ELMIRA WATER BOARD FILTRATION PLANT - Executive Summary
1. Accidental Release Prevention and Emergency Response Policies |
We at the ELMIRA WATER BOARD 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 ELMIRA FIRE DEPARTMENT/HAZMAT TEAM, 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 an 8 to 16 MGD Water Filtration Plant. We have 1 regulated substance present at our facility. This substance is Chlorine. Chlorine is used for r
aw and treated water disinfection.
The maximum inventory of Chlorine at our facility is 8000.00 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 3 toxic substances involve a catastrophic gas release from Liquid Chlorine. The scenario involves the release of 2000 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 3.5 miles is obtained corresponding to a toxic
endpoint of 0.0087 mg/L.
One alternative release scenario has been submitted for Chlorine present in Program 3 processes.
The alternative release scenario for Chlorine involves a release from (1) one ton tank - active in the Liquid Chlorine process. The scenario involves the release of 317 lb. of Chlorine in a gaseous form over 60 minutes. Passive mitigation controls such as enclosures and drains are taken into account to calculate the scenario. The release is also assumed to be controlled by active mitigation measures that include scrubbers, neutralization and emergency shutdown systems. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.11 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 requirement set out under 40 CFR part 68 of the EPA. This facility was designed and
constructed in accordance with NFPA-58 Standard, 1998 Edition. A number of processes at our facility are subject 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
ELMIRA WATER BOARD FILTRATION PLANT 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 has conducted comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses were modeled with the information provided in the A.W.W.A. COMPLIAMCE GUIDANCE FOR RISK MANAGEMENT FOR WATER TREATMENT PLANTS. The studies were undertaken by a team of qualified pers
onnel with expertise in engineering and process operations and are revalidated annually. Any findings related to the hazard analysis are addressed in a timely manner.
For the purposes of safely conducting activities within our covered processes, ELMIRA WATER BOARD FILTRATION PLANT 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.
ELMIRA WATER BOARD FILTRATION 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. Refresher training is provided yearly and more frequently as needed. The Elmira Water Board complies with all respirato
ry protection programs and conducts safety training annually with the Elmira Fire Department Hazmat team.
ELMIRA WATER BOARD FILTRATION PLANT 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. Qualified personnel carry out maintenance operations 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 ELMIRA WATER BOARD FILTRATION 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-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at ELMIRA WATER BOARD FILTRATION 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.
ELMIRA WATER BOARD FILTRATION PLANT conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits will be 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.
ELMIRA WATER BOARD FILTRATION PLANT will 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.
The ELMIRA WATER BOARD truly believes that process safety management and accident prevention is a team effort. Our 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. The ELMIRA WATER BOARD has a strict policy of infor
ming 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 History
The ELMIRA WATER BOARD FILTRATION PLANT has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period.
6. Emergency Response Plan
The ELMIRA WATER BOARD FILTRATION PLANT carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response depending on the seriousness of the leak and in-house controllability. In the event of a major chlorine leak, the operator on duty will immediately call 911 to alert the Elmira Fire Department / Hazmat Team. The response team will immediately be dispatched to the scene where
they will take complete command of the entire situation. First aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas will commence.
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.
7. Planned Changes to Improve Safety
Due to the EPA Risk Management Rule, some major changes in our facility have been addressed and implemented to reduce the potential hazard associated with chlorine. The changes concern our total maximum inventory and delivery of chlorine.
Our chlorine inventory was reduced from six one ton cylinders to four one ton cylinders. Prior to January 1999, normal chlorine process delivery consisted of two open tanks active, with two open tanks in standby.
This delivery procedure has now been reduced to one open tank active, and one unopened tank in standby. Furthermore, the valve of the unopened tank in standby, will not be opened until there is 100 lbs. or less of chlorine in the active tank.
The cylinders are now connected to a new flexible, connecting feed line hosing, approved by the Chlorine Institute. This new hose replaces the existing soft tubing that was susceptible to kinks and stress fractures, which could cause the release of chlorine gas.
Cylinders will only be changed during the day shift, ensuring enough qualified staff is on hand in the event of an accidental chlorine release.
Elmira Water Board Filtration Plant operators and staff have initiated some major preventive changes.
1. The purchase of two chlorine suits to offer chemical protection.
2. Chlorine lines are now "tagged" to keep an accurate record of the number of changes to each tank occurring on a particular chlorine line. After 20 changes, due to use
and deterioration, that particular chlorine line will be replaced as recommended by the Chlorine Institute.
3. The mask portion of the self contained breathing apparatus (SCBA) is disassembled, reassembled, and inspected on a routine monthly basis by required staff and observed by a co- worker for approval and individual reinforcement. This program is documented.
4. New cylinder mounted vacuum regulators have been ordered and will be installed to each cylinder upon arrival. These devices will further reduce the potential for a chlorine gas leak.