Seneca Wastewater Treatment Plant - Executive Summary

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Executive Summary 
Introduction  
Chemicals are widely used in industry, in the home, and in the environment.  They are transported on roads, water, and railways.  The Metropolitan Council's Seneca Wastewater Treatment Plant stores chemicals that it uses in its daily operations. The facility currently uses chlorine stored in up to eight 1-ton containers and sulfur dioxide in stored in up to six 1-ton containers.  Chlorine is used to disinfect the treated wastewater and the sulfur dioxide is used to remove residual chlorine, or dechlorinate, the treated wastewater to protect organisms in the river when it is discharged. The natural world contains more than 1,500 chlorine-containing compounds.  Chlorine is also used to purify our drinking water, disinfect our swimming pools and protect human health through the destruction of disease-causing organisms. The World Health Organization estimates that 25,000 children who die daily could be saved through the use of an effective water disinfectio 
n agent such as chlorine. 
The Seneca Plant also stores up to 51,000 gallons of liquid propane in two bulk storage tanks. The liquid propane system is designed to provide propane as an auxiliary fuel source for the solids incinerator burners and the plant boilers.  The propane system is used periodically in winter when natural gas usage is curtailed by the gas company. 
Chlorine and sulfur dioxide are non-explosive and non-flammable. However, they support combustion under some circumstances. They are both respiratory irritants, and if accidentally released into the environment, exposure through inhalation or through eye or skin contact can pose a health risk.  Propane's extreme flammability, extensive explosibility range, and very low flash point represent dangerous fire and explosion risks.  When propane is mixed with air in the proper concentration, an explosive mixture may result.  An explosive mixture in the presence of a spark or flame could result in an explosion. As a precaution,  
the Seneca Plant has special safety systems that are an integral part of the chlorine, sulfur dioxide, and propane systems. 
We take our safety obligations in storing and using chemicals as seriously as we take providing the environment with safe disinfected water.  The following document describes the steps we take everyday to ensure a safely operating plant, what could happen if there was an accidental release of a chemical stored on site, and what to do in event of an emergency.   
Accidental Release Prevention and Emergency Response Policies 
This document complies with the U.S. Environmental Protection Agency's (EPA's) Risk Management Program, codified under Section 112 (r) of the Clean Air Act (CAA) Amendments of 1990, 40 Code of Federal Regulations (CFR) Part 68.  The Risk Management Program requires facilities that use certain substances above certain quantity thresholds to develop a plan to reduce the likelihood of an accidental release of the substances to the atmosphere and red 
uce the likelihood of serious harm to the public and the environment. This plan is referred to the Risk Management Plan (RMP). 
Chlorine, sulfur dioxide, and propane are stored in quantities above the regulatory thresholds at which a RMP is required.  This RMP document summarizes our existing safety systems, policies, procedures, and on-going actions that are designed to prevent or minimize impacts of accidental releases of chlorine or sulfur dioxide to the environment. The Seneca Plant has a detailed and comprehensive emergency response plan to handle any potential accidental releases.  To date, we have had an excellent record in preventing accidents from occurring. No chlorine, sulfur dioxide, or propane releases causing a safety or health hazard affecting the surrounding community have occurred at the Seneca Plant since use of these chemicals began (chlorine disinfection began in 1972, and the propane system was added in 1992). 
Understanding the Chemicals Used at the Seneca Plant 
The 
Seneca Plant, operating since the 1972, is located at 3750 Plant Road in Eagan, Minnesota.  Wastewater from Burnsville, Eagan, Savage, and Bloomington is treated at the Seneca Plant and discharged into the Minnesota River.  The wastewater treatment process includes preliminary screening, primary settling and treatment, secondary treatment and clarification, and chlorination and dechlorination before final discharge.  The Seneca Plant treats approximately 25 million gallons of wastewater per day. The Seneca Plant has a chlorination system that uses chlorine gas fed from 1-ton chlorine containers and a dechlorination system that uses sulfur dioxide gas fed from 1-ton sulfur dioxide containers.  The plant also has a propane system to provide auxiliary fuel for incinerator burners and plant boilers. 
