City of Hickory Water Treatment Plant - Executive Summary |
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City of Hickory Hickory, NC Executive Summary The City of Hickory has implemented a comprehensive program to safely manage chlorine at its water plant and chlorine plus sulfur dioxide at its two wastewater treatment plants located in or adjacent to the City of Hickory. There have been no chlorine or sulfur dioxide incidents in the most recent five-year history period. In 1995 and 1996, a Process Safety Management (PSM) program was initiated at the Plants with the assistance of Operations Excellence Consulting, Inc., and GEOSH, two consulting organizations. A PSM Implementation Manual was edited to be site specific and issued to the plants. With this step, approximately 50% of PSM requirements were met. Key items included in the manual were: -Written site specific procedures for Employee Involvement, Management of Change, Incident Investigation, Pre-Startup Reviews and Self Audits; and -Chlorine and Sulfur Dioxide safety information as 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 Process Hazards Analyses for the three chlorine processes -Developing Standard Operating Procedures for Chlorine and Sulfur Dioxide Management -Developing an initial Emergency Response Plan -Training in support of the certification of operators The supervisor, chief operator and several plant operators are meeting monthly to review and update procedures and to maintain compliance with all aspects of the PSM regulation. The chlorine and sulfur dioxide delivery systems at the plants have been upgraded to vacuum processes over the past 10 years. This process has proven to greatly reduce leaks by reducing the amount of equipment that is exposed to pressurized chlorine or sulfur dioxide. Complete new delivery systems were installed at the Henry Fork Plant in July, 1997. We install ed external visual and audible aids for any leak detection alert at the Henry Fork Plant in March, 1998. A new, updated toxic gas leak detector was installed at the Northeast Plant in March, 1999. The site's Emergency Response Plans (ERP) have been significantly upgraded in 1997. The ERP was revised to include offsite response and communication. The Catawba County LEPC and other local response organizations have been incorporated into the ERP. Where necessary, communication plans have been developed to notify businesses or residences that may be impacted by a release. To further understand chlorine and sulfur dioxide 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" chlorine release scenarios were studied for each site. The results showed that the risk of chlorine or sulfur dioxide exposure varies depending on t he plant's location. The Water Treatment Plant is located inside the City of Hickory, on the northwest side. There is no green belt surrounding the plant particularly on the west where the chlorine is located. The plant is on an elevated plateau. Thus, most any sizable chlorine or release (more than 25 pounds) would have some impact on neighboring facilities. The Northeast Wastewater Treatment Plant is located in the northeastern section of the county, at 310 Cloninger Mill Road, NE, near Lake Hickory. Due to the topography and location of the plant, the most likely scenario would be for the chlorine or sulfur dioxide to fall to the adjacent creek and follow the creek until the chlorine cloud disperses. The Henry Fork Wastewater Treatment Plant is located in the southeastern section of the county, off of River Road. The Local topography at the site favors the containment of any leak. Thus, most chlorine or sulfur dioxide releases will have little to no impact on the surrounding area s. Also, the site has a large green belt that will contain most small to medium (0 to 100 pound) leaks on site. In addition to Process Safety Management, the organization has an active safety program. The City of Hickory has had an active Safety Committee. There is an Utility representative on the Committee. The committee meets monthly and its duties include reviewing new safety procedures, accident investigations, safety surveys and safety communications. Sean Hovis, Risk Manager for the City of Hickory, also takes an active role in supporting the Utilities Safety Program. Mr. Hovis uses support from the city's insurance carrier and an outside consulting firm, currently Operations Excellence Consulting, Inc., to implement a city wide safety program. Within the Utilities department, there are monthly safety meetings to review an OSHA subject or discuss a safety issue. Routine training is conducted for topics such as: - Hazard Communications - Personal Protective Equipment - Lockout /Tagout - Confined Space As a result of our programs, the plants have had an excellent safety record. We plan to continue our emphasis on safety to maintain and improve our safety performance. Report by: Gene Hayes Director of Utilities City of Hickory, North Carolina |