White Oak Bayou Treatment Plant - Executive Summary |
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1.0 Accidental Release Prevention and Emergency Response Policies North Little Rock Waste Water Utility is committed to the safety of our workers, the public, and the environment. This commitment is demonstrated by the resources invested in the prevention of accidental releases of hazardous substances. The North Little Rock Waste Water Utility's White Oak Bayou Treatment Plant implements reasonable controls, such as training of personnel and the safe design, installation, operation and maintenance of our processes. Our policy is to make every effort to prevent the release of hazardous substance but in the event of a release, our trained personnel and local emergency response agencies will respond to control and contain the release in a manner that will be safe for workers and will help prevent injuries to the public or the environment. 2.0 Description of the North Little Rock Waste Water Utility's White Oak Bayou Treatment Plant and Regulated Substances The White Oak Bayou Tr eatment Plant is located within the city limits of North Little Rock, Arkansas. The facility is part of the North Little Rock Waste Water Utility wastewater collection and treatment system which services an area with a population of over 60,000 people and has a design wastewater flow of 4.3 million gallons per day. The White Oak Bayou Treatment Plant handles one substance regulated by the Risk Management Program Rule (RMP Rule) in quantities above the Threshold Quantity. This substance is: * Chlorine - stored in 1 ton cylinders and used for the disinfection of the wastewater prior to releasing to the receiving stream. 3.0 Hazard Assessment The RMP Rule requires the White Oak Bayou Treatment Plant to perform a Hazard Assessment of the chlorine stored and used in the chlorination process at the facility. This Hazard Assessment includes an offsite consequence analysis for the following scenarios: * One worst-case and one alternative release scenario for the toxic substance chlor ine for the chlorination process unit at the facility. The following information summarizes these offsite consequence analyses. 3.1 Chlorination Process The worst-case scenario for toxic substances is the failure of a 1 ton cylinder of liquid chlorine. The toxic cloud formed by the evaporating chlorine would reach off-site endpoints and public receptors. The alternative release scenario for chlorine is a cylinder valve sticking in the open position allowing a sixty minute release of chlorine gas. The toxic cloud formed by the escaping gas would reach offsite endpoints and public receptors. 4.0 Accidental Release Prevention Program and Chemical-Specific Prevention Steps The Risk Management Program rule (RMP rule) requires that a prevention program be established for the White Oak Bayou Treatment Plant chlorination process. The following details the prevention program elements at the White Oak Bayou Treatment Plant that apply to these processes. 4.1 Safety Information The Wh ite Oak Bayou Treatment Plant maintains a variety of technical documents that are used to help ensure safe operation of the White Oak Bayou Treatment Plant processes. Material safety data sheets (MSDSs) document the physical and chemical properties of hazardous substances handled at the White Oak Bayou Treatment Plant, including the chlorine in the covered processes. 4.2 Hazard Review The White Oak Bayou Treatment Plant has performed a Hazard Review of the chlorination process; an additional Hazard Review is scheduled to ensure the critical elements for safely storing and handling chlorine are in place in the process. 4.3 Operating Procedures The White Oak Bayou Treatment Plant has experienced employees operating the chlorination process at the facility. These operators have been certified as being knowledgeable in the procedures required to safely operate the chlorination process. Written operating procedures are being prepared which will be used to: 1. train employees and con tractors, and 2. serve as reference guides for appropriate actions to take during normal and abnormal process conditions. 4.4 Training The White Oak Bayou Treatment Plant trains personnel in the operating procedures to help ensure safe and effective performance of their assigned tasks. A formal training program is being developed to ensure a record of all training is maintained and refresher training is provided on a timely basis. 4.5 Maintenance The White Oak Bayou Treatment Plant properly maintains the equipment in our processes. A formal Preventive Maintenance program is being developed which includes: 1. procedures to safely guide workers in their maintenance tasks, 2. worker training in the maintenance procedures, and 3. an inspection and testing program to help identify equipment deterioration and damage before equipment fails. 4.6 Compliance Audits The White Oak Bayou Treatment Plant performs periodic (at least every three years) audits of covered processes to verify the processes are operating in compliance with the requirements of the RMP Rule. A compliance audit report is prepared after each audit, and any deficiencies noted by the audit are corrected in a timely manner. 4.7 Incident Investigations The White Oak Bayou Treatment Plant will investigate all incidents that could reasonably result in a serious injury to personnel, the public, or the environment. The White Oak Bayou Treatment Plant is developing an incident investigation program which encourages employees to identify and report any and all incidents requiring investigation. An investigation team will be assembled, and the investigation will be initiated within 48 hours of the incident. The results of the investigation will be documented, recommendations resolved, and appropriate process enhancements implemented. 4.8 Chemical-specific Prevention Steps - Chlorine Industry standards are followed at The White Oak Bayou Treatment Plant to help ensure safe handling of chlorine. The vendor supplies chlorine via a Department of Transportation (DOT) approved truck and in DOT approved 1 ton cylinders. The chlorination process equipment is designed and constructed with state-of-the-art materials and technology utilizing the standards and guidelines of the Chlorine Institute, American Water Works Association, ASME, ANSI, and other applicable codes. Workers who perform operations involving chlorine receive training emphasizing safe handling procedures according to the guidelines required by the White Oak Bayou Treatment Plant. 5.0 Five Year Accident History The White Oak Bayou Treatment Plant compiled a five-year accident history that fulfills the requirements of the RMP Rule. This history indicates a good record of accidental release prevention over the past five years. No releases of regulated substances have occurred from the White Oak Bayou Treatment Plant that have resulted in offsite consequences, injuries to the public, or impacts on the environment. Mi nor releases have occurred during maintenance activities with no injuries occurring to the White Oak Bayou Treatment Plant employees. 6.0 Emergency Response Programs The White Oak Bayou Treatment Plant has prepared a written emergency response plan. This plan will be communicated to the Local Emergency Planning Committee (LEPC) and local fire department. The White Oak Bayou Treatment Plant will periodically conduct emergency drills to test our emergency plan and coordinate these drills with the local fire department. 7.0 Planned Changes to Improve Safety The White Oak Bayou Treatment Plant continuously attempts to improve the safety of our processes to protect our employees, the public, and the environment. The White Oak Bayou Treatment Plant incident investigations, employee suggestions, and improvements in technology will be utilized to update the safety aspects of the process. The following changes to improve process safety are planned or have recently been completed. 1 . implement a chlorine shipment Quality Assurance Program to aid in the inspection of chlorine cylinders when received, and 2. implement a preventive maintenance program for the hoists used to move chlorine cylinders. June 17, 1999 |