Chlorine and Sulfur Dioxide 
The chemical distributor delivers 1-ton chlorine and sulfur dioxide containers to the plant.  Gaseous chlorine is withdrawn directly from the 1-ton containers and d 
elivered to the wastewater chlorination process.  Similarly, gaseous sulfur dioxide is withdrawn from the 1-ton containers and delivered to the wastewater dechlorination process.  The Seneca Plant uses state-of-the-art process equipment to maximize the safety for plant staff and the community at large.  Some of the specific features are as follows.  Chlorine and sulfur dioxide leak detectors continuously monitor for leaks in the bulk storage areas and in the chlorination and dechlorination rooms.  Leak alarms activate an audible alarm throughout the plant as well as a red flashing warning light on the storage building. The alarms also sound at the central and local control panels.  The leak alarms are tested weekly.  
Other system alarms include low vacuum at the chlorinator or sulfonator, and low injector water pressure. Vacuum regulators are used on the gas piping so that chlorine and sulfur dioxide gas is delivered under vacuum.  If a leak were to occur on this piping, outside air wo 
uld be drawn into the piping rather than chlorine or sulfur dioxide gas being forced out of the piping.  
The chlorine and sulfur dioxide storage areas are enclosed in a building.  The building is equipped with an emergency ventilation system that activates a scrubber when either the chlorine or sulfur dioxide leak detector detects chlorine or sulfur dioxide in the room.  Chlorine or sulfur dioxide leaks are treated in the scrubber and cleaned gas is discharged to the atmosphere.  The scrubber is sized to treat the entire contents of a 1-ton chlorine or sulfur dioxide container.   
Emergency showers and eye wash stations are provided at each building along with smoke alarms.  
The Seneca Plant's water discharge permit issued by the Minnesota Pollution Control Agency (MPCA) only requires disinfection from March 1 through October 31.  During the rest of the year chlorine usage is significantly reduced, all of the sulfur dioxide is removed from the plant, and a complete preventative maintena 
nce program is administered on all chlorine and sulfur dioxide piping and equipment.  
Propane 
The chemical distributor delivers propane to the Seneca Plant and transfers the liquid propane into the two bulk storage tanks. The Seneca Plant enforces a no smoking policy in the propane areas.  All equipment in these areas is non-sparking and designed to meet explosion-proof standards.  There are lower explosion limit (LEL) detectors in several locations around the propane area.  If a propane leak occurred resulting in an explosive mixture of gas and air, the LEL detector would trigger an alarm. 
The propane system is only used during the winter when natural gas usage is curtailed by the gas company.  During the rest of the year, the propane system is shut down.  At the beginning of each heating season, the propane system supplier performs a complete system inspection and exercises the equipment to ensure that it is functioning properly.   
RMP Requirements 
The RMP consists of three major par 
ts. The first part is the Hazard Assessment. The Hazard Assessment is done to determine the potential effects that a release of a regulated substance could have on the public surrounding the facility. The second part is a Prevention Program that consists of 12 elements designed to improve the system safety and decrease the likelihood of a release. The third part is the Emergency Response Program, which develops a plan for dealing with a release in the unlikely event that one would occur. Because the regulations are very similar, the Prevention Program and the Emergency Response Program also serve as the OSHA Process Safety Management (PSM) plan, and this document is therefore is referred to as the RMP/PSM plan. 
Hazard Assessment 
A Hazard Assessment was performed to determine the effects a release would have on the public surrounding the facility. For chlorine and sulfur dioxide, the distance a set endpoint concentration of the gas would travel must be determined. For propane, the dista 
nce to the end of the impact zone resulting from a propane explosion must be determined.  In addition, an estimate of the population that could be affected by a release of chlorine or sulfur dioxide or a propane explosion was determined, and sensitive receptors such as hospitals, schools, and nursing homes were identified. The Hazard Assessment considers two release scenarios-a "worst case" and an "alternative case."  
