Lakeshore Water Treatment Plant - Executive Summary |
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1.1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICY SUMMARY The Lakeshore Water Treatment Plant 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 EPA regulations relevant to accidental release prevention, JEA has developed a 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 Facili ty. 1.2 STATIONARY SOURCE DESCRIPTION The Facility is designed for the treatment of potable water prior to distribution through Jacksonville's public water supply system. The Facility uses chlorine for water disinfection. Chlorine is delivered to the Facility via truck in ton (2,000 pounds) containers, which are used onsite as storage vessels. These containers are stored and used in a building located on the Facility property. The maximum intended inventory of chlorine at this location is 8,000 pounds, in one-ton containers (4 containers). To facilitate the chlorination process, two (2) one-ton containers (4,000 pounds) are simultaneously connected to a split manifold configuration that has two banks of one container. Only one bank is active at any given time, meaning that a total maximum of one container (2,000 pounds) of chlorine are attached on-line when the active containers are full. 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. 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. For this scenario, it was assumed that the ton containers were half full, resulting in a release of 1,000 pounds of chlorine. In addition, a more realistic release period of 30 minutes was used for the alternative case scenario. A credit of 45 percent was applied to the release rate to account for the passive mitigation provided by the building. This scenario also results in potential impacts to off-site receptors. 1.4 A CCIDENTAL 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 h as 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 modifications to Facility procedures designed to improv e 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. |