City of Vero Beach Waste Water Treatment Plant - Executive Summary |
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CITY OF VERO BEACH WASTE WATER TREATMENT PLANT RISK MANAGEMENT PLAN EXECUTIVE SUMMARY 1. Corporate Prevention and Emergency Response Approach The City of Vero Beach Waste Water Treatment Plant (Vero Beach) is owned by Vero Beach. The facility has developed and maintains accident prevention programs and an emergency response plan to prevent and mitigate the effects of hazardous chemical releases. 2. Description of Stationary Source The Vero Beach WWTP is a Waste Water Treament facility located on the Intracoastal Waterwayat 17-17th Street, east of downtown Vero Beach, Indian River County, Florida. Vero Beach uses chlorine as a disinfectant for sewage treatment process. They also use sulfur dioxide when needed to remove excess chlorine from water to be released into adjacent waterways. Liquefied chlorine gas is stored in up to ten one-ton containers at the Chlorination process. Four containers are always connected to the process, while up to six additional containers are st ored adjacent to the connected containers. The total chlorine inventory in the process at any one time is 20,000 lbs. This is greater than the 2,500 lb. RMP threshold quantity for chlorine. This process is not enclosed in a building. Liquefied sulfur dioxide gas is stored in up to three one-ton containers at the Dechlorination process. Two one-ton containers are always connected to the process, while one is stored adjacent to the connected containers. The total sulfur dioxide inventory in the process at any one time is 6,000 lbs. This is greater than the 5000 lb. RMP threshold quantity for sulfur dioxide. This process is not enclosed in a building. 3. Description of the Worst Case and Alternative Release Scenarios The Worst Case release scenario is the rupture of a ton container from the Dechlorination process, releasing 2,000 lbs. of Sulfur Dioxide gas over a ten minute period. Under worst case weather conditions, the sulfur dioxide gas could travel 3.1 miles before disp ersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .0078 mg/L), using the WWTP Guidance lookup tables. Since there are two RMP covered processes at the Vero Beach WWTP, two alternative release scenarios are required to be reported. Both Alternative Release Scenarios are characterized by a two phase release due the failure of the liquid supply valve connection from worker/human error, external impact, or corrosion. For the chlorination (Chlorine) process, the release rate was determined to be 1,387 lbs/min. Under normally expected weather conditions, the chlorination process chlorine gas could travel 1.5 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .0087 mg/L). For the dechlorination (sulfur dioxide) process, the release rate was determined to be 892.4 lbs/min. Under normally expected weather conditions, the Dechlorination process sulfur dioxide gas could travel 1.4 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .0078 mg/L), using the WWTP Guidance. 4. Prevention Program For both Chlorination and Dechlorination processes, this facility exceeds the chlorine and sulfur dioxide threshold quantity for the OSHA Process Safety Management (PSM) Standard, 1910.119, and is therefore subject to the PSM requirements. For RMP compliance purposes, this places both of the Vero Beach Chlorination and Dechlorination processes in the Program 3 level. The Vero Beach facility will use its PSM program as the required Program 3 Prevention Program. Vero Beach has a program in place to comply with the OSHA Process Safety Management Standard, 29 CFR 1910.119. To ensure that all requirements of the RMP regulation were met, the PSM Program was reviewed and updated in 1999. The PSM Program includes written operating procedures for the chlorination and dechlorination process es. These procedures cover all phases of operation and include information on worker protection. These procedures will be used to train all operators and mechanics who work on the chlorination and dechlorination processes to ensure consistency of operation and minimize human error. The PSM Program also includes a preventative maintenance plan which requires all chlorination and dechlorination equipment to be periodically inspected and serviced. This will ensure that the equipment remains in good operating condition and will minimize the probability of accidents due to faulty equipment. Safe work practices, such as Lockout/Tagout and Hot Work Permit, have long been required by the City of Vero Beach. These were reviewed and updated to ensure that all non-routine work can be performed safely. Other components of the Prevention Program include the collection and review of all equipment information and the development of updated Piping & Instrumentation Diagrams (P&IDs). These act ions will ensure that the equipment meets all chlorination and wastewater industry standards and that accurate equipment information will be available when needed. The staff also performed a Process Hazard Analysis of each process. Other PSM procedures, including Management of Change, Pre-Startup Safety Review, Compliance Audits, and Incident Investigation have also been incorporated into this program to ensure continued safe operation and prompt correction of deficiencies. The PSM Program receives full support of plant management and involvement of employees at all levels. 5. Accident History The Vero Beach facility has had no accidental releases of chlorine or sulfur dioxide in the past five years. 6. Emergency Response Program The Vero Beach WWTP has an Emergency Response Plan in place. The program complies with 29 CFR 1910.38. The site also has some internal emergency response capability and has a procedure for addressing small releases of chlorine and sulfur dioxide. The current plan has been coordinated with the Indian River County Fire Department, and the Regional Local Emergency Planning Committee. Notification is made locally by dialing 911 and by notifying Florida State Warning Point at (800) 320-0519. |