District II Water Reclamation Facility - Executive Summary
1.1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICY SUMMARY |
The District II Water Reclamation Facility is a critical part of the JEA water supply and waste water treatment system. JEA is committed to operating this and other JEA facilities in a manner that is protective of the health and safety of JEA and Contractor employees, the public, and the environment. JEA is committed to operating this and other JEA facilities in full compliance with all applicable Occupational Safety and Health Administration (OSHA) and Environmental Protection Agency (EPA) regulatory requirements.
To ensure that the Facility is operated in a safe manner and in compliance with applicable OSHA and EPA regulations relevant to accidental release prevention, JEA has developed an integrated Process Safety Management/Risk Management Plan (the Plan) for the Facility. Among the important components of the Plan are JEA's system of policies and procedures for operation and maintenance of the Facility,
and JEA's Emergency Response Plan (ERP) for the Facility.
1.2 STATIONARY SOURCE DESCRIPTION
The Facility is designed for the treatment of waste water from Jacksonville's sanitary sewer system. The Facility uses chlorine for waste water disinfection (the chlorine system), and sulfur dioxide to control the level of residual chlorine in the treated effluent (the sulfur dioxide system).
Chlorine is delivered to the Facility via truck and stored in silver-colored one-ton (2,000 pounds) containers which are used onsite as storage vessels. These containers are stored and used in the chlorination/ sulfonation building near the southeast corner of the Facility property. The maximum intended inventory of chlorine at this location is 24,000 pounds, in one-ton containers (12 containers). Chlorine is also used in 150 pounds cylinders at the sludge thickener. The 150 pound Cylinders are delivered to and stored in the chlorination/dechlorination building. Sulfur dioxide is delivered to the
Facility in yellow-colored ton containers which are used onsite as storage vessels. The containers are also located in the chlorination/sulfonation building. The maximum intended inventory of sulfur dioxide at this location is 16,000 pounds in one-ton containers (8 containers).
To facilitate the chlorination process, four (4) one-ton containers (8,000 pounds) are simultaneously connected to a split manifold configuration that has two banks of two containers. Only one bank is active at any given time, meaning that a total maximum of two containers (4,000 pounds) of chlorine are attached on-line when the active containers are full. A similar configuration is used for the sulfonation process.
1.3 WORST CASE AND ALTERNATIVE CASE RELEASE SCENARIOS
The worst case release scenario is the 10-minute release of the contents of one full one-ton container of chlorine, or 2,000 pounds, as required by applicable Risk Management Plan (RMP) regulations. Consideration was given to a release
of one full one-ton container of sulfur dioxide, or 2,000 pounds, over a ten minute period. However, the endpoint for that scenario was found to be a shorter distance from the Facility than that for the chlorine release. Thus, the chlorine release was used as the worst case release scenario. Because the chlorine containers are stored and used within a building, the Facility qualifies for a passive mitigation credit of 45 percent that is applied against the release rate. Using the methodology prescribed in the regulations, this worst case release scenario results in potential impacts to off-site receptors.
A more realistic, alternative release scenario also was examined for chlorine and sulfur dioxide. For this scenario, it was assumed that the ton containers were half full, resulting in a release of 1,000 pounds of chlorine or sulfur dioxide. In addition, a more realistic release period of 30 minutes was used for the alternative case scenario. These scenarios also result in pote
ntial impacts to off-site receptors.
1.4 ACCIDENTAL RELEASE PREVENTION PROGRAM
The Facility has an aggressive accidental release prevention program that is based upon a foundation of employee awareness and proactive system maintenance. This program is documented in the integrated Plan and is based on the requirements of applicable PSM/RMP regulations. The effectiveness of this program is evident by the fact that the Facility has had no significant releases of chlorine in the five years prior to the date of this Plan.
1.5 FIVE YEAR ACCIDENT HISTORY
There have been no accidental releases at the Facility in the five years prior to the date of the Plan that resulted in injuries or death to Facility or Contractor employees onsite or the offsite public, or damage to potential environmental receptors.
1.6 EMERGENCY RESPONSE PROGRAM
The Facility has an Emergency Response Plan (ERP) that defines the sequence of actions to be taken by Facility employees in the event of an accidental
release of hazardous materials. This ERP has been communicated to the City of Jacksonville Fire and Rescue Department (JFRD) and the Local Emergency Planning Committee (LEPC). It is JEA's policy with regard to emergency response that its personnel are trained to the First Responder Awareness Level. These are individuals who are likely to witness or discover a hazardous substance release and who have been trained to initiate an emergency response sequence by notifying the proper authorities of the release. They would take no further action beyond notifying the authorities of the release. Thus, it is JEA's policy for employees to call 911 in the event of a release emergency and allow the local Hazardous Materials (HazMat) Response Team to mitigate the release conditions. The JFRD is presently responsible for determining when evacuation of offsite areas is necessary, and for public notification.
1.7 PLANNED CHANGES TO IMPROVE SAFETY
The Plan incorporates a number of modificatio
ns to Facility procedures designed to improve employee safety awareness, enhance safe operations and maintenance of the chlorine and sulfur dioxide systems, reduce the potential for accidental releases to occur, and increase the speed and effectiveness of the Facility's response should a release occur.