Conestoga Water Treatment Plant - Executive Summary |
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The Conestoga Water Treatment Plant (CWTP) is one of two water treatment plants owned and operated by the City of Lancaster Pennsylvania, Bureau of Water. The CWTP is located at 150 Pitney Road, Lancaster Pennsylvania. The overall approach to chemical safety and accidental release prevention at this facility is based on education, training, and practice of safe operating and maintenance procedures. The CWTP management is committed to safety and implementation of safe procedures. Employees are trained annually in safety procedures, safe operations of chemical equipment, and emergency response procedures. The training includes classroom, hands-on training, and emergency response awareness level training. All employees are certified competent through a proficiency examination before being allowed to operate chemical equipment. The Bureau of Water's training policy for a reportable quantity chemical release instructs the operator on duty to notify the Lancaster County Emergency Man agement Agency (LEMA) and Bureau of Water supervisory personnel. LEMA is the designated responder for a chlorine leak. The policy also includes evacuation procedures if necessary. The only EPA RMProgram Rule chemical present at the CWTP is chlorine. This facility produces drinking water for the City of Lancaster and surrounding municipalities. According to Pennsylvania Department of Environmental Protection (DEP) drinking water from a surface water source must be disinfected. In addition, there must be a residual disinfectant present in the water throughout the distribution system. Chlorine is approved by the DEP for this purpose and is the disinfectant used by the CWTP. The maximum chlorine storage at this facility is 24,000 pounds, stored in one-ton containers. The EPA RMProgram Rule mandates that a worst-case scenario release be addressed. The worst-case release for this facility would be 2000 pounds (one one-ton container) at a release rate of 200 pounds per minute. I f this release occurred, the distance to the toxic endpoint of 0.0087 mg/L would be 1.3 miles. This release would have an offsite impact. The distance to toxic endpoint was determined using the EPA RMP*COMP gas dispersion modeling program. This is a release that is unlikely to happen. The EPA RMProgram Rule also mandates that an alternative release scenario be addressed. The alterative release is one that is more likely to happen. The alterative release considered for this facility is a release through a 5/16 inch valve body. This opening could be from a broken line or valve. The maximum release for this scenario would be 630 pounds for 60 minutes or 10.5 pounds per minute. The distance to toxic endpoint would be 0.1 miles using the RMP*COMP modeling program. This release would have a slight offsite impact. The impact area of the worst-case and alternative releases are reduced through the use of passive mitigation at this facility. The passive mitigation includes containe r inspection before delivery acceptance, operating and maintenance procedures and training, enclosed building containment, emergency response awareness level training, and emergency response coordination with LEMA. In addition chlorine equipment is inspected daily for defects. In complying with the EPA RMProgram Rule, the CWTP has developed operating, maintenance, emergency response, and training procedures that will enhance the prevention of a chlorine release. The enactment of this program has caused changes to the chlorine system to protect the system and make it safer to operate. These changes include adding barriers to protect stored containers from vehicle impact, storing containers with valves in the 6/12 o'clock position, labeling all valves, piping, and equipment, and installing piping with consistent slope and no low areas. The EPA RMProgram Rule mandates that a five-year accident history be recorded. The CWTP has not had a reportable quantity release in the last five years. All equipment and instrumentation operated by the CWTP is Y2K compliant. The Off-Site Response Plan developed by the Lancaster County Emergency Management Agency for the CWTP has been adopted as the emergency response plan for the RMProgram. This plan was developed in accordance with the provisions of the Superfund Amendments and Reauthorization Act of 1986 (SARA) Title III, the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA) and the Hazardous Material Emergency Planning and Response Act, Pennsylvania Act 1990-165. This plan was originally approved by the Local Emergency Planning Committee of Lancaster County on January 11, 1990. The latest annual review was approved on February 4, 1999. Any drills, public notification, or alert systems will be enacted by LEMA as deemed necessary or appropriate. At this time there are no changes or improvements planned for the CWTP chlorine system. The Bureau of Water is constantly searching for me thids and technology to improve its management of risk. |