Worst-Case Scenario 
The regulations require the development of a worst-case release scenario based on conservative assumptions. For example, the Seneca Plant is required to assume that the entire contents of the largest single container of chlorine or sulfur dioxide will be released in 10 minutes. This is an extremely unlikely occurrence since the physical properties of both chlorine and sulfur dioxide would cause a freeze and thaw cycle to occur at the leak, which would slow the release. In addition, only "passive" mitigation methods such as buildings or dikes can be con 
sidered when determining the distance the release could travel. Passive mitigation, as defined, requires no mechanical, electrical, or human input. However, in many scenarios mitigating the release by isolating the process could reduce the amount released. In addition, the worst-case scenario requires that very stable atmospheric conditions be assumed which results in a large area of impact. These conservative assumptions were set by EPA to ensure public notification and ensure that local emergency response planning takes into account the greatest possible impacted area surrounding the release point. 
The scenario used for both chlorine and sulfur dioxide at the Seneca Plant is the rupture of a 1-ton container, resulting in a release of 2,000 pounds of chlorine or sulfur dioxide over a 10-minute duration.  The released liquid is assumed to quickly volatilize and to disperse as a vapor cloud. The hazard assessment requires that the "toxic endpoint" or distance from the point of release t 
o a location at which the chemical concentration equals or exceeds a certain concentration must be determined. The distance to the toxic endpoint was estimated using the EPA-approved DEGADIS BreezeHaz(tm) DEGADIS+ 2.0 gas dispersion model. That concentration is defined as the maximum airborne concentration below which individuals could be exposed for up to 1 hour without experiencing or developing irreversible or other serious health effects, or symptoms that could impair an individual's ability to take protective action.  
In practice this type of total release of a bulk tank would be unlikely and probably never occur during the lifetime of the plant. The results of the dispersion modeling analysis for the chlorine and sulfur dioxide worst-case release scenario indicate that the scenarios have an offsite impact that extends to a 1.7-mile radius for chlorine and a 1.9-mile radius for sulfur dioxide.  
For the propane worst-case scenario, it must be assumed that all the gas in the vessel  
containing the largest quantity of propane is catastrophically released, and the gas is ignited and explodes. This is very unlikely to occur since the proper mixture of propane and oxygen required for an explosion would be difficult to achieve. The distance to the end of the impact zone for a propane explosion is defined by a "1-psi overpressure." The 1-psi overpressure is the radius outside of the explosion shock wave, along which broken glass and other similar structural damage is possible. The results of the analysis for the propane worst-case release scenario indicate that the scenario has an offsite impact that extends to a 0.4-mile radius. 
Alternative Scenario 
The RMP rule also requires that at least one alternative release scenario be evaluated for chlorine, sulfur dioxide, and propane. The alternative scenarios reflect a type of release that is more likely to occur compared to the worst-case scenario. Unlike the worst-case scenario, the alternative release scenario may consider 
"active" mitigation such as shutoff valves and a more realistic release quantity and release rate. Active mitigation is defined as requiring mechanical, electrical, or human input. Lastly, it assumes local, typical meteorology, which is more realistic than the conservative meteorological conditions that must be assumed for the worst-case scenario. The scenario used for both chlorine and sulfur dioxide assumes that a small hole or puncture occurs in the gas piping.  This release scenario considered reductions in the leak due to passive mitigation because the piping system is enclosed in a building.  Under this scenario, the amount of chlorine and sulfur dioxide released was calculated to be 20 pounds and 9 pounds, respectively. The same modeling approach was used as for the worst-case release scenario, except meteorological conditions were adjusted to more likely local conditions. The results of the dispersion modeling analysis for the chlorine and sulfur dioxide alternative case relea 
se scenario indicate that the scenarios have an off site impact that extends to a 0.1-mile radius for both chlorine and sulfur dioxide.  
