R. Dwayne Huffman Reclaimed Water Plant - Executive Summary |
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Executive Summary 1. Accidental Release Prevention and Emergency Policies We at the R. Dwayne Huffman Reclaimed Water Plant are strongly committed to employee, public and environmental safety. The commitment is inherent to a compressive accidental release prevention program in place that covers areas of design, installation, operating procedures, maintenance, and employee training associated with the process at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforseseeably, if such a release does occur, we are completely coordinated with Port Orange Fire and Rescue, which provides highly trained emergency response personnel to control and mitigate the effects of the release. 2. The Stationary Source and the Regulated Substance to be handled. Our facility's primary activities encompass the treatment of domestic wastewater (sewage) from the community of Port Orange Fl.. The wastewater is biologically treated to meet strict criteria as mandated by our operating permit issued by the Florida DEP and then disenfected with chlorine before being recycled to the local residents of the city to be reused as lawn irrigation.Effluent wastewater may be discharged into the Halifax River, if public reuse demand is low. During these periods of river outfall discharge, Sulfur dioxide is used as a de-chlorinating agent. DEP permit states that we will not discharge water ino the river with any detectable chlorine residual in the discharge water. Therefore we store 2 regulated substances at our facility. (Chlorine and Sulfur Dioxide). 3. The Worst Case Release Scenario and The Alternative Release Scenario, Including Administration Controls and Mitigation Measures to Limit The Distance for each reported scenario. To perform the required offsite consequence analysis for our facility, we have used the RMP Comp software provided by EPA. The following paragraphs provide details of the chosen scenarios.The worst case scenario submitted for program 2 ansd 3 toxic substances as a class involves a castrophic release from chlorine. The scenario involves the release of 2000 lb of chlorine in a gaseous form over 10 minutes. At class F atmosphere stability and 1.5 m/s windspeed, the maximum distance of 0.9 miles obtained corresponding to a toxic endpoint of 0.0087 mg/l. One alternative scenario has been submitted for each toxic substance at or above the threshold quantity in Program 2 and 3 prosess cumulatively. The alternative release scenario for chlorine/sulfur dioxide involves a release from tank # 1 in the chlorine/sulfur dioxide process. The scenario involves the release of 2000 lb. of chlorine a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance of endpoint of 0.0087 mg/l of chlorine/sulfur dioxide is 0.9 miles. 4. The General Accidental Release Prevention Program and The Chemical Specific Prevention Steps. Our facility has taken all necessary steps to com ply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 edition. Our facility is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release program that is in place at our stationary source. Process Safety Information- R. Dwayne Huffman Reclaimed Water Plant maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis- Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analysis is the What If Checklist. The studies are undertaken by a team of qualified personnel with expertise in process operations, and are revalidated at a regular annual interval. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures- For the purpose of safety conducting activities within our covered procedures. These procedures address various modes of operation such as start-up, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and start-up after turnaround. The information is regulary reviewed and is readily accessible to operators involved in the process. Training- R. Dwayne Huffman Reclaimed Water Plant has a comprehensive training program to ensure all employees that are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every 3 years, and more frequently as needed. Mechanical Integrity- R. Dwayne Huffman Reclaimed Water Plant carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these check s includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems,emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices, furthermore these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change- Written procedures are in place at The R. Dwayne Huffman Reclaimed Water Plant to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of an offered training to deal with the modification. Pre-startup Reviews- Pre-startup reviews related to new processes and to modifications in established processes are conducted as a regular practice at The R. Dwayne Huff man Reclaimed Water Plant. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits- The R. Dwayne Huffman Reclaimed Water Plant conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years, and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation- The R. Dwayne Huffman Reclaimed Water Plant promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. these investigations are undertaken to identify the situation leading to the incident, as well as any corrective actions to prevent the release from recurring. All reports are retained for a minimum of 5 years. Employee Participation- Th e R. Dwayne Huffman Reclaimed Water Plant truly believes that process safety management and accident prevention is a team effort. city employees are strongly encouraged to express their views concerning accident prevention issues, and to recommend improvements. In addition, our employees have access to all information created as part of the facilities implementation of the RMP rule, including information resulting from process hazard analysis in particular. Contractors- On occasion, our city hires contractors to conduct a specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. The R. Dwayne Huffman Reclaimed Water Plant has a strict policy of informing the contractors of known potential hazards related to the contractors work and the processes. Contractors are informed of all the procedures for emergency response should an accidental release of regulated substance occur. 5 . Five Year Accident History The R. Dwayne Huffman Reclaimed Water plant has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental releases during this period. 6. Emergency Response The R. Dwayne Huffman Reclaimed Water Plant carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response, including adquate first aid and medical treatment evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To insure proper functioning, our emergency response equipment is regulary inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. East Coast Florida Regional Planning Council, 1101 Wymore Rd., Suite 105, Winter Park Florida 32789. Phone:(407) 623-1075, Fax:(407) 623-1084 is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety We are presently investigating the feasibility of converting from our present gas chlorine feed system to a liquid hypochlorie solution feed system. We would like to implement this change in the next 12-24 months. Certification Statement The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. Name: Phillip L. Clark Signature: Title : Chief Operatort, R. Dwayne Huffman Reclaimed Water Plant Date: |