Orangeburg DPU Water Treatment Plant - Executive Summary
EXECUTIVE SUMMARY FOR ORANGEBURG DPU WATER TREATMENT PLANT |
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
The Orangeburg DPU's accidental release prevention and emergency response policies show that Orangeburg DPU 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 Orangeburg DPU's policy to implement appropriate measures to prevent possible releases of regulated substances.
STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED
Orangeburg DPU Water Treatment Plant has one (1) regulated substa
nce at the facility above the threshold quantity. The regulated substance is chlorine. Chlorine is used in the water treatment process. Chlorine is handled in one ton cylinders and the maximum amount of chlorine handled is 24,000 pounds. Orangeburg DPU is mandated to meet Program 3 requirements.
The offsite consequence analysis includes consideration of two chlorine release scenarios, identified as "worst case release scenario" and "alternative release 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. The alternative release scenario is defined by EPA as a release that is more likely to occur than the worst case release scenario. Orangeburg DPU 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 submitted for Orangeburg DPU involves a catas
trophic release from a one ton cylinder (2,000 lb.) of chlorine in a gaseous form over 10 minutes. The chlorine is stored in an enclosed building; therefore, passive mitigation was taken into account. The worst case release scenario was analyzed for a release rate of 110 lb/min, Class F atmospheric stability, 1.5 m/s wind speed, 102 F, 70% 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 scenario did result in offsite impact.
The alternative release scenario for chlorine involves a fusible plug failure in a one ton cylinder (2,000 lb.) of chlorine. The failure released the entire contents of chlorine in a gaseous form over 30 minutes. The chlorine is stored in an enclosed building; therefore, passive mitigation was taken into account. The alternative release scenario was analyzed for a release rate of 37.0 lb/min, Class D atmospheric stability, 3.0 m/s wind speed, 66 F, 75% humidity and 0.1 m surfa
ce roughness for the maximum distance to the toxic endpoint of 0.0087 mg/L (3 ppm). The alternative release scenario did result in offsite impact. However, the Orangeburg DPU is in the process of installing an emergency chlorine scrubber. The scrubber will eliminate all off-site impacts due to a chlorine release at the Water Treatment Plant. The emergency chlorine scrubber will be fully operational on June 25, 1999.
The alternative release scenario is much more likely to occur at the facility than the worst case release scenario. The worst case release scenario is unrealistic because when chlorine is released at such a high rate, the chlorine will most likely freeze over the opening in the cylinder which would prohibit more gas from escaping the cylinder. Also, it is not appropriate to compare a 10 minute release to a one hour standard. The toxic endpoint concentration is based on a one hour exposure time, while the worst case release scenario occurs over a ten minute period. T
herefore, 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 scenario 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
Orangeburg DPU 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 ch
lorine, 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 Water Treatment Plant are properly trained and aware of all safety practices, hazards, emergency procedures and maintenance procedures.
5. An on-going 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 Orangeburg DPU Water 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 Orangeburg DPU Water 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 City Department of Public Safety and Orangeburg County. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, and notification of local emergency response agencies and the public.
PLANNED CHANGES TO IMPROVED SAFETY
The last Process Hazard Analysis (PHA) was performed in November 1994 and it resulted in a few recommended changes at that time. As a result of the PHA, a new gas detector was installed, the chlorine emergency kit was repaired and a wind sock was installed.