North Davis County Sewer District - Executive Summary |
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Section 1 - Executive Summary The main purpose of this North Davis County Sewer District (NDCSD) Risk Management Plan (RMP) is to prevent releases of chlorine that could expose district employees and the public. This RMP program includes: 1) Section 1 - an executive summary of NDCSD's RMP; 2) Section 2 - an assessment of the potential impacts of a major chlorine or sulfur dioxide release; 3) Section 3 - a prevention program that details the intrinsic/extrinsic safeguards, control strategies and personnel procedures that are in place at the district; 4) Section 4 - an emergency response plan that describes the districts response in the event of a major chlorine or sulfur dioxide release; and 5) Section 5 - a copy of the completed RMP submittal form for submission to EPA. An effective RMP program minimizes risk by promoting a safer and more efficient waste water treatment operation through better process control and preventive maintenance. Also, a well thought out Emergency Response Plan will help reduce the impact of a chlorine release. This RMP program meets the requirements of the Environmental Protection Agency 40 CFR part 68, which applies to facilities with certain threshold quantities (TQ) of hazardous chemicals, including chlorine ( TQ 1,500 lbs). NDCSD uses chlorine to disinfect waste water from the North Davis County area. The District uses two 80,000 lb pound tanks to store chlorine. However, administrative policy restricts the amount of chlorine in each tank to a maximum of 34,000 pounds, making the maximum amount of chlorine onsite 68,000 lbs. Because NDCSD utilizes chlorine in these quantities, the District is covered by the RMP rule. It is NDCSD's goal to provide a safe and cost effective way for treating wastewater generated by residents and businesses. Present treatment operations at NDCSD require the use of chlorine for disinfection. With respect for the potential hazards involved with using this chemical, NDCSD has taken many steps to prevent its release. Accident History Since NDCSD has been in operation there has not been one significant release of chlorine. No District employees have ever been injured by a chlorine release. Furthermore, no off-site or public receptors, human or animal, have been injured by an air release of chlorine. During the last 40 years of treating wastewater, NDCSD has never had a significant chemical accident of any kind. Prevention Program Due to the highly automated and fault tolerant delivery system, the likelihood of even a minor chlorine release is very low. The entire delivery system, beginning at the storage tanks and ending at the chlorine injectors, is maintained under constant vacuum pressure. This system automatically and instantaneously shuts down the flow of chlorine in the event of a fault or break in the line. The entire chlorine delivery system, including the chlorine tanks, undergo rigorous integrity tests and are routinely inspected by NDCSD personnel and annually inspected b y a professional contractor. No only is NDCSD's chlorination system engineered to be very fault tolerant, but it is also operated in a safe manner. NDCSD is very pro-active in accident prevention and preventive maintenance of their chlorination equipment and associated controls, including: routine upgrades, change-outs and rebuilding of disinfection delivery and storage equipment as recommended by equipment manufacturers, frequent mechanical integrity inspections on equipment and intrinsic and extrinsic safety controls for processes, and frequent inspections from outside contractors and safety advisors to insure that operator training and district operating procedures are efficiently established. Emergency Response In the event of an emergency release of chlorine or sulfur dioxide, NDCSD has a highly competent and well trained chlorine team with personnel both on-site and on call around the clock. The members of this chlorine team are certified by the state to safely operate t he chlorination and sulfonation equipment. Moreover, these individuals receive frequent specific training for responding to and managing chlorine releases. Members of the NDCSD chlorine team are equipped and trained for chlorine emergencies and coordinate emergency response activities with the Syracuse City Fire Department. Planned Changes NDCSD's chlorination system is engineered to be very fault tolerant and is operated in a safe manner. However, NDCSD understands that extreme events (e.g., natural disasters) could potentially push these systems beyond what they were designed to withstand. Therefore, as technology changes and different means of disinfection become practical solutions, NDCSD will research and implement new equipment and processes to further reduce the hazards associated with the storage of chemicals that may harm district employees, the public or the environment. Certification Statement As the District Manager of North Davis County Sewer District, I, the undersigned , certify that the following document is NDCSD's Risk Management Program and describes our current operations and best efforts for preventing and planning for emergency releases of chlorine. This program meets the requirements of EPA's 40 CFR part 68. ____________________________________ Kevin Cowan, District Manager - NDCSD |