Seabrook Wastewater Treatment Plant - Executive Summary

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General Executive Summary for the City of Seabrook Wastewater Treatment Facility 
 
1. Accidental release prevention and Emergency Response policies 
 
We at the Seabrook Wastewater 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 process 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 Seabrook 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 one regulated substance present at our facility which is chlorine. 
 
The maximum inventory of chlorine that is ex 
pected to be present in this facility based on process/ operational requirements is 4,000 lbs. 
 
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 cosequence analysis for our facility, we have used the look-up tables and equations provided by the EPA int the RMP Offsite Consequence Analysis Guidence. The following paragraphs provide details of the chosen scenarios. 
 
Toxic Worst-Case Analyses 
 
The Worst Case scenario involves a catastrophic gaseous chlorine release. The scenario involves the release of 4,000 lbs. of chlorine in a gaseous form over 10 minutes. The release rate (lbs./min.) is calculated to be 220. A distance to endpoint of 5.4 miles is obtained which affects a residential population of 61,036 within this distance.  
 
Toxic Alternative-Case Analyses 
 
The Alternative Case scenario involves a catastrophic gaseous ch 
lorine release. The scenario involves the release of 2,000 lbs. of chlorine in a gaseous form over 37 minutes. Passive mitigation controls such as dikes, enclosures and sumps are also taken into account to calculate the scenario. The release rate (lbs./min.) is calculated to be 54.5 and a distance to endpoint of 0.81 miles is obtained which affects a residential population of 1,373. 
 
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. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. 
 
Process Safety information 
 
The S 
eabrook Wastewater Treatment Plant maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all the 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 daily monitoring and sampling. The studies are undertaken by a team of qualified personnel with with expertise in engineering and process operations and are revalidated at regular intervals. 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, the Seabrook Wastewater Treatment Plant maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency s 
hutdown, 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 
 
The Seabrook Wastewater 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 basic classroom training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided at least annually and more frequently as needed. 
 
Mechanical Integrity 
 
The Seabrook Wastewater Treatment Plant carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks include among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Main 
tenance 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 the Seabrook Wastewater 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-startup safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Seabrook Wastewater 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 
 
The Seabrook Wastewater 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 
 
The Seabrook Wastewater 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 corrective actions to prevent the release from reoccuring. All reports are retained for a minimum of 5 years. 
 
Employee Participation 
 
The Seabrook Wastewater Treatment Plant truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to expr 
ess 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. 
 
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. The Seabrook Wastewater Treatment Plant has a strict ploicy of informing the contractors of known potential hazards related to 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 
 
The Seabrook Wastewater Treatment Facility has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringen 
t release prevention policies, there has been no accidental release during this period. 
 
6. Emergency Response Plan 
 
Facility is included in written community ER Plan. 
 
The local agency coordinating the ER Plan is the is the Seabrook Fire Department which has the phone number 281-291-5610. 
 
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. Converting from chlorine gas to liquid bleach is one of the major steps we want to take to improve safety at our facility. This change is expected to be implemented by the summer of 1999.
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