The scenario used for propane assumes that a propane tank is overfilled resulting in a release of propane gas through the pressure relief valves on top of the tank.  This scenario further assumes that an ignition source, such as a spark or flame, is present to ignite the propane released through the pressure relief valves and cause an explosion.  The results of the analysis for the propane alternative release scenario indicate that the scenario has an offsite impact that extends to a 0.1-mile radius.   
Prevention Program 
The Prevention Program consists of 12 elements designed to improve the system safety and decrease the likelihood of a release. 
Employee Participation  
The participation of the Seneca Plant staff in preparing the RMP/PSM program was critical to the program's successful implementation. Employee participation is valuable because it incre 
ases the safety awareness of the staff and it allows the staff's experience in operating and maintaining the processes to be incorporated into the plan. 
Seneca Plant staff participated in the development of the Prevention Program through a series of meetings and workshops. Another way that the Seneca Plant staff participated in the development of the RMP/PSM was the Process Hazard Analysis that is described below. All staff receive RMP/PSM awareness training that instruct them on how the RMP/PSM requirements may impact their jobs.  Staff who operate and maintain the RMP/PSM processes are trained in how to safely maintain and operate the processes. 
Process Safety Information 
The RMP/PSM regulations require that information concerning process chemicals, technology, and equipment be compiled as part of the RMP program. Emergency response planners can use such information to develop training programs and procedures, or as a general resource. The information is also supplied to contractors  
who will work in the chlorine, sulfur dioxide, or propane process areas as part of the requirements outlined in the Contractors element of this program. All the required process safety information was compiled as stated in the RMP regulations. The information meets and in many cases exceeds the minimum required by the regulations. 
Process Hazard Analysis 
A process hazard analysis (PHA) was conducted systematically to evaluate potential causes and consequences of accidental releases. This information was used by Seneca Plant staff to improve safety and reduce the likelihood and potential consequences of an accidental release. Equipment, instrumentation, utilities, human actions, and external factors that might affect the process were the focus of the PHAs that were performed for the chlorine, sulfur dioxide, and propane processes. 
The chlorine, sulfur dioxide, and propane PHAs were conducted by an interdisciplinary team of plant staff familiar with process operation and maintenance. The 
PHA was done using a combination of "What-If" and "Checklist" methods. Based on the results of the PHAs, numerous changes in operating, maintenance, and other process safety management procedures that would improve the overall safety of the plant were identified. Several changes have been adopted by the plant and incorporated as part of the overall RMP/PSM program. Other improvements and process modifications to reduce or eliminate potential hazards are scheduled to be implemented or incorporated. 
Operating Procedures 
Operating procedures for the chlorine, sulfur dioxide, and propane processes have been developed as part of the RPM/PSM plan. Written operating procedures assure continuous, efficient, and safe operation of the facility. The goal of the operating procedures is to provide clear instructions to safely operate the process. Operating procedures are also used to train new employees and to provide refresher training for existing staff. 
The detailed operating procedures include 
chlorine, sulfur dioxide, and propane loading and unloading, startup, shutdown and normal operating procedures. The procedures describe how the system should be operated in order to minimize the chances of an accidental release. The procedures also emphasize safety considerations during operation and address potential hazardous situations that could occur and how to correct them. 
Training 
An effective RMP/PSM training program can significantly reduce the potential for accidental release incidents. Employees involved in operating or maintaining the chlorine or sulfur dioxide processes must receive training that includes applicable operating and maintenance procedures and an overview of the process. Training must emphasize safety and health hazards and safe work practices. 
Seneca Plant staff receive initial training on the operations and maintenance of the chlorine, sulfur dioxide, and propane processes, an overview of each of the RMP/PSM plan elements, and the procedures that must be f 
ollowed to comply with the requirements of the RMP/PSM plan. In addition to RMP/PSM plan training, select staff have been trained to respond to an accidental release. Refresher process operation training must be provided at least every 3 years. Refresher training for emergency response is conducted annually. 
