Charles B. Garnsey Water Treatment Plant - Executive Summary
1. Accidental Release Prevention and Emergency Response Policies. |
We at Charles B. Garnsey Water Treatment Plant are strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas of 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 Port Orange, Fla. Fire and Rescue, which provides highly trained emergency response personnel to control and mitigate the effects of the release.
2. The Stationary Source and the Regulated Substance Handled.
Our facility's primary activities encompass the treatment of raw well water, through a lime softening treatment process, for the use of the community of Port Orange, Fla. The water is
disinfected using a combined chlorine (chlorine and anhydrous ammonia) residual. The water is then filtered, and either pumped to storage, or directly into the water distribution system to meet the consumer's demand. We have 2 regulated substances at our facility. These substances include Chlorine and Anhydrous Ammonia. The regulated substances at our facility are involved in one predominate use. Both Chlorine and Anhydrous Ammonia together are used for the disinfection of the potable water supply.
The maximum inventory of Chlorine at our facility is 18000 lbs., while Anhydrous Ammonia is present at our facility in a maximum quantity of 4300 lbs.
3. The Worst Case Release Scenario And The Alternative Release Scenario, Including Administrative Controls And Mitigation Measures To Limit The Distance For Each Reported Scenario.
To perform the required offsite consequence analysis for our facility, we have used the RMP Comp software provided by the EPA. The following paragraphs provide
details of the chosen scenarios.
The worst case scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from Chlorine. The scenario involves the release of 2000 lbs. of Chlorine in a gaseous form over 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 1.3 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L.
One alternative release scenario has been submitted for each toxic substance at or above the threshold quantity in Program 2 and 3 processes cumulatively.
The alternative release scenario for Chlorine involves a release from Tank #1 in the Chlorine process.The scenario involves the release of 2000 lbs. of Chlorine in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to endpoint of 0.0087 mg/L of Chlorine is .8 miles.
4. The General Accidental Release Prevention Program And The Chemical Specific Prevention Steps.
Our facility has taken all the n
ecessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. 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-
Charles B. Garnsey Water 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 conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analysis the What If/Checklist. The studies are undertaken by a team of qualified personnel with expertise in process operations, and are revalidated at a
regular annual interval. Any findings related to the hazard analysis are addressed in a timely manner.
For the purposes of safely conducting activities within our covered processes, Charles B. Garnsey Water Treatment 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 turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes.
Charles B. Garnsey Water Treatment Plant has a comprehensive training program to ensure that employees that are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every 3 years, and more frequently as needed.
Charles B. Garnsey Water Treatment Plant carries out highly documented maint
enance 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. Maintenance 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 Charles B. Garnsey Water 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 an offered training to deal with the modification.
Pre-startup safety reviews related to new proce
sses and to modifications in established processes are conducted as a regular practice at Charles B. Garnsey Water 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.
Charles B. Garnsey Water 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.
Charles B. Garnsey Water 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 any corrective actions to prevent the release fr
om reoccurring. All reports are retained for a minimum of 5 years.
Charles B. Garnsey Water Treatment Plant truly believes that process safety management and accident prevention is a team effort. City 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 analysis in particular.
On occasion, our city 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. Charles B. Garnsey Water Treatment Plant has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of all the procedur
es for emergency response should an accidental release of a regulated substance occur.
5. Five -Year Accident History
Charles B. Garnsey Water Treatment 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 releases during this period.
6. Emergency Response Plan
Charles B. Garnsey Water Treatment Plant carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response, including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas.
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 mo
dified emergency response.
East Central Florida Regional Planning Council, 1011 Wymore Road, suite 105, Winter Park, Florida 32789, Phone: (407) 623-1075, Fax: (407) 623-1084 is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified.
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. The inclusion of a fully enclosed and release secure Chlorine containment building with automatic gas detection equipment and alarm system, and a scrubber release mitigation system are some of the major steps we want to take to improve safety at our facility. These changes are expected to be included in our plant expansion, that will tentatively begin in the fall of 1999, and should be completed an implemented near the end of the year 2000.
P.S. (In resubmitting my RMP the software would not allow me to proceed unless I su
bmitted a compliance audit date. After talking to one of your information specialists, I was instructed to fill in this field with the present date, and to make a notation of this at the end of my executive summary. The date I inserted was 06/28/99.
The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete.
Name: Steven W. Miller
Title: Chief Operator, Charles B. Garnsey Water Treatment Plant
Date Signed: 06/08/1999