South Valley Water Reclamation Facility - Executive Summary
General Executive Summary for South Valley Water Reclamation Facility |
1. Accidental Release Prevention and Emergency Response Policies
We at South Valley Water Reclamation Facility are strongly 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 West Jordan 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
Our facility's primary activities encompass Wastewater treatment. We have 2 regulated substances present at our fa
cility. These substances include Chlorine and Sulfur dioxide (anhydrous). The regulated substances at our facility are involved in several uses. Chlorine is used for disinfection. Sulfur dioxide (anhydrous) is used for dechlorination.
The maximum inventory of Chlorine at our facility is 80000.00 lb. while Sulfur dioxide (anhydrous) is present at our facility in a maximum quantity of 54000.00 lb..
3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), 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.
The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from Chlorine. The scenario i
nvolves the release of 40000 lb. of Chlorine in a gaseous form over 10 minutes. Passive mitigation controls such as enclosures are also taken into account to calculate the scenario. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 4.4 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L.
One alternative release scenario has been submitted for each toxic substance present in Program 2 and Program 3 processes cumulatively.
The alternative release scenario for Chlorine involves a release from CB-T-1 Chlorine tank in the Chlorine process. The scenario involves the release of 232.00 lb. of Chlorine in a gaseous form over 2 minutes. The release is also assumed to be controlled by active mitigation measures that include excess flow valve(s) and Operator stationed during transfer will mitigate. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.62 miles.
The alternative release scen
ario for Sulfur dioxide (anhydrous) involves a release from tank #1 in the Sulfur Dioxide process. The scenario involves the release of 230.00 lb. of Sulfur dioxide (anhydrous) in a gaseous form over 2 minutes. Passive mitigation controls such as enclosures are taken into account to calculate the scenario. The release is also assumed to be controlled by active mitigation measures that include Operator intervention . Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0078 mg/L of Sulfur dioxide (anhydrous) is 0.31 miles.
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. This facility was designed and constructed in accordance with Generally recognized good engineering practices for waste water treatment fil. A number of processes at our facility are subje
ct 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 our stationary source.
Process Safety Information
South Valley Water Reclamation Facility 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 checklist method. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of five years. Any findings related to the hazard analysis are addressed in a timely manner.
For the purposes of safely conducting activities within our covered processes, South Valley Water Reclamation Facility 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.
South Valley Water Reclamation Facility 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. Refresher training is provided at least every 3 years and more frequently as needed.
South Valley Water Reclamation Facility carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes
among others; 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. 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 South Valley Water Reclamation Facility 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-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at South Valley Water Recl
amation Facility. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
South Valley Water Reclamation Facility 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.
South Valley Water Reclamation Facility 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.
South Valley Water Reclam
ation Facility 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 improvements. 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.
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. South Valley Water Reclamation Facility 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 Hi
South Valley Water Reclamation Facility has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, only one accidental release has occurred during this period.
There has been only one accidental release of a regulated substance from our facility within the last 5 years. This release took place on 07/31/98 and involved 2 lb. of Chlorine. The incident was a result of human error. There were no offsite impacts. No deaths or injuries occured offsite as a result of this accident. Onsite, there were 1 injuries.
6. Emergency Response Plan
South Valley Water Reclamation Facility carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of aff
To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.
Salt Lake County LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified.
7. Planned Changes to Improve Safety
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Changing to ultraviolet disinfection and eliminating hazardous chemicals are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by January 1, 2001.
8. Certification Statement
The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate