Springdale Water Utilities - Executive Summary |
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Executive Summary for Springdale Water Utilities' Publicly Owned Treatment Works (POTW ) 1. Accidental Release Prevention and Emergency Response Policies: We at Springdale Water Utilities are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled: Our facility's primary activity is wastewater treatment for the City of Springdale, AR and outlying areas. We have 2 regulated substances present at our facility. These substances are Chlorine and Sulfur dioxide (anhydrous). Chlorine is used for disinfecting wastewater. This insures that the wastewater is safe to discha rge into Spring Creek, a tributary of the Illinois River. Sulfur dioxide (anhydrous) is used for dechlorinating wastewater. This binds up the remaining chlorine, making the facility's discharge safe for fish and other living organisms in the creek. The maximum inventory of Chlorine at our facility is 12,000 lb. and Sulfur dioxide (anhydrous) is also present at our facility in a maximum quantity of 12,000 lb.. No more than six (one ton) cylinders of each chemical is present on site at any given time. 3. The Worst Case Release Scenarios and the Alternative Release Scenarios, including administrative controls and mitigation measures to limit the distances for each reported scenario: To perform the required offsite consequence analysis for our facility, we have used the EPA's RMP*Comp(TM) software. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 toxic substances as a class involves a catastrophic release fro m the chlorination process. In this scenario 2000 lb. of Chlorine is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. The released quantity has been limited to less than 17% of the maximum inventory of the source by a system of administrative controls. Passive mitigation systems such as enclosures are also taken into account to calculate the scenario. These mitigation systems have the effect of substantially reducing the offsite consequences of a worst case release. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 0.9 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. The actual population that might be affected by an accidental release is likely much less than that estimated for this scenario. The estimate was based on the entire population of the three 1990 Census Block Groups surrounding Springdale's Wastewater Treatment Facility. A large portion of these block groups lies outside a circle of 0.9 miles around the facility, and only the small portion of that circle downwind from an accidental release would be affected in the unlikely event of a release with offsite consequences. The alternative release scenario for chlorine also involves a release from chlorination. The scenario involves the release of 2000 lb. of chlorine. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 20 minutes. Passive mitigation controls such as enclosures are again taken into account to calculate the scenario, having the effect of even more substantially reducing offsite consequences. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.2 miles. The only public receptor within 0.2 miles of Springdale's Wastewater Treatment Facility is a public road, Si lent Grove Rd.. It would only be affected if the wind was blowing from the west. This road's use is minimal, so it could easily be blocked off if necessary to protect the public from offsite consequences. The alternative release scenario for sulfur dioxide (anhydrous) involves a release from dechlorination. The scenario involves the release of 2000 lb. of sulfur dioxide. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 20 minutes. Passive mitigation controls such as enclosure(s) are taken into account to calculate the scenario, having the same effect as that on chlorine in its alternative release scenario. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0078 mg/L of Sulfur dioxide (anhydrous) is 0.2 miles, and again would only affect a public road. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Ste ps: Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Springdale Water Utilities maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is through regular in-house reviews, along with updates as provided from numerous sources including the Chlorine Institute, the US Environmental Protection Agency, the American Waterworks Association, the Water Environment Federation, and the Arkansas Department of Labor. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of no less than once every three years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed in June, 1999, just prior to Springdale Water Utilities' first RMP submission. Operating Procedures For the purposes of safely conducting activities within our covered processes, Springdale Water Utilities maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, emergency shutdown, emergency operations, and normal shutdown. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Springdale Water Utilities has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least annually and more frequently as needed. Mechanical Integrity Springdale Water Utilities carries out frequent, routine maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Springdale Water Utilities to manage changes in process chemicals, technology, equipment and procedures. The most recent review of maintenance procedures was performed in June, 1999, just prior to submission of this RMP. No revisions were required at that time. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and provided training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Springdale Water Utilities. The most recent review of current processes was performed in June, 1999. No revisions were required at that time. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Springdale Water Utilities conducts audits on a regular basis to determine whether the provisions set out under the RMP rule ar e being implemented. The most recent comliance audit was conducted in June, 1999. These audits will be carried out at least every 3 years and any corrective actions required as a result of the audits will be undertaken in a safe and prompt manner. Incident Investigation Springdale Water Utilities will promptly investigates any incident that results in, or could reasonably result in a catastrophic release of a regulated substance. These investigations, should a release occur, would be undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports will be retained for a minimum of 5 years. Employee Participation Springdale Water Utilities truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access t o all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Springdale Water Utilities has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History: Springdale Water Utilities has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there have been no accidental releases during this period. More specifically, there has not been a single accidental rel ease with offsite consequences since 1978, when the first regulated substance, chlorine, was first brought on site. 6. Emergency Response Plan: Springdale Water Utilities has a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident inspection of affected areas for corrosion. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 7. Planned Changes to Improve Safety: Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Continuing to review and upgrade em ployee training programs as needed, updating onsite training with the local Haz-Mat team, and working with the Washington and Benton County LEPCs on emergency planning for our facility are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by August, 1999. |