City of Sanford Water Treatment Plant - Executive Summary

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City of Sanford 
 
RMP Executive Summary 
 
The City has implemented a comprehensive program to safely manage chlorine at its water treatment plant and chlorine and sulfur dioxide at its wastewater treatment plants located outside the city. There have been no chlorine or sulfur dioxide incidents in the most recent five-year history period. 
 
In 1994, a Hazardous Chemical Handling Team manual was prepared to safely address handling hazardous chemicals at the Big Buffalo Wastewater Treatment Plant (chlorine and sulfur dioxide) and the Water Treatment Plant (chlorine). The information in this manual includes: 
 
- Written standard operating procedures 
 
- Emergency response procedures 
 
- Leak investigation procedures 
 
- A Chlorine training program including respiratory protection 
 
- Chlorine safety information 
 
 
In 1999, these additional steps were implemented to complete all requirements for the EPA Risk Management Program. 
 
- Conducting  Process Hazards Analyses for the three chlorine processes 
 
 
-Updating and expanding the Standard Operating Procedures for Chlorine and Sulfur Dioxide Management 
 
- Providing procedures for Management of Change, Incident Investigation and Employee Participation.     
 
- Expanding the Emergency Response Plan to include offsite response and first aid information 
 
- Revising the site maintenance program to include all chlorine and sulfur dioxide critical equipment. 
 
- Developing Process and Instrumentation Drawings (P&ID) for all processes. 
 
- Conducting refresher training in support of the certification of operators. 
 
- Conducting a Self Audit. 
 
The supervisor, chief operator and several plant operators are meeting several times per year to review and update procedures and to maintain compliance with all aspects of the RMP regulation. 
 
In addition to RMP compliance, the chlorine and sulfur dioxide delivery systems at the plants have been upgraded to vacuum processes over the past 10 years. This process has proven to greatly reduce leaks by re 
ducing the amount of equipment that is exposed to pressurized chlorine. 
 
To further understand chlorine risks, a consulting firm was contracted to conduct "Offsite Consequence" Modeling Analysis, as required by EPA's Risk Management Program. Both a "Worst Case" and an "Alternative Case" chlorine release scenarios were studied for each site. 
 
The "Worst Case" modeling showed the potential impact of a full, 2000 pound cylinder of chlorine released in 10 minutes. This resulting chlorine and sulfur dioxide plumes extended  0.9. miles for both plants. For the "Alternative Case", a more typical possible release of 60 pounds, 3 pounds/minute for 60 minutes, was modeled. The modeling indicated that a plume extending 0.1 miles would result. 
 
The results showed that the risk of offsite chlorine or sulfur dioxide exposure is low due to the favorable location of the plants. 
 
The Big Buffalo Wastewater Treatment Plant is located north of the town. All chlorine and sulfur dioxide is stored inside a  
building. This location will assist in any emergency by initially containing any leak. Also, due to the topography and location of the plant, the most likely scenario would be for the chlorine or sulfur dioxide (both heavier-than-air gases) to fall to the Deep River and follow the river until the chlorine cloud disperses. In addition, the area surrounding the plant is heavily forested. This fact will also significant assist to contain any leak. Thus, a chlorine or sulfur dioxide release should result in no to minimum public exposure. 
 
-The Water Treatment Plant is located east of the town. All chlorine is stored inside a building. This location will assist in any emergency by initially containing a chlorine leak. The local typography at the site favors the containment of any leak. Any release would be directed to the Cape Fear  and be contained until dispersed. Also, the site  has a large green belt that will contain small to medium ( up to 100 pounds) leaks on site. Thus, the impact o 
f a chlorine release from this facility would be small to insignificant to the public. 
 
In addition to Risk Management Compliance, the organization has an active safety program. The City has an active Safety Committee. The committee meets monthly and its duties include reviewing new safety procedures, accident investigations, safety surveys and safety communications. The Risk  Manager for the City also takes an active role in supporting the Utilities Safety Program.  
 
Within the Utilities department, there are monthly safety meetings to review an OSHA subject or discuss a safety issue. Routine training is conducted for topics such as: 
 
- Hazard Communications 
 
- Personal Protective Equipment 
 
- Lockout/Tagout 
 
- Confined Space 
 
As a result of our programs, the plants have had an excellent safety record with no recordable injuries over the past three years. As mentioned earlier, there have no reportable chlorine or sulfur dioxide releases from the plants in the last five years.  The cit 
y has worked extensively to upgrade its safety program. 
 
Report by:                                                               
 
Larry Thomas 
Director of Public Utilities
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