chlorine feed to the gas side of the ton containers and the removal of the liquid chlorine evaporators. Originally the WW/L Facility was equipped with evaporators supplied from the liquid side of the ton containers. A leak of liquid Chlorine is many times more dangerous than a gaseous chlorine leak. Switching to gaseous chlorine has greatly reduced the risk from a chlorine accident. The latest modification was the addition of a remote automatic valve closure system. This system automatically closes the ton container feed valve if a chlorine leak is sensed by any of the (5) chlorine sensors located around the chlorine area. The Worst-Case Release Scenario and The Alternative Release Scenario This facility used a one ton container rupture in the chlorine s torage area for the worst case scenario. This was used because the storage area is a covered raised concrete pad with three sides open. This allows direct access to the atmosphere. The scenario was run using RMP Comp. The model showed a 3-mile range. This would impact residents, businesses, schools, and nursing homes. Protection of this area is extremely difficult. The addition of two chlorine detectors located on the north and south side of the pad reduced the leak duration by alarming an auto dialing notification system, which will initiate an Emergency Response. In addition to the detectors some procedures minimize the chance of a liquid leak by requiring all ton containers to be stored with the valves perpendicular to the ground. This allows a 50% chance of a gas leak in the event of a valve failure. And hoist operations are performed by EHS operators only. A flex connector failure was chosen as the alternate scenario because of a high probability factor. Hazard Analysi s and Risk Assessments have shown human error particularly with the flex connector or associated equipment to have the highest probability of a serious release at this facility. These components particularly are subject to human error on a daily basis. Recognizing this, procedures and training are focused in this area. In this scenario the flex connector is sheared. A sheared line has a lower probability than a lead washer failure or a crack in the line. But a leaking washer or a crack in the connector didn't qualify as an alternate scenario as it didn't have offsite impact. This equipment is located in an enclosed room (not airtight) with manual ventilation. The model showed a plume of 0.2 miles. That would impact one highway and a back-bay waterway. This room has two detectors that will activate the ton container valve closure system and an emergency response. The valve closure system will close the supply by as much as 25 minutes sooner than the emergency response team can ge t in and close it. For the purpose of this scenario it was assumed that the closure system didn't activate. The general accidental release prevention program and chemical-specific prevention steps This Facility complies with OHSA, EPA, and NJDEP regulations. It is our practice to understand the intent of each regulation and apply them properly. An example of that is our training program. We recognized the need for awareness in and about the chlorine system. But the regulations required extensive training just to go in the room. Working with the NJDEP we split our EHS Operator training program into 3 levels of operators. Level 1 operators are trained to identify all EHS equipment and recognize abnormal conditions. Emphasis is put on handling ton containers. Level 2 operators are trained to know what all the equipment does and how to respond to abnormal conditions. Level 3 operators are trained to know how all the equipment operates so they can perform maintenance and trouble shoot. This training system has proven to work well as we have had no EHS accidents at this facility. The Five-Year Accident History This facility has not had any accidents. The Emergency Response Program This facility maintains an in house Emergency Response Team (ERT). The team is comprised of varying levels of EHS operators. In addition to our expert site specific ERT we also have the US Coast Guard ERT as a back up. At least one of our two drills a year utilizes off site affiliations. Fire, Police, Rescue and the US Coast Guard. We are very fortunate to have highly qualified and cooperative off site affiliations. |