Junction City Water Treatment Plant - Executive Summary |
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Introduction The City of Junction City, Kansas is served by a 10-million gallon per day water treatment plant, which is owned and operated by PSG, Inc. This Risk Management Plan (RMP) covers the Section 112r regulated substances maintained at the Junction City Water Treatment Plant, which will be referred to herein as the Plant. Plant Description The Plant maintains only one regulated substance on site: chlorine. Maximum chlorine storage is 12,000 pounds, which exceeds the RMP threshold quantity of 2,500 pounds. The storage and management of chlorine are addressed in this RMP. The Plant is located at 2101 N. Jackson, Junction City, Kansas, which is in an urban area. The surrounding area contains some small housing developments, and the downtown area of Junction City is approximately one mile from the plant. The Worst Case Release Scenario The worst case release scenario for chlorine is the release of a single one-ton cylinder in accordance with the definition provided in the Environmental Protection Agency guidance for RMP development. The chlorine storage is enclosed, so the building will serve as a passive control during a worst-case release. The conditions of the scenario, such as release time and weather status are taken from the EPA Off-Site Consequence Analysis Guidance. The area of potential impact was determined using RMP*Comp, modeling software developed by the EPA. The Off-Site Consequence Analysis indicated that the chlorine would travel approximately 0.9 miles under the specified weather conditions before dispersing in the atmosphere to a harmless concentration. Within that radius of the Plant, an estimated 3000 persons could potentially be affected. Maps of the area and a list of the types of receptors in the potential impact area are provided in the Off-Site Impact Analysis Section. The list of potential receptors includes: 7 Airport 7 Fort Riley 7 Washington School 7 Westwood School 7 Junction City Middle School 7 12th Street Commun ity Center 7 Republican River Industrial Park This type of release would only occur if the cylinder valve was broken off, or the cylinder was breached. The likelihood of such an incident occurring is minimal. Alternative Release Scenario The alternative release scenario is, by definition, a more likely release scenario than the worst case. Engineered controls, such as the chlorine detection system and emergency procedures, are considered in the analysis. The type of system failure selected for the alternative release was the loss of chlorine due to a break in the flexible tubing leading from the cylinder to the vacuum regulator. The chlorine would leak from a 3/8" opening. The leak would continue until the operator handling the cylinder could close the valve. The time for the response was estimated at 30 seconds. Once on site, the fire response personnel would enter the room in protective clothing and close the valve on the leaking cylinder. The results of the Off-Site Con sequence Analysis using RMP*Comp, indicated that the chlorine would travel approximately 0.3 miles under the specified weather conditions in order to disperse in the atmosphere to a harmless concentration. Within that radius of the Plant, an estimated 150 persons could potentially be affected. Maps of the area and a list of the types of receptors in the potential impact area are provided in the Off-Site Impact Analysis Section. Process Hazard Assessment A process hazard assessment was performed on the chlorine system beginning with cylinder unloading and ending with the chlorine in solution. A checklist and a modified "What if" analysis were used. In the checklist analysis, general questions regarding the storage and use areas, as well as protocols associated with the management of the chlorination system, were answered. A copy of that checklist is included in this plan. Following the checklist, each valve, line, and piece of equipment in the system was assessed from the cylinde r to point of chlorine injection using a system flow diagram. The valves and other points in the system where chlorine could be released are numbered on the flow diagram. The assessment is formatted in accordance with those numbers. Compliance with code requirements, potential failures, maintenance and inspection concerns, and standard operating procedures were reviewed for each point in the system. Comments are summarized in the Process Hazard Assessment section. Prevention System The Plant has an operation, maintenance and inspection system designed to review each element of the chlorination system routinely. There are Operation and Maintenance manuals for each major piece of equipment, and personnel receive significant training before being allowed to work on the system. No work on the chlorine system is done without the Facilities Supervisor being present. At the beginning and end of the daily operating period, and as each cylinder is changed, the valves and piping are tes ted for leaks. There are standard operating procedures (SOPs) for startup, shutdown, normal operation, and emergency operation. The SOPs are written and posted in the appropriate areas. Personnel are trained routinely on safety concerns and general operation procedures as well as emergency procedures. The system is equipped with chlorine detectors in both the chlorine feed and storage rooms and alarms that indicate leaks. Ventilation is provided in the chlorine room only when a worker is present. Emergency Response Plan Plant personnel are allowed and trained to respond to leaks that can be managed by turning off a valve. Any response requiring entry in a dangerous atmosphere or use of a chlorine repair kit is to be managed by the Fort Riley Fire Department. The Plant has an agreement with the Fire Department, which is included in this plan. A complete copy of the Emergency Response Plan is also included. Accident History The Plant has had no chlorine releases in the pas t five years. |