Sugar Creek Wastewater Treatment Plant - Executive Summary |
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Section 1 Executive Summary The Public Works Department of the of Alexander City Public has developed a Risk Management Plan (RMPlan) for the Sugar Creek Wastewater Treatment Plant in an effort to protect human health and the environment and to meet applicable federal regulations. This plant is operated by the Public Works Department of Alexander City and has a capacity to process 18 million gallons of wastewater per day. Currently, the plant is treating approximately 2 million gallons per day. It is located at 1 Airport Drive Alexander City, Alabama in Section 9, Township 22 South, Range 21 East. This RMPlan has been developed in order to meet the standards published in the 40 Code of Federal Register (CFR) Part 68. The EPA promulgated these regulations to cover the accidental release prevention provision under the Clean Air Act '112(r)(7). These provisions require facilities that exceed the cited threshold quantities for certain chemicals to develop a RMPlan. The goal of a RM Plan is to focus on reducing the risk of accidental releases of certain chemicals; thereby, preventing harm to employees as well as potentially catastrophic impacts to the public. Over 60 accidental releases of regulated chemicals at water treatment plants (WTP's) and wastewater treatment facilities in the United States were reported between 1986 and 1995. Chlorine is currently used in the treatment process at this facility and the quantity stored on site exceeds the 2,500-pound threshold for coverage under the RMP Program. Currently, the maximum potential amount of chlorine to be present on site at any one time is 24,000 pounds. Chlorine is stored and used at the site in one-ton cylinders. Except during delivery, all of the chlorine is stored within an enclosed building. Sulfur dioxide is also used at the treatment plant. Currently, a maximum of 24,000 pounds of sulfur dioxide is stored/used at the treatment plant. The threshold limit for sulfur dioxide is 5,000 pounds. In o rder to illustrate the areas that could be impacted from a release of either chlorine or SO2 into the atmosphere, hazard analyses were conducted. Two analyses were performed on chlorine and one analysis was performed for SO2 to estimate the off-site consequence from a potential release. The first release scenario is the case defined by the Environmental Protection Agency (EPA) as the "worst case" scenario. This scenario assumes that the largest vessel is full and it releases the entire contents of the container during a ten-minute period. The second scenario (or alternative scenario) is based on a situation more likely to occur which will result in a release of chemicals at the facility. The radii of impact were determined based on the guidance provided in Chapter 4: "Offsite Consequence Analysis" of the General Guidance for Risk Management Programs dated October 27, 1998 and the Compliance Guidance and Model Risk Management Program for Water Treatment Plants. The distance to the end point concentration was determined with the aide of the Computer Program Aerial Locations of Hazardous Atmosphere, version 5.2.1 (ALOHA). This program was developed by the National Safety Council for emergency planners. ALOHA works in conjunction with the Computer-Aided Management of Emergency Operations (CAMEO) database and MARPLOT program. In all release scenarios, the toxic end point concentration remains the same. The toxic end point for chlorine is three parts per million (ppm) or 0.0087 milligrams per liter (mg/l) and 0.0078 mg/l for sulfur dioxide, which is the endpoint concentration published in the 40 CPR Part 68. The American Industrial Hygiene Association (AIHA) has listed these concentrations as the "maximum airborne concentration", at which nearly all individuals could be exposed to for up to one hour without experiencing or developing life threatening health effects. This level is referred to as the Emergency Response Planning Guideline (ERPG-2) concentration. Results of the hazard analyses for the EPA "worst case" scenario led to an area defined by a 1.3-mile radius for chlorine. This 1.3-mile radius encompasses 5.3 square miles and includes a population of approximately 655 people (according to the U.S. Census Landview III Program, utilizing 1990 census data). The alternative off-site consequence analysis yields significantly smaller areas. The off-site analysis for chlorine indicates a 0.48-mile radius to the end point concentration. Based on the 1990 census data Landview III Program, the estimated population inside the area is 361. The key to a successful risk management program is to first define hazard, risk and to undertake a comprehensive approach to prevention. The Center for Chemical Process Safety has defined hazard as: A chemical or physical condition that has the potential for causing damage to people, property or the environment Once hazards are identified on the site, an evaluation of the risk involved will lead to systematic identification, evaluation, and control of potential losses that may arise in operation from future events such as fires, explosions, or toxic chemical releases. Currently, the Sugar Creek Wastewater Treatment Plant is operating in accordance with the procedures outlined in the plant's operation and maintenance manual. Throughout this RMPlan, the emergency readiness procedures and regular training schedules are emphasized. One of the goals of implementing these procedures and schedules is to minimize the chance of a release occurring. If the plant employees practice preventative maintenance and are well trained in emergency procedures, they will be successful in preventing and minimizing personnel injury, if a release occurs. All employees of the Sugar Creek Wastewater Treatment Plant are required to know the locations of the emergency telephone numbers and names of individuals to contact in case of a release. If an emergency occurs, each employee will have an assigned task. This risk management plan enhances the standard operating procedures because it provides a clear checklist that identifies predetermined individuals and agencies that require notification and coordination in case of an emergency. This RMPlan details which individuals will respond to contain the release, and it outlines the agencies that will be responsible for evacuating the appropriate areas, and for sounding the "all clear" once the leak is contained. The plan also includes procedures for the periodic review of readiness. Since the Sugar Creek Wastewater Treatment Plant has been in operation, there have not been any major or minor reported releases from this facility. One of the goals of this Risk Management Plan is to maintain the plant's current high level of safety and the excellent safety record. This plan includes the following sections: 7 Program requirements 7 Hazard Assessment 7 Emergency Response Plan 7 Prevention Plan 7 Audit Schedules Material Safety Data She ets (MSDS), Tier 2 reports, employee training certificates and release confirmation and report forms will be maintained as part of this document. |