Primrose Water Treatment Plant - Executive Summary |
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1. Corporate Prevention and Emergency Response Approach The Primrose Water Treatment Plant (Primrose WTP) is owned by the Orlando Utilities Commission. The facility has developed and maintains accident prevention programs and an emergency response plan to prevent and mitigate the effects of hazardous chemical releases. 2. Description of Stationary Source The Primrose WTP is located on at 203 S. Primrose Drive, Orlando, Orange County, Florida. Primrose WTP adds chlorine in their chlorination process in order to disinfect the City's water supply. Liquefied chlorine gas is stored in up to fourteen one-ton containers at the Chlorination process building. Ten one-ton containers are always connected to the process. Four one-ton containers are on-line at one time feeding the system with ten on standby when those are exhausted. The total chlorine inventory in the process at any one time is 28,000 lbs. This is greater than the 2,500 lb. RMP threshold quantity for chlorine. This process does not meet the EPA definition of being in an enclosed in a building. 3. Description of the Worst Case and Alternative Release Scenarios The Worst Case release scenario is the rupture of a one- ton container from the Chlorination process, releasing 2,000 lbs. of Chlorine gas over a ten minute period. Under worst case weather conditions, the chlorine gas could travel 1.3 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .0087 mg/L), using the WWTP Guidance lookup tables. The Alternative-Case Release Scenario resulted in an unmitigated release rate of 1387.2 lbs/min. from a 0.75 inch diameter hole. Under average weather conditions, the chlorine gas could travel 0.57 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .0087 mg/L), using the WWTP Guidance lookup tables. 4. Prevention Program For the Chlorination process, this faci lity exceeds the chlorine threshold quantity for the OSHA Process Safety Management (PSM) Standard, 1910.119, however this is an unmanned site and does not is therefore not subject to the PSM requirements. For RMP compliance purposes, this places the Primrose WTP Chlorination process in the Program 2 level. The Primrose facility will address all elements for the Prevention Program 2 as required by the RMP rule. The Prevention Program 2 contains the following elements: a Process Hazard Review of the process, Process Safety Information, Preventative Maintenance Program, and Operating Procedures. Compliance Audits, Safety Training, and Incident Investigation have also been incorporated into this program to ensure continued safe operation and prompt correction of deficiencies. The Prevention Program receives full support of plant management and involvement of employees at all levels. 5. Accident History The Primrose facility has had no accidental releases of chlorine in the past five years. 6. Emergency Response Program The Primrose WTP has an Emergency Response Plan in place. The program complies with 29 CFR 1910.38. The site also has some internal assessment capabilities in the ER plan of action to respond to an emergency and has a procedure for address small releases of chlorine. The current plan has been coordinated with the Orlando/Orange County Fire Department and Hazardous Materials Response Team, and the Regional Local Emergency Planning Committee. Notification is made locally by dialing 911, and by notifying Florida State Warning Point at (800) 320-0519. |