City of Jacksonville Canada Street WWTP - Executive Summary |
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EXECUTIVE SUMMARY 1.0 REGULATED SUBSTANCES The City of Jacksonville Canada Street Wastewater Treatment Plant (WWTP) uses the regulated chemical chlorine in the treatment of municipal wastewater. Chlorine is used in the disinfection of municipal wastewater. Chlorine is stored prior to and during use in 1-ton containers. The chlorine is stored as a pressurized liquefied gas, and is released into wastewater using a vacuum-regulated system. The maximum intended chlorine inventory at the facility is 6,000 pounds, which exceeds the RMP threshold quantity of 2,500 pounds. 2.0 POLICIES Chlorine is a toxic chemical and precautions must be taken in order to prevent unnecessary exposure to facility personnel and to reduce the threat of accidental release which might result in exposure to the surrounding community and to the environment. It is our policy to adhere to all applicable Federal, State, and industry rules, regulations, and guidelines. Chemical safety at the City of Jacksonville Canada Street WWTP is dependent upon strict operating procedures, safe handling methods, and thorough training of employees. Chlorine safety devices are also inherent in the design of the facility and in the equipment used in the chlorine chemical process. 3.0 WORST-CASE/ALTERNATIVE-CASE SCENARIO ANALYSES INCLUDING ADMINISTRATIVE CONTROLS AND MITIGATION MEASURES TO LIMIT THE DISTANCES FOR EACH REPORTED SCENARIO EPA defines the worst-case scenario as total failure of the largest vessel. The alternative-case scenario is defined as a release that is more likely to occur than the worst-case scenario. The alternative-case scenario should also reach an offsite endpoint, unless no such scenario exists. At the City of Jacksonville Canada Street WWTP, the worst-case scenario for chlorine would result in a release of 2,000 pounds of chlorine gas. The impact radius would be 1.3 miles and affect 830 persons. Public receptors would include schools, residences, public recreation areas or arenas, and major commercial or industrial areas. There were no environmental receptors within the impact radius. The alternative-case scenario for chlorine would result in a release of 2,000 pounds of chlorine gas. The impact radius would be 0.1 mile and affect 30 persons. Public receptors would include residences. There were no environmental receptors within the impact radius. 4.0 PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS The City of Jacksonville Canada Street WWTP complies with the EPA's Accidental Release Prevention Rule and with all applicable State codes and regulations. Our facility has taken all the necessary steps to comply with the accidental release prevention requirements under 40 CFR Part 68 of the EPA. The following sections briefly describe the elements of the release prevention program that is in place at our facility. Safety Information The City of Jacksonville Canada Street WWTP maintains a detailed record of safety information that describes the chemic al hazards, operating parameters, and equipment designs associated with the wastewater disinfection process. Hazard Review Our facility conducts detailed studies to ensure that the hazards associated with our chlorine process is identified and controlled efficiently. The studies are undertaken by a team of qualified personnel and are revalidated at least once every five years. Any findings related to the hazard review are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our chlorine process, the City of Jacksonville Canada Street WWTP maintains written operation procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the process. Training The City of Jacksonville Canada S treet WWTP has a comprehensive training program to ensure employees who are operating the chlorine process are competent in the operations procedures associated with the process. Maintenance The City of Jacksonville Canada Street WWTP conducts regular maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes; 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. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Compliance Audit The City of Jacksonville Canada Street WWTP conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every three years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation The City of Jacksonville Canada Street WWTP promptly investigates any incident that results in, or could reasonably result in a catastrophic release of chlorine. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All investigation reports are retained for a minimum of five years. 5.0 FIVE YEAR ACCIDENT HISTORY In the past five years, there have been no accidental releases of chlorine that has resulted in deaths, injuries, or significant property damage onsite, or known offsite deaths, injuries, property damage, environmental damage, evacuations, or sheltering in place. 6.0 EMERGENCY RESPONSE PROGRAM The City of Jacksonville Canada Street WWTP employees will not respond to a chemical emergency at the plant. As required by 40 CFR Part 68.90, the City of Jacksonville Canada Street WWTP is included in the community emergency response plan and appropriate mechanisms are in place to notify emergency responders when there is a need for response. 7.0 PLANNED CHANGES TO IMPROVE SAFETY The City of Jacksonville Canada Street WWTP plans to develop chemical specific operating procedures, training procedures, and maintenance procedures by June 2000. These procedures will then be implemented to ensure the safe operation and mechanical integrity of the RMP regulated process. |