Water Treatment Plant - Executive Summary |
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Executive Summary This document was developed to comply with the Environmental Protection Agency's (EPA's) Risk Management Program, under Section 112 (r) of the Clean Air Act (CAA) Amendments of 1990, 40 CFR Part 68. An outline of the Risk Management Program is provided in Figure ES-1. Because the City of Monroe stores and uses in excess of the threshold quantity of chlorine at the water treatment plant (WTP), this process is covered under this regulation. The technical information herein may be used as a training reference in initial and recurring operator and maintenance training. Training on process fundamentals, operations, and maintenance, coupled with the recommended process modifications discussed below, will reduce the potential hazards to plant personnel and the surrounding community. An Emergency Response Program and an Incident Investigation Program are included. These two programs should be an integral part of both initial and recurring training. A Risk Management Pla n (RMP), in the format required by the EPA, is included at the end of the main body of this document. It consists of a summary of data elements as required by EPA for inclusion in a public access database. The RMP is intended to inform the public of the City of Monroe's proactive stance toward protection of the environment and the surrounding community. E.1 Hazard Assessment The Hazard Assessment is comprised of a Worst Case and Alternative Release Scenario for the chlorine system, as well as a 5-Year Accident History for the same. The Hazard Assessment was conducted as an initial screening procedure as part of determining which Program Level (I, II, or III) the WTP falls. Residences lie within the EPA-defined endpoint concentrations of the plant's Worst-Case releases, therefore, the plant is ineligible for Program I. The WTP is operated by public personnel and therefore excluded from Program III. The WTP is included in Risk Management Program II. Worst Case Release Scenario Th e Worst Case Scenario is defined as a ton container (2,000 pounds) of chlorine being released by a catastrophic event within a 10 minute duration. Because the building in which the chlorine is housed is not provided with a solid door or any other containment, no mitigation factor is taken for the structure. This scenario was developed using the EPA Offsite Consequence Analysis Guidance document. The distance to the toxic endpoint for a chlorine release was determined to be 4.49 miles for the location on the plant site impacting a total of 14,738 people. For the worst case release scenarios, public receptors include: residences, hospitals, recreation areas, schools, business and commercial areas. Alternative Release Scenario The Alternative Release Scenario for chlorine was also determined using the EPA Offsite Consequence Analysis Guidance document. The alternative release scenario for each of the chlorine system assumed a valve failure on the tank resulting in a 60 minute release of a total chlorine quantity of 697 pounds. The distance to the toxic endpoint for the chlorine alternative release scenarios was 1.77 miles impacting approximately 2,290 people. E.2 5-Year Accident History There have been no reportable releases within the past five years at the facility. E.3 Management Program A Document Management System was established to attribute responsibility for the development, implementation, and maintenance of the Risk Management Program. The Program must be updated every three years, or any time a covered process undergoes a physical or administrative modification. The Document Management System is largely the responsibility of the Risk Management Program Team lead by the Plant Superintendent. The Risk Management Team consist of one operator, one maintenance person, and the Plant Superintendent. The Plant Superintendent has the ultimate responsibility. E.4 Prevention Program The Accidental Release Prevention Program is comprised of Safety Info rmation, Hazard Review, Operating Procedures, Training, Maintenance, Incident Investigation, and Compliance Audit procedures. Chemical Safety Information Comprehensive chemical data is provided in this section to include: health hazard and chemical exposure limitations as well as physical properties of chlorine. This information was compiled from numerous sources and is intended to be a one-stop source for the reader seeking data on this compound. The physical data will provide useful information in the inevitable event the plant process is modified, thereby requiring revisited dense gas dispersion. It is also imperative that plant operators and managers are appraised of the potential health hazards and exposure limits associated with chlorine stored on the plant site. Process Safety Information Basic specifications on each process are included in this document for easy reference. Details such as Maximum Intended Inventory, Safe Upper and Lower Temperatures, Safe Upper and Lower Pressures, and Codes and Standards Used to Design, Build and Operate the Process are provided in this section. Used as a training reference, together with the Process Schematics, the reader will readily understand the function and operation of the plant chlorine system. Hazard Review A Hazard Review was also conducted for the chlorine system. The Hazard Review technique used was a "What If" analysis. The "What If" was developed from experience at similar chlorine system. The Hazard Review team consisted of plant management, plant operations, and an outside process design engineers knowledgeable in the Hazard Review process. Recommendations The result of the Hazard Review is a set of recommendations for the plant to implement. Rule 40 CFR 68.50 requires the City of Monroe to ensure that problems identified are "resolved in a timely manner." For those items that can not be promptly resolved, it is recommended that a schedule be developed that addresses those issues, with responsi bility for each assigned to the appropriate personnel. The recommendations were developed by the Hazard Review Team with a consensus from all team members. Recommendations are summarized below: 1. Provide labeling on valves throughout the chlorine system. 