Utoy Creek WRC - Executive Summary |
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In accordance with Title 40 of the Code of Federal Regulations, Chapter 68, Subpart G, Section 155 (40 CFR 68.155), under section 112(r) of the Clean Air Act Amendments (CAAA), the Utoy Creek Water Reclamation Center (WRC) located at 805 Selig Drive, Atlanta, Georgia, has established an Executive Summary of the Risk Management Plan. One process has been determined to be subject to the 112(r) requirements. As part of water reclamation, the natural breakdown of solids which have been separated from the water occurs in structures known as digesters. The digestion process at the Utoy Creek WRC generates digestion gas containing flammable concentrations of methane. The digester gas is either stored, flared, or burned as an alternative fuel source for process sludge incineration. An accidental release of digester gas could result in fire or explosion because of the methane content of the gas. The Utoy Creek WRC has developed a Risk Management Plan and Program to help prevent a potentia lly flammable or explosive release of digester gas and to be prepared to respond in case such a release occurs. For the digestion (methane) process, worst-case and alternative scenarios were developed to assess the possible consequences of accidental releases of digester gas. Worst-case scenarios involved estimation of the impact of a rapid, substantial release under artificially adverse weather conditions. The developed alternative scenario estimates the impact based on more realistic release parameters under typical meteorological conditions. Specifically, the worst-case scenario for methane was modeled on a vapor cloud explosion of the entire contents of the largest vessel in the digester gas system. The alternative case for methane was based on a vapor cloud fire from an accidental release from a digester unit roof vent. The Environmental Protection Agency (EPA) developed and approved software package, RMP*Comp, was utilized to estimate the explosive and flammable endpoint di stances for the release scenarios. Another EPA-approved software package, LandView III, as well as other available information, were employed to identify public and environmental receptors within the extents identified by RMP*Comp. Specific values from these calculations are provided in Sections 2 through 5 of the Risk Management Plan and Chapter 2 of the Risk Management Program. The calculations did not account for active or passive mitigation measures. There have been no accidents involving substantial methane release that resulted in on-site or off-site injury, property damage, environmental damage, evacuations or sheltering in place within the past 5 years. The facility has an emergency response plan which is coordinated with the Atlanta-Fulton County Emergency Management Agency/Fulton County Local Emergency Planning Committee (LEPC) and the Fire Department (FD). The Utoy Creek WRC is prepared to respond by assessing the hazard level of a release, and correcting or interrupti ng incidental leaks. The LEPC/FD will respond to substantial releases, releases with combustion, and any release that is identified as migrating off the Utoy Creek WRC property. The LEPC/FD will notify the public if an imminent health threat is determined to exist. To help prevent accidental releases of methane, the Utoy Creek WRC has developed a Prevention Program (Program 2). The Prevention Program includes the following key elements: 7 safety information and equipment (such as methane detectors) 7 hazard review of equipment and procedures 7 safe and standard operating procedures 7 operator training 7 preventive maintenance program 7 compliance auditing program 7 incident investigation program The Utoy Creek WRC has identified opportunities to increase the safety of the facility, the public, and the environment. The facility plans to implement improvements including, but not limited to: detection system upgrades, digestion system appurtenance upgrades and continuing enhanceme nt of the inspection and response planning procedures. |