Contractors 
The Seneca Plant must make contractors aware of the known hazards of the chlorine, sulfur dioxide, and propane processes related to the contractors' work. In addition, the plant must make contractors aware of the applicable elements of its emergency response plan. The Seneca Plant must evaluate contractors' safety programs and select only those that can perform work on or adjacent to the chlorine or sulfur dioxide processes without compromising the safety and health of employees at the facility or the surrounding public.  
Before allowing a contractor to work on or adjacent to the chlorine or sulfur dioxide processes, the plant must obtain and evaluate information regard 
ing the contractor's safety performance and programs. When a contract involving work on or adjacent to the chlorine or sulfur dioxide processes is to be bid, the bidding procedures must ensure that contractor safety management requirements are met. If a contractor is to work in or adjacent to any hazardous chemical, a safety briefing, to make the contractor aware of the plant's RMP/PSM plan requirements, must be conducted before work begins.  
Pre-startup Review 
A pre-startup safety review must be conducted for any new process that uses a regulated substance under RMP, or for significant modifications to the existing chlorine or sulfur dioxide processes that necessitate a change in the process safety information. No new or significantly modified process will start up and no acutely hazardous chemicals will be introduced into such a process prior to the pre-startup safety review. The purpose of the pre-startup safety review is to ensure that the facility is ready to operate new and modif 
ied regulated processes safely.  
To initiate the pre-startup safety review, all updated elements of the RMP/PSM plan are assembled for review. This includes all process safety information, process hazard analysis, operating procedures, employee training and mechanical integrity. A pre-startup safety review team completes a pre-startup checklist. The pre-startup safety review team should complete and sign a Pre-startup Safety Review Form. This form documents the process, and helps ensure that the review has been properly performed. The Pre-startup Safety Review Form must be authorized before startup. 
Mechanical Integrity 
An effective mechanical integrity program is one of the primary lines of defense against an accidental release. The mechanical integrity program also addresses equipment testing and inspection, preventative maintenance schedules, and personnel training. The intent is to ensure that equipment used to process, store, or handle chlorine, sulfur dioxide, and propane is main 
tained and installed to minimize the risk of releases. 
The Seneca Plant maintenance staff use a computerized maintenance management system to store equipment information, generate and prioritize work orders, schedule preventative maintenance (PM), provide safety procedures for work orders, and maintain an inventory of parts and materials. In addition to preventative maintenance, the plant staff performs corrective maintenance in the event of equipment malfunction or breakdown. Work orders indicate what safety precautions must be followed including whether lockout/tagout or confined space entry provisions are applicable. The staff that perform maintenance tasks are all trained as part of the RMP/PSM program. 
Hot Works Permits 
RMP/PSM regulations require employees and contractors to employ safe work practices when performing "hot work" in, on, or around the chlorine or sulfur dioxide processes. To ensure that hot work is done safely, a Hot Work Permit Program has been developed that requ 
ires a permit to be issued before hot work is performed. Hot work is defined as the use of oxyacetylene torches, welding equipment, grinders, cutting, brazing, or similar flame- or spark-producing operations. 
The process of completing the hot work permit makes it necessary to identify the hazard, recognize what safeguards are appropriate, and then initiate the safeguards necessary to ensure a fire-safe workplace. Following the standards outline in this section aid in complying with the OSHA Hot Work Regulations (29 CFR 1910.252(a)). 
Management of Change 
A system for the proper management of changes and modifications to equipment, procedures, chemicals, and processing conditions is required under the RMP/PSM. Modifications to the chlorine or sulfur dioxide systems will be reviewed before they are implemented to determine if the modification would compromise system safety. An effective change management system will help minimize the chance for an accidental release. 
If a modification cov 
ered under RMP/PSM is made, its effects must be addressed, employees must be informed, and the written operating procedures must be updated. The intent is to require that all modifications to equipment, procedures, and processing conditions other than "replacement in kind" be managed by identifying and reviewing them before implementation. A Management of Change Committee that consists of plant engineering, operations, and/or maintenance staff is formed to evaluate any modifications that are covered under the RMP/PSM. The committee will complete a Management of Change Form that must be reviewed and authorized prior to initiation of a covered change. 
