Hillview Reservoir - Executive Summary |
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New York City Department of Environmental Protection (NYCDEP) uses chlorine to meet the New York State Sanitary Code and federal Safe Drinking Water Act disinfection requirements. Hillview Reservoir is one of the locations where some of the City's water is treated with chlorine. New York City DEP is committed to protecting the public, its employees, and the environment from any accidental releases of hazardous materials used at its facilities. We have implemented safety, environmental protection, and risk management programs to prevent hazardous materials releases. If there is an accidental release, we will immediately call for emergency response to minimize the effect of the release and notify the public of any actions necessary to ensure public protection, through county & City emergency management agencies. Worst-Case Release Scenario The NYCDEP has conducted an offsite consequence analysis as required by the regulations, including an extremely unlikely worst-case release sce nario (i.e., total release from the single largest container over a ten minute period and assuming worst case meteorological conditions). Results of this worst-case indicate that offsite receptors would be affected. A release represented by this worst-case scenario is extremely unlikely because of the robust design of chlorine containers (they are designed to withstand transportation mishaps) and the rigorous maintenance and prevention programs in place at the Hillview Reservoir Facility. In fact, release reporting databases and water industry experience suggest that the worst-case release scenario as defined in the RMP regulations is so unlikely that it should not be used as the basis for emergency planning. A more reasonable potential release scenario for emergency planning is presented in "The alternative release scenario(s)" section below. Alternative Release Scenario A "credible worst-case" scenario, formulated in accordance with USEPA guidance, was selected as the Hil lview Reservoir alternative release scenario. This scenario assumes that the liquid chlorine header connected to the container is completely severed and chlorine is released over a ten-minute period. Results of this credible worst-case event indicate that offsite receptors could be affected. The results of the process hazard analysis (PHA) and the facility's operating history suggest that even this credible worst-case is extremely unlikely to occur, but it can serve as the basis for emergency planning. Accidental Release Prevention Steps NYCDEP is committed to personnel safety, public safety, continued reliable operation and regulatory compliance. Based on this commitment, an individual, designated as the RMP Responsible Manager, has assumed overall responsibility for the development and implementation of the Risk Management Program. The RMP Responsible Manager has also clearly defined accountability and responsibility for each of the prevention program elements to meet both EPA and OSHA Process Safety Management requirements. To ensure that a worst-case or alternative release scenario does not occur, the NYC DEP maintains a release prevention program with the primary focus of protecting plant employees and the public from the hazards associated with an accident or release involving chlorine. The multifaceted program includes the use of: Chlorine detectors and alarms to rapidly alert operators to any problems; Process Safety Information to document the safe process design; Process Hazards Analyses to evaluate the chemical and process hazards; Operating Procedures to ensure that the system is operated safely; Maintenance, inspection and testing to ensure that the system is maintained according to applicable standards and manufacturer's recommendations; Training, hot work permits, contractor safety and employee participation programs to ensure that all employees and contractors working on and around the processes are aware of the hazards, can perform the ir job duties safely and know the actions to be taken in an emergency; Management of Change and Pre-startup Safety Reviews to ensure that changes are documented, analyzed and kept within the design basis; Incident Investigation procedure to investigate each incident and "near misses" to determine root causes and make needed safety improvements; and, Pperiodic compliance audits to ensure that our programs are working as they should to protect both employees and the public. Five-Year Accident History Within the past five years, the Hillview Reservoir Facility not had any accidental releases that resulted in injuries or property damage. The plant has maintained an excellent safety record throughout its operating history and has never had a major chlorine release that could have had adverse effects on the public. Emergency Response In the event that a chlorine release does occur, the Hillview Reservoir Facility has an emergency response program that coordinates emergency response with the Fire Department. If such a release did occur, plant personnel would contact the Fire Department who would dispatch a trained HAZMAT team to the site to handle the chlorine release. Maintaining A Safe Operation The NYCDEP continually works to safely manage the hazards of chlorine to protect employees and the community we serve. The Risk Management Program will be maintained to reduce the risk of accidental releases and each year we will conduct training, review procedures, maintain the equipment and follow safe work practices. Periodically, we will audit our program, review our Process Hazard Analysis and coordinate with the community emergency response organization. Althought the chance of any chlorine release at the Hillview Reservoir Facility is remote, NYCDEP has decided to move to the use of sodium hypochlorite for disinfection. Sodium hypochlorite is less hazardous than chlorine and would further reduce any possible risk. This change requires significant facility mo difications as well as increased costs and will be implemented over a number of years. |