D. B. Lee Wastewater Treatment Facility - Executive Summary |
1. EXECUTIVE SUMMARY 68.155 The City of Melbourne Utility Department (CMUD) operates the D. B. Lee Wastewater Treatment Facility (DBLWWTF) for the City of Melbourne, Florida (City). 1.1 Accidental Release Prevention And Emergency Response Policies (a) The City DBLWWTF accident prevention policy involves a unified approach that integrates technologies, procedures and management practices. The City's prevention program compiles with all applicable procedures of the U.S. Environmental Protection Agency (EPA) Risk Management Program (RMP) 40 CFR -68, Prevention Program. 1.1.1 Management System (A)(1) The City has a management system in place which oversees the implementation and on-going use of the RMP elements. This program, along with other policies, eliminates and/or reduces the likelihood of a chemical release at the facility. 1.1.2 Prevention Program Level 3 (A)(2) The City maintains policies, procedures and systems as part of their prevention program. The program addresses each of the EPA Program Level 3 listed elements and the elements needed to implement the RMP program. These are retained in the City's Document Control System (DCS). 1.2 The City's Stationary Source and Regulated Substance Handling. The City employs twent-five (25) employees at the facility and in field operations. Chlorine is used in the treatment process. 1.2.1 Site Description The facility has covered chlorine storage. The chlorine distribution system is contained in a process building. The boundaries of the chlorine system subject to the RMP regulation include the bulk chlorine storage and control building and associated vent and exhaust systems. 1.2.2 Regula ted Substance (b)(2) Chlorine is the only regulated substance on site which exceeds the EPA 40 CFR-68 rule threshold quantity. 1.3 Worst and Alternative Case Release Scenario's (c) The worst and anternate scenario's were evaluated using EPA guidance. 1.3.1 Worst Case The worst case scenario involves the total release of a one (1) ton container to the atmosphere. 1.3.2 Alternative Case (c)(2) The alternative release scenarion involves the failure of the yoke assembly regulator piping. The yoke assembly is the vacuum control system which is connected to the container outlet valve. 1.4 Accidental Release Prevention Program (d) The City's accidental release prevention program is based on OSHA's PSM and EPA's RMP Level 3 prevention program. The PSM program has been in place and effectively used for several years. It is part of the facility operating culture. There are two parts to the program. The first is the general overall site program. The second part is the chlorine-specific actions within the site program. The program is coordinated with the City's fire department. 1.4.1 General Accidental Release Prevention Program Facility-wide, many elements of the prevention program are used for all operations. 1.4.2 Chlorine Specific Response Program 1.4.2.1 Chlorine- Specific Policies and Procedures Chemical-specific prevention features at the facility include specific procedures for the operation of the chlorine system. 1.4.2.2 Facility Design The chlorine storage area and the chlorine process building are equipped with ambient ventilation and a fan ventilated control room respecti vely. 1.4.2.3 Equiptment Design The facility has high and low pressure pipe systems. 1.5 Five Year Accident History The City's DBLWWTF had no reportable releleases of chlorine in the past five years per EPA 40 CFR 67.42 (a) 1.6 Emergency Response Program (f) Emergency response procedures are contained in the City's Emergency Response Plan (ERP). The ERP is reviewed by the the Melbourne Fire Department, which coordinates with the Local Emergency Planning Committee (LEPC) and HazMat Team #3, Melbourne, Florida. 1.6.1 Personnel (F)(1) City employee's comprise the operations and emergency response teams. 1.7 Changes To Improve Safety Recommended actions were identified during the internal safety tour audit. The recommended actions have been evaluated by the City and inplemented as required. The City continually reviews implemented and potential safety improvements for all of its operations. Currently the City management team and process safety team are reviewing potential upgrades of the chlorine operations to make the system even safer and minimize consequences in the event of a release. |