Lawson Fork Wastewater Treament Plant - Executive Summary |
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EXECUTIVE SUMMARY FOR LAWSON FORK WASTEWATER TREATMENT PLANT ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Spartanburg Sanitary Sewer District's accidental release prevention and emergency response policies show that the Lawson Fork Wastewater Treatment Plant is strongly committed to employee, public and environmental safety and adheres to all applicable regulations. The comprehensive accidental release prevention program covers areas such as safety, hazard analysis, operating procedures, maintenance and employee training associated with the processes at the facility. The effective emergency response plan covers response procedures such as pre-emergency employee training, lines of authority, emergency recognition, evacuation routes and procedures and emergency medical treatment. It is Spartanburg Sanitary Sewer District's policy to implement appropriate measures to prevent possible releases of regulated substances. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDL ED The Lawson Fork Wastewater Treatment Plant has two (2) regulated substances at the facility above the substance's threshold quantity. One regulated substance is chlorine with a threshold quantity of 2,500 lb. Chlorine is used in the wastewater treatment process at the facility. Chlorine is handled in one ton cylinders and the maximum amount handled is 28,000 pounds. The other regulated substance is sulfur dioxide with a threshold quantity of 5,000 lb. Sulfur dioxide is used in the wastewater treatment process at the facility. Sulfur dioxide is also handled in one ton cylinders and the maximum amount handled is 8,000 pounds. Spartanburg Sanitary Sewer District is mandated to meet Program 3 requirements. HAZARD ASSESSMENT The offsite consequence analysis includes consideration of two different types of release scenarios, identified as "worst case release" and "alternative scenario". The worst case release scenario is defined by EPA as a release of the largest storage vessel over a ten (10) minute period due to an unspecified failure. One worst case release is required to be reported for all regulated toxic substances. Therefore, chlorine is reported as the worst case release scenario since it resulted in a greater offsite distance than the worst case release of sulfur dioxide. The alternative release is defined by EPA as a release that is more likely to occur than the worst case release. One alternative release scenario is required to be reported for each regulated toxic substance. Therefore, one alternative release is reported for chlorine and one alternative release is reported for sulfur dioxide. Spartanburg Sanitary Sewer District chose DEGADIS+ to perform the air dispersion consequence modeling due to the nature of the chemical and the release scenarios. The worst case release scenario involves a catastrophic release from a one ton cylinder (2,000 lb.) of chlorine in a gaseous form over 10 minutes. The worst case release rate would be 200 lb/m in. The worst case release was analyzed at Class F atmospheric stability, 1.5 m/s wind speed, 100 F, 71% humidity and 0.1 m surface roughness for the maximum distance to the toxic endpoint of 0.0087 mg/L (3 ppm). The worst case release resulted in offsite impact. The alternative release scenario for chlorine involves a break in the one(1) inch feed line for the Purifax system which would result in the release of liquid chlorine. The failure released the entire contents of a one (1) ton (2,000 pounds) cylinder of chlorine in a liquid form. The calculated alternative release rate would be 115.3 lb/min which differs from the one reported in the RMPlan because EPA requested the release rate to be reported to one significant digit in the RMPlan. The alternative release scenario was analyzed at Class D atmospheric stability, 3.0 m/s wind speed, 59.9 F, 71% humidity and 0.1 m surface roughness for the maximum distance to the toxic endpoint of 0.0087 mg/L (3 ppm). The alternative releas e for chlorine resulted in offsite impact. The alternative release scenario for sulfur dioxide involves a fusible plug failure on a one ton cylinder (2,000 lb.) resulting in the release of gas through the 3/4-inch opening. The fusible plug failure released the entire contents of sulfur dioxide in a gaseous form. The calculated alternative release rate would be 28.7 lb/min which differs from the one reported in the RMPlan because EPA requested the release rate to be reported to one significant digit in the RMPlan. The alternative release scenario was analyzed at Class D atmospheric stability, 3.0 m/s wind speed, 59.9 F, 71% humidity and 0.1 m surface roughness for the maximum distance to the toxic endpoint of 0.0078 mg/L (3 ppm). The alternative release for sulfur dioxide resulted in offsite impact. The alternative releases are much more likely to occur at the facility than the worst case release scenario. The worst case release is unrealistic because at that high of a release ra te, the chlorine will most likely freeze over the hole in the container which will prohibit more chlorine gas from escaping. It is not appropriate to compare a 10 minute release to a one hour exposure time standard. The toxic endpoint concentration is based on a one hour exposure time, while the worst case release occurs over a ten minute period. Therefore, the ten minute release period is used as the averaging time instead of one hour exposure time. Realistically, if a person can withstand a certain concentration over a one hour period with no health effects, they could withstand a higher concentration over a ten minute period. One solution would be to adjust the toxic endpoint value to correlate to the ten minute exposure during a worst case release instead of the one hour standard. However, there is no allowance in the RMP rule by the EPA to make this adjustment. ACCIDENTAL RELEASE PREVENTION AND CHEMICAL SPECIFIC PREVENTION Spartanburg Sanitary Sewer District has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The process is subject to the OSHA PSM standard under 29 CFR 1910.119 and is already in compliance. The following steps are key to the prevention program: 1. Detailed records of safety information describing the chemical hazards of chlorine, process technology, and process equipment. 2. Comprehensive process hazard analysis are conducted to ensure that hazards are recognized and evaluated. 3. Operating procedures have been developed and implemented which describe tasks to be preformed, dates to be recorded, operating conditions to be maintained, emergency operating procedures and safety and health precautions to be taken. 4. Employee training program is in effect to ensure that the employees of the Lawson Fork Wastewater Treatment Plant are properly trained and aware of all safety practices, hazards, emergency procedures and maintenance procedures. 5. An on-goin g mechanical integrity program is in place to ensure safe process operation. 6. Incident investigation procedures are in place to ensure that all unplanned events affecting process safety are properly investigated in a timely manner to identify the causes of the incident and to implement corrective action. FIVE-YEAR ACCIDENT HISTORY The Lawson Fork Wastewater Treatment Plant has had an excellent record of preventing accidental releases over the last five years. Due to the effective release prevention policies, there have been no accidental release during the last five years. EMERGENCY RESPONSE PLAN The Lawson Fork Wastewater Treatment Plant has a written emergency response plan to deal with accidental releases of chlorine and other hazardous materials, which has been coordinated with the local emergency response personnel. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, and notification of local emergency respons e agencies and the public. PLANNED CHANGES TO IMPROVED SAFETY The last Process Safety Hazard Analysis was performed in XX 199X and it resulted in XXX recommended changes at that time. |