HWEA: Moss Water Treatment Plant - Executive Summary |
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This executive summary will provide a brief description of the Moss Water Treatment Plant's risk management program. It will communicate the risks posed by the facility to the community and what we have done to minimize the risk. HWEA and its employees have placed great effort and resources into the accident prevention program. In addition, several new prevention programs are planned and will be completed in the near future. Senior management is committed to safety and implementation. The facility's overall approach to chemical safety is excellent. For example, several accidential release prevention and emergency response policies have been written and reviewed by both internal and external sources. These include: a written community emergency response plan, facility emergency response plan, procedures for informing the public, and emergency health care actions. These plans are coordinated through the Christian County DES office and reviewed annually. Chlorine is the only regulated chemical stored in sufficent quantities and used in the production of treated water that requires compliance with EPA's Risk Management Plan(RMP). Chlorine stored in excess of 2500 pounds in one process requires a RMP to be completed. Chlorine is stored in 4 each 1-ton steel cylinders. The cylinders meet or exceed Department of Transportation regulatory requirements. The operators are provided with training and the proper equipment to safely and properly handle the chemical. The chlorine system is a new process that was designed and installed into prevent incidents. This plan includes a worst case release scenario involving chlorine. The analysis details the off-site impact based on the release of the total inventory within a ten minute duration as required by the RMP regulations. The EPA computer model estimates the release would affect approximately 900 members of the community with a distance of 1.9 miles from the source. However, the actual releas ed amount of chlorine would be much less than the required estimate and scenerio making the worst-case release unlikely. Passive mitigation systems such as the process enclosure would limit the release. Also, the trained operations personnel and operating procedures would allow for a quick and successful response. The written procedures and area alarm systems would reduce the loss. The plan also includes an alternative chlorine release. The failure of the feeder valve diaphram scenario is more likely to address the severity of a release. The alternative release involves the loss of 10 pounds over a 35 minute duration. This would affect approximately 100 members of the community within a 0.10 mile radius. The release would be reduced due to the passive and active mitigation systems. This includes an enclosed process system an blast walls. The water treatment facility is covered by several state and federal regulatory agency requirements. These include: OSHA, EPA, DOT, f ire marshal and local fire department. Various agency inspections are conducted during normal operations. The prevention program includes many elements. These include: process controls such as vents, relief valves, manual shutoffs, interlocks, alarms and procedures, emergency power, and backup pumps. Process area monitors observe for any chlorine concentration and respond to the high levels. Improved maintenance procedures and operating training are an important element. The plant has experienced only one accidential release during the five-year accident history. The plan outlines the details of the release. No one offsite was injured and no evacuations were necessary. A detailed incident report and root cause analysis was conducted during the investigation. All of the action items from the investigation are now complete. The chlorine system was a factory designed system with several improvements as a result of the 1999 release. An excellent emergency response program was developed and is maintained to meet or exceed all regulatory requirements. For example, the response plan is reviewed by the local emergency response agency and all employees. In addition, personnel receive ERT training, drills are conducted, and public notification and alert systems are in place to provide a quick response and minimize the impact. A detailed process hazard review (PHR) is scheduled to begin during June. The PHR will utilize acceptable industry techniques such as: what-ifs, checklists and what if/checklists. The review will identify any process areas with opportunities for improvement. The action items will be completed as soon as possible to ensure a safe system is provided. In summary, HWEA and its employees strive to provide a safe and efficient water treatment facility. Many systems are in place to prevent a chlorine release and limit the impact on the community. |