Moline South Treatment Plant - Executive Summary |
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Executive Summary City of Moline South Wastewater Treatment Plant 1. Accidental release prevention and Emergency Response policies We at Moline South Treatment Plant are 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. Unforeseeably, if such a release does occur, we are completely coordinated with the Moline Fire Department which provides highly trained emergency response personnel to control and mitigate the effects of the release. 2. The Stationary Source and the Regulated Substances Handled. We have 1 regulated substance present at our facility which is Chlorine. The maximum inventory of Chlorine at our facility is 12000 l bs. 3. The Worst Case Release Scenario and the Alternative Release Scenario, 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 look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. Toxic Worst-case analyses: The Worst Case scenario involves a catastrophic release from Chlorination of effluents, RAS, and storage. The scenario involves the release of 2000 lb. of Chlorine in a gaseous form over 10 minutes. The Release rate (lbs/min) is calculated to be 200. A distance to endpoint of 5.4 miles is obtained which affects a residential population of 136,735 within this distance. Toxic Alternative-case analyses: The Alternative Case scenario involves a catastrophic release from Chlorination of effluents, RAS, and storage. The sc enario involves the release of 8.25 lb. of Chlorine in a gaseous form over 25 minutes. Passive mitigation controls such as , enclosures, drains and sumps are also taken into account to calculate the scenario. The Release rate (lbs/min) is calculated to be 0.33 and a Distance to endpoint of 0.07 miles is obtained which affects a residential population of 22. Flammables Worst-case analyses: None applicable Flammables Alternative-case analyses: None applicable 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps. 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. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at o ur stationary source. Process Safety Information: Moline South Treatment Plant 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 the what-if method. The studies are undertaken by a team of qualified personnel with expertise in maintenance and process operations and are revalidated at a regular interval of three years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures: For the purposes of safely conducting activities within our covered processes, Moline South Treatment Plant maintains written operating 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 processes. Training: Moline South Treatment Plant 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. New employees receive on-the-job supervision until they are deemed competent to work independently. Refresher training is provided at least every yearly and more frequently as needed. Mechanical Integrity: Moline South Treatment Plant carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, regulators, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by q ualified 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 Moline South Treatment Plant to manage changes in process chemicals, technology, equipment and procedures. 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 offered 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 Moline South Treatment Plant. 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: Moline South Treatment Plant 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 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation: Moline South Treatment Plant promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. 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 reports are retained for a minimum of 5 years. Employee Participation: Moline South Treatment Plant 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 im provements. In addition, our employees have access to 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. Moline South Treatment Plant 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. Moline South Treatment Plant has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. E mergency Response Plan. Moline South Treatment Plant is included in written Community Emergency Response Plan. The Local agency coordinating Emergency Response Plan is the Moline Fire Department whose phone number is 309-797-0416. 7. Planned Changes to Improve Safety After our hazard analysis at Moline South Treatment Plant and improvments made prior to the institution of RMP we have no planned changes at this time. |