City of Hays Wastewater Treatment Plant - Executive Summary

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Executive Summary: 
 
a.  The City of Hays WastewaterTreatment Facility (WWT) accidental release prevention policy involves a unified approach that intergrates technologies, procedures, and management practices.  All applicable procedures of the U.S. Environmental Protection Agency (EPA) Prevention Program are adhered to.  The WWT emergency response policy involves the preparation of response plans which are tailored to the facility and to the emergency response services available in the community, and is in compliance with the EPA Emergency Response Program requirements. 
 
b.  The WWT chlorination system has been installed to disinfect the flow of wastewater releases to Chetahola Creek and to the reuse of reclaimed water for irrigation purposes.  The chlorination station is located on the Old Hiway 40 Bypass, approximately three quarters of one mile east of the intersection of Vine Street and the Old Hiway 40 Bypass.  The station includes a chlorination room, which contains liquid chlori 
ne containers, a chlorinator, and various safety equipment, and an instrument room, which contains a flow recorder, various electrical panels, and additional safety equipment.  The amount of chlorine handled is two one-ton containers and a 150-lb cylinder.  Because the chlorinator building is located on the wastewater treatment site, the chlorinator building is normally unmanned, however, the waterwater treatment facility is manned 24-hours per day, seven days per week and periodic checks of the chlorinator building are made throughout the day. 
 
c.  The offsite consequence analysis includes consideration of two chlorine release scenarios, identified as "worst case release" and "alternative scenario".  The first scenario is defined by EPA, which states that "the owner or operator shall assume that the ...maximum quanitity in the largest vessell... is released as a gas over 10 mimutes," due to an unspecified failure.  The alternative scenario is defined as "more likely to  occur than the 
worst-case scenario". 
 
EPA's RMP*COMP(tm) atmosheric dispersion modeling has to be performed to determine the distance traved by the cholorine released before its concentration decreases to the "toxic endpoint" slected by EPA of 3 ppm, which is the Emergency Response Planning Guideline Level 2 (ERPG-2).  This is defined by the American Industrial Hygiene Association (AIHA) as the "maximum airborne concentration below which it believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action."  The residential population within a circle with a radius corresponding to the toxic endpoint distance has to be defined, "to estimate the population potentially affected".  To determine the population within the impacted area local mobil home parks were contacted. 
 
Actuation of the chlorine detector is an active mitigation measure 
considered.  An additional mitigation system installed is the conversion of the existing chlorinators to a remote vacuum type, with all pressurized chlorine gas piping replaced with vacuum piping.  This will reduce significantly the amount of chlorine released in case of pigtail rupture. 
 
d.  The general WWT accidental release prevention program is based on the following key elements: 
- High level of training of operators 
- Preventive maintenance program 
- Use of state-of-the-art process and safety equipment 
- Use of accurate and effective operating procedures, written with the participation of the operators 
- Performance of a hazard review of equipment and procedures 
- Implementation of an auditing and inspection program. 
 
Chemical-specific prevention steps include availability of self-contained breathling apparatus (SCBA),  awareness of hazardous and toxic properties of chlorine, and presence of chlorine dectectors. 
 
e.  No accidental releases of chlorine have occurred at this facil 
ity in the past five years. 
 
f.  The facility has an emergency response program, which has been coordinated (reviewed) by the City of Hays Fire Department, which is a member of the Local Emergency Response Planning Committee (LEPC).  This program includes an emergency response decision tree and notification plan.  Emergency response drills and drill evaluations are conducted periodically; emergency operation and response procedures are also reviewed at that time. 
 
g.  Fourteen changes to improve safety (recommended actions) were identified in March 1994, when a Sate of Kansas was completed at the facility.  These recommended actions have now been evaluated and implemented as required. 
S1FACILITY|RMP*Submit|1.1.7|F|City of Hays Wastewater Treatment Plant|City of Hays||100000160568|||||1498 E. Hiway 40 Bypass||Hays|KS|67601||051|385138.3|-0991844.7|A2|AB|City of Hays|7856287360|PO Box 490||Hays|KS|67601||Steve Leiker|Waserwater Division Superintendent|Steve Leiker|Wastewater Superintende 
nt|7856287360|7856287360|||||Ellis County LEPC|8||Y||||19960325|State occupational safety agency|||Y|||| 
S1PROCESS|847|2||Wastewater Treatment Plan 
S1PROCESSNAICS|911|847|22132 
S1PROCESSCHEMICAL|1028|847|Chlorine|7782-50-5|2000| 
S2TOXIC|1028||b|EPA's RMP*Comp(TM)|b|2000|200|10.0|1.5|F|a|0.90|2000|Y|Y|Y||Y|Y|||||||Y||Y|||| 
S3TOXIC|1028||b|EPA's RMP*Comp(TM)|Pipe leak|100|10.0|10.0|3|D|a|0.10|900|Y|Y|Y||Y|Y|||||||Y||Y||||||Y||||||| 
S8PP2|359|911|19990610||||Y|||||19990610|20000325|Y||||||Y|||Y|||Y|Y|||||Y|||Y|||Y||Y|Y|Y||||||||||Y|||||Y|Y|||Y|||||||Y|Y||||||19990610|19990325|Y|Y|||||Y||19990610|19990610| chlorinators, chlorine detection equipment, SCBA gear, scrubber|19990610|20000325|||||Clorination of wastewater prior to release into the environment. 
S8PP2CHEMICALS|359|1028 
S9ERPLAN|Y|Y|Y|Y|Y|19990610|19990601|Hays City Fire and Inspection Serv.|7856287330|Y||||||Insurance Planning 
EXECUTIVE SUMMARY|RMP.TXT|Executive Summary: 
 