Incident Investigation 
Each incident that resulted in or could reasonably have resulted in a catastrophic release of chlorine or sulfur dioxide must be investigated. A process to identify the underlying causes of incidents and to implement procedures for preventing similar events has been developed. To investigate an incident, facility mana 
gement will establish an investigation team. As part of the investigation, the investigation team will prepare an incident report to recommend system changes. 
The investigation team should ask questions such as what equipment failed, which behavior failed, and which material leaked, reacted, or exploded. As part of the incident review, staff actions that may have contributed to the incident will also be reviewed. A determination will be made as to whether it is necessary to institute additional training for the employees to prevent the incident from occurring in the future. On the incident report form, the plant management identifies which of the recommended system changes are approved for implementation. The incident investigation report and any changes resulting from the report will be reviewed with all staff members who operate and maintain the applicable system.  
Compliance Audit 
The Seneca Plant is required to complete a compliance audit for the RMP/PSM program. The primary goals  
of conducting an internal compliance audit are to gather sufficient data to verify compliance with RMP/PSM requirements and good process safety practices, identify process safety deficiencies and develop corrective actions, and to increase safety awareness among plant staff. 
The compliance audit methodology is modeled after OSHA's guidelines for conducting regulatory PSM compliance audits: Compliance Guidelines and Enforcement Procedures, OSHA Instruction CPL 2-2.45A (September 28, 1995). An internal compliance audit must be conducted at the plant at least once every 3 years for the chlorine, sulfur dioxide, and propane processes. A team that includes at least one person knowledgeable in the covered processes and an audit leader knowledgeable in RMP/PSM requirements and audit techniques will conduct the audits. Plant management and the audit team will promptly determine an appropriate corrective action for each deficiency identified during the audit and document the corrective actions  
and the dates by which they must be taken. 
Emergency Response Program 
The Emergency Response Program develops a plan for dealing with a release. OSHA Process Safety Management regulation 29 CFR 1910.119(n) and EPA RMP regulation 40 CFR 68 Subpart E require that an Accidental Release Emergency Response Plan be prepared. The plan must be prepared in accordance with the provisions of another overlapping OSHA regulation-Employee Emergency Plans (29 CFR 1910.38(a)). In addition, provisions of the OSHA hazardous waste and emergency response standard, 29 CFR 1910.120 (q), must also be considered. The Emergency Planning and Response Plan described in this section complies with the requirements of 40 CFR 68.95, 29 CFR 1910.38(a), and 29 CFR 1910.120(q).  
The Emergency Planning and Response plan provides specific emergency response procedures for accidental releases of chlorine or sulfur dioxide. The emergency response procedures cover a release from the initial alarm stage through either leak s 
toppage or assistance from an outside hazardous materials response team.  As part of the emergency response procedures there are plans for victim rescue, leak investigation, and communication with additional support agencies. The Emergency Planning and Response plan also indicates the level of training needed to carryout the emergency response procedures.  
Information regarding self-contained breathing apparatus is also provided in the Emergency Planning and Response plan. It also addresses plant site communication, emergency response equipment, first aid and medical treatment, medical surveillance and consultation, and emergency response drills. 
The Seneca Plant personnel have been in contact with emergency personnel in the surrounding jurisdictions. These individuals are aware of the chemicals stored and used on site, and have included this information when developing emergency plans for areas impacted off site. 
In conclusion, the Seneca Plant has taken all necessary steps to prevent 
the release of hazardous chemicals that may harm facility staff or the surrounding public.  
SENECA WASTEWATER TREATMENT PLANT     
EXECUTIVE SUMMARY    RISK MANAGEMENT PROGRAM 
 
 
 
 
06/17/99    ES-2 
 
06/17/99    ES-1
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