Mountianburg Water Treatment Facility - Executive Summary |
|
1.0 Accidental Release Prevention and Emergency Response Policies The City of Fort Smith's Mountainburg Water Treatment Plant is committed to the safety of our workers, the public, and the environment. This commitment is demonstrated by the resources invested in the prevention of accidental releases of hazardous substances. The City of Fort Smith's Mountainburg Water Treatment Plant implements reasonable controls, such as training of personnel and the safe design, installation, operation and maintenance of our processes. Our policy is to make every effort to prevent the release of hazardous substance but in the event of a release, our trained personnel and local emergency response agencies will respond to control and contain the release in a manner that will be safe for workers and will help prevent injuries to the public or the environment. 2.0 Description of the City of Fort Smith's Mountainburg Water Treatment Plant and Regulated Substances The City of Fort Smith's Mounta inburg Water Treatment Plant is located within the city limits of Mountainburg, Arkansas. The facility is part of the City of Fort Smith's water distribution system which has 13 contract customers and services an area with a population of over 150,000 people. The City of Fort Smith's Mountainburg Water Treatment Plant handles one substance regulated by the Risk Management Program Rule (RMP Rule) in quantities above the Threshold Quantity. This substance is: * Chlorine - stored in 1 ton cylinders and used for the disinfection of the water treated and distributed to our customers. 3.0 Hazard Assessment The RMP Rule requires The City of Fort Smith's Mountainburg Water Treatment Plant to perform a Hazard Assessment of the chlorine stored and used in the chlorination process at the facility. This Hazard Assessment includes an offsite consequence analysis for the following scenarios: * One worst-case and one alternative release scenario for the toxic substance chlorine for t he chlorination process unit at the facility. The following information summarizes these offsite consequence analyses. 3.1 Chlorination Process The worst-case scenario for toxic substances is the failure of a 1 ton cylinder of liquid chlorine. The toxic cloud formed by the evaporating chlorine would reach off-site endpoints and public receptors. The alternative release scenario for chlorine is a cylinder valve sticking in the open position allowing a sixty minute release of chlorine gas. The toxic cloud formed by the escaping gas would reach offsite endpoints and public receptors. 4.0 Accidental Release Prevention Program and Chemical-Specific Prevention Steps The RMP Rule requires that a prevention program be established for the City of Fort Smith's Mountainburg Water Treatment Plant chlorination process. The following details the prevention program elements at the City of Fort Smith's Mountainburg Water Treatment Plant that apply to these processes. 4.1 Safety Information The City of Fort Smith's Mountainburg Water Treatment Plant maintains a variety of technical documents that are used to help ensure safe operation of the City of Fort Smith's Mountainburg Water Treatment Plant processes. Material safety data sheets (MSDSs) document the physical and chemical properties of hazardous substances handled at the City of Fort Smith's Mountainburg Water Treatment Plant, including the chlorine in the covered processes. The engineering design documents include the operating parameters, the design basis and configuration of the equipment in each covered process, and references to applicable codes and standards. 4.2 Hazard Review The City of Fort Smith's Mountainburg Water Treatment Plant performs and periodically updates hazard reviews of the covered processes to help identify and control process hazards. Checklists are used to guide the hazard review. These checklists include items to help ensure the City of Fort Smith's Mountainburg Water Treatment Plan t operates and maintains the equipment in a manner consistent with the applicable design specifications, codes, standards, and regulations. 4.3 Operating Procedures The City of Fort Smith's Mountainburg Water Treatment Plant develops and maintains operating procedures to define how tasks related to process operations should be performed. The operating procedures are used to: 1. train employees and contractors, and 2. serve as reference guides for appropriate actions to take during both normal and abnormal process conditions. 4.4 Training The City of Fort Smith's Mountainburg Water Treatment Plant trains personnel in the operating procedures to help ensure safe and effective performance of their assigned tasks. A record of all training is maintained to help ensure new and refresher training is provided on a timely basis. 4.5 Maintenance The City of Fort Smith's Mountainburg Water Treatment Plant properly maintains the equipment in our processes. The City of Fort Smith's Mount ainburg Water Treatment Plant maintenance program includes: 1. procedures to safely guide workers in their maintenance tasks, 2. worker training in the maintenance procedures, and 3. an inspection and testing program to help identify equipment deterioration and damage before equipment fails. 4.6 Compliance Audits The City of Fort Smith's Mountainburg Water Treatment Plant performs periodic (at least every three years) audits of covered processes to verify the processes are operating in compliance with the requirements of the RMP Rule. A compliance audit report is prepared after each audit, and any deficiencies noted by the audit are corrected in a timely manner. 4.7 Incident Investigations The City of Fort Smith's Mountainburg Water Treatment Plant investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment. The City of Fort Smith's Mountainburg Water Treatment Plant trains employees to identify and report any a nd all incidents requiring investigation. An investigation team is assembled and the investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved, and appropriate process enhancements are implemented. 4.8 Chemical-specific Prevention Steps - Chlorine Industry standards are followed at The City of Fort Smith's Mountainburg Water Treatment Plant to help ensure safe handling of chlorine. The vendor supplies chlorine via a Department of Transportation (DOT) approved truck and in DOT approved 1 ton cylinders. The chlorination process equipment is designed and constructed with state-of-the-art materials and technology utilizing the standards and guidelines of the Chlorine Institute, American Water Works Association, ASME, ANSI, and other applicable codes. Workers who perform operations involving chlorine receive training emphasizing safe handling procedures according to the guidelines required by the City of Fort Smith's Mountainburg Water Treatment Plant. The City of Fort Smith's Mountainburg Water Treatment Plant has a state of the art chlorine scrubber system which is designed to capture chlorine released in the chlorine storage area and chlorination room. The scrubber system is activated when chlorine detectors in the building detect a release of chlorine and prevents the gas from escaping the building. 5.0 Five Year Accident History The City of Fort Smith's Mountainburg Water Treatment Plant compiled a five-year accident history that fulfills the requirements of the RMP Rule. This history indicates a good record of accidental release prevention over the past five years. No releases of regulated substances have occurred from the City of Fort Smith's Mountainburg Water Treatment Plant that have resulted in offsite consequences - injuries to the public or impacts on the environment. Minor releases have occurred during loading and unloading procedures and maintenance activities wi th no injuries occurring to the City of Fort Smith's Mountainburg Water Treatment Plant employees. 6.0 Emergency Response Programs The City of Fort Smith's Mountainburg Water Treatment Plant has prepared a written emergency response plan that complies with the RMP Rule, other federal standards and industry guidelines. This plan has been communicated to the Local Emergency Planning Committee (LEPC) and local fire department. The City of Fort Smith's Mountainburg Water Treatment Plant periodically conducts emergency drills to test our emergency plan and coordinate these drills with the local fire department. 7.0 Planned Changes to Improve Safety The City of Fort Smith's Mountainburg Water Treatment Plant continuously attempts to improve the safety of our processes to protect our employee, the public and the environment. The City of Fort Smith's Mountainburg Water Treatment Plant incident investigations, employee suggestions and improvements in technology are utilized to update the safety aspects of the processes. The following changes to improve process safety are planned or have recently been completed. 1. Implement a chlorine shipment Quality Assurance Program to aid in the inspection of chlorine cylinders when received, and 2. Implement a preventive maintenance program for the hoists used to move chlorine cylinders. |