2. Install wind socks at the facility. 3. Install an emergency shower and eye wash system near the chlorine room 4. Upgrade the leak detection and alarm systems to provide better warning. 5. Conduct an emergency response drill with the Fire Department. 6. Plug the drains in the chlorine room with removable plugs 7. Inspect chlorine containers prior to them being off loaded from the delivery truck 8. Relocate the SCBA to a location uphill from the building 9. Install a door sweep from the chlorine room to the remaining plant building 10. Post a sign at the plant entrance requiring visitors and vendors to sign in prior to working at the plant. Operating Procedures Basic chlorine system operating procedures have been developed and documented for the facility. They provide system descriptions, specifications, and operating procedures for the chlorine gas system. Procedures include Start-up, Shutdown, Normal, Abnormal, and Emergency Operation. Training Training is required by the EPA to be included in the Risk Management Program. Training Record Forms are included with the Program for the required documentation. Maintenance Basic chlorine system maintenance procedures have been developed with associated documentation forms. Sound preventive maintenance will reduce potential hazards to personnel onsite, as well as to the off-site public. In the event of an inspection or compliance review, state and federal regulators will request to see documentation and record keeping associated with the Maintenance Program. Incident Investigation An Incident Investigation Program has also been developed. The EPA has established strict guidelines to follow in the aftermath of any release involving the chlorine system. The Incident Investigation Program outlines key milestones that must be accomplished within 24 hours of any covered incident, and the actions that must occur subsequently. Ultimately, it is desired that the plant learns from the incident and takes action to prevent similar incidents in the future. Incident Investigation Report Forms are included, and must be maintained for a minimum of five years after each incident. Compliance Audits Internal Compliance Audits must be conducted every three years to verify compliance with the programs and procedures contained in this document. The Plant Manager must certify that the Risk Management Program team has evaluated compliance with the provisions of the Program, and verify that the procedures and practices are adequate and are being followed. Audit Report Forms are provided, the two most recent of which must always be maintained. This means that in the year 2006, the Compliance Audit Report for the year 2000 may be discarde d. E.5 Emergency Response Program The Emergency Response Program is included as part of the Risk Management Program in case a significant release ever occurs. As in all the above programs, it is important to review this program regularly. The Rule, 40 CFR 68.95 requires training for all employees "in relevant procedures" of the Emergency Response Program. It is recommended that training on the specific plant safety procedures take place upon initial employment and every year thereafter, as with most of the other RMP training programs. The City has elected to allow the City of Monroe Fire Department to address all major releases at the plant site. Minor releases will be handled by the plant staff. E.6 Summary of Action Items 1. The RMP Rule, 40 CFR 68.42 requires that details of all accidental releases be recorded from this date forward. 2. The RMP Rule, 40 CFR 68.15 requires that the Document Management System (e.g., the RMP Team) be updated anytime personnel changes or ad ministrative changes are made that would affect the lines of authority or responsibility for maintaining the RMP. 3. The RMP Rule, 40 CFR 68.54 requires that each employee presently operating a process, and each employee newly assigned to a covered process be trained or tested competent in the operating procedures. As an alternative, the City may certify in writing that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as provided in the operating procedures. Training documentation forms will be recorded and filed at the plant site. 4. The RMP Rule, 40 CFR 68.56 requires training on the plant maintenance procedures. The City of Monroe must train or cause to be trained each employee involved in maintaining the on-going mechanical integrity of the process. To ensure that the employee can perform the job tasks in a safe manner, each such employee must be trained in the hazards of the process, in how to avoid or cor rect unsafe conditions, and in the procedures applicable to the employee's job tasks. Refresher training on operating and maintenance procedures must be provided every three years. 5. The RMP Rule, 40 CFR 68.60 requires incident investigations no later than 24 hours following each incident. 6. The RMP Rule, 40 CFR 68.58 requires the City to certify compliance with RMP Accident Prevention Program provisions at least every three years to verify that the procedures and practices developed under the rule are adequate and are being followed. 7. The Rule, 40 CFR 68.95 requires training for all employees "in relevant procedures" of the Emergency Response Program. It is recommended that training on the specific plant procedures take place upon initial employment and every year thereafter, as with most of the other RMP training programs. |