City of Jacksonville Land Treatment System - Executive Summary
City of Jacksonville |
Chlorine Executive Summary
The City of Jacksonville has implemented a comprehensive program to safely manage chlorine at its new Land Treatment Plant. It is located 1716 Firetower Road east of the City of Jacksonville. The chlorine safety record at the city's old Wastewater Treatment plant site has been excellent. There have been no chlorine incidents or accidents in the most recent Five-Year history period.
In 1997, a Process Safety Management (PSM) was completed for the new Land Treatment Plant with the assistance of Operations Excellence Consulting, Inc., a consulting firm. A PSM Implementation Manual was edited to be site specific and issued to the Water Plant. With this step, approximately 50% of PSM requirements were met. Key items included in the manual were:
- Written site specific procedures for the Employee Involvement, Management of Change, Incident Investigation, Pre-Startup Reviews and Self Audits.
- Chlorine safety information a
s required by the regulations
Next, these additional steps were implemented to complete the PSM program.
-Training on PSM and its key components including Management of Change, Mechanical Integrity and Incident Investigation.
-Conducting a Process Hazards Analysis
-Developing Standard Operating Procedures for Chlorine Management
-Developing an Emergency Response Plant
-Conducting a Pre-Startup Safety Review
-Training and certification of operators
The supervisor, chief operator and several plant operators will meet several times per year to review and update procedures and to maintain compliance with all aspects of the PSM regulation.
In addition to PSM compliance, the plants have implemented a number of programs to improve the safe handling of chlorine.
-The chlorine delivery system at the new plant is a vacuum process. This process has proven to greatly reduced chlorine leaks by reducing the amount of equipment that is exposed to pressurized chlorine.
-A chlorine g
as scrubber using a sodium hydroxide solution as the scrubbing agent has been installed. This system will be capable of neutralizing 2,000 pounds of chlorine.
The department's Emergency Response Plan has been significantly upgraded. In 1997, the ERP was revised to include offsite response and communication.
To further understand chlorine risks, Operations Excellence Consulting, Inc., a consulting firm was contracted to conduct "Offsite Consequence" Modeling Analysis, as required by EPA's Risk Management Program. Both a "Worst Case" and an "Alternative Case" release scenarios were studied.
The results showed that there is very little risk of chlorine exposure due to the plant's remote location, the large size of the site and the presence of the caustic scrubber. It would take a combined event of a large leak with a scrubber failure to result in an offsite event. The likelihood of such a combination of events is extremely remote. Also, there are no institution, only
an occasion resident within 1.5 miles of the site.
In addition to Process Safety Management, the organization has an active safety program. The City of Jacksonville has had an active Safety Committee for six years. The committee meets monthly and Mr. Raymond Holder is the Utilities representative. The committee's duties include reviewing new safety procedures, accident investigations, safety surveys and safety communications. The Fire Chief is the city's safety director and the head of the Safety Committee.
Within the Utilities department, there are monthly safety meeting to review an OSHA subject or discuss a safety issue. Routine training is conducted for topics such as:
- Hazard Communications
- Personal Protective Equipment
- Confined Space
As a result of our programs, the plants have had an excellent safety record with only 5 recordable injuries over the past four years. We plan to continue our emphasis on safety to maintain and improve our safety performa
Raymond L. Holder, Plants Superintendent