a.  The City of Hays WastewaterTreatment Facility (WWT) acc 
idental release prevention policy involves a unified approach that intergrates technologies, procedures, and management practices.  All applicable procedures of the U.S. Environmental Protection Agency (EPA) Prevention Program are adhered to.  The WWT emergency response policy involves the preparation of response plans which are tailored to the facility and to the emergency response services available in the community, and is in compliance with the EPA Emergency Response Program requirements. 
 
b.  The WWT chlorination system has been installed to disinfect the flow of wastewater releases to Chetahola Creek and to the reuse of reclaimed water for irrigation purposes.  The chlorination station is located on the Old Hiway 40 Bypass, approximately three quarters of one mile east of the intersection of Vine Street and the Old Hiway 40 Bypass.  The station includes a chlorination room, which contains liquid chlorine containers, a chlorinator, and various safety equipment, and an instrument r 
oom, which contains a flow recorder, various electrical panels, and additional safety equipment.  The amount of chlorine handled is two one-ton containers and a 150-lb cylinder.  Because the chlorinator building is located on the wastewater treatment site, the chlorinator building is normally unmanned, however, the waterwater treatment facility is manned 24-hours per day, seven days per week and periodic checks of the chlorinator building are made throughout the day. 
 
c.  The offsite consequence analysis includes consideration of two chlorine release scenarios, identified as "worst case release" and "alternative scenario".  The first scenario is defined by EPA, which states that "the owner or operator shall assume that the ...maximum quanitity in the largest vessell... is released as a gas over 10 mimutes," due to an unspecified failure.  The alternative scenario is defined as "more likely to  occur than the worst-case scenario". 
 
EPA's RMP*COMP(tm) atmosheric dispersion modeling has t 
o be performed to determine the distance traved by the cholorine released before its concentration decreases to the "toxic endpoint" slected by EPA of 3 ppm, which is the Emergency Response Planning Guideline Level 2 (ERPG-2).  This is defined by the American Industrial Hygiene Association (AIHA) as the "maximum airborne concentration below which it believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action."  The residential population within a circle with a radius corresponding to the toxic endpoint distance has to be defined, "to estimate the population potentially affected".  To determine the population within the impacted area local mobil home parks were contacted. 
 
Actuation of the chlorine detector is an active mitigation measure considered.  An additional mitigation system installed is the conversion of th 
e existing chlorinators to a remote vacuum type, with all pressurized chlorine gas piping replaced with vacuum piping.  This will reduce significantly the amount of chlorine released in case of pigtail rupture. 
 
d.  The general WWT accidental release prevention program is based on the following key elements: 
- High level of training of operators 
- Preventive maintenance program 
- Use of state-of-the-art process and safety equipment 
- Use of accurate and effective operating procedures, written with the participation of the operators 
- Performance of a hazard review of equipment and procedures 
- Implementation of an auditing and inspection program. 
 
Chemical-specific prevention steps include availability of self-contained breathling apparatus (SCBA),  awareness of hazardous and toxic properties of chlorine, and presence of chlorine dectectors. 
 
e.  No accidental releases of chlorine have occurred at this facility in the past five years. 
 
f.  The facility has an emergency response program 
, which has been coordinated (reviewed) by the City of Hays Fire Department, which is a member of the Local Emergency Response Planning Committee (LEPC).  This program includes an emergency response decision tree and notification plan.  Emergency response drills and drill evaluations are conducted periodically; emergency operation and response procedures are also reviewed at that time. 
 
g.  Fourteen changes to improve safety (recommended actions) were identified in March 1994, when a Sate of Kansas was completed at the facility.  These recommended actions have now been evaluated and implemented as required. 
RECCENTER|19990806|19990827|Y|Y||||RMP*Submit|||Y|||19990803 
BARCODE|MRM-1999-2-015682-5
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