Iowa City Water Treatment Facility - Executive Summary |
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EXECUTIVE SUMMARY Risk Management Plan 40 CFR Part 68 City of Iowa City Water Division Accidental release prevention policies of the City of Iowa City Water Division: This Risk Management Plan was developed to prevent the occurrence of, or minimize the consequences of any accidental releases of chlorine. It is the stated policy of the City of Iowa City Water Division to provide its employees with a safe and healthful work environment and to conduct its operations in such a manner as to have minimal impact on the environment and the surrounding community. Every effort has been made to provide the greatest degree of safety for City employees and the citizens of Iowa City. The Risk Management Plan includes all elements of the pertinent OSHA standard and current EPA regulations: a process hazard analysis, standard operating procedures for all systems involved in the water treatment process, worst-case and alternate-case toxic release scenarios, management-of-change and chemical pro cess safety guidelines, and descriptions of employee training programs and equipment preventive maintenance policies. Water Division employees, representatives of the University of Iowa, and the citizens of Iowa City will be provided full access to this document, including the process hazard analysis and all other information contained in the process safety and risk management program. Primary activities: The primary responsibility of the Water Division is to provide the citizens of Iowa City with a safe and reliable source of drinking water. This is accomplished through the use of chlorine gas to disinfect the raw water supply. Chlorine used for this disinfection is delivered to the Water Division in ton containers. These containers are stored in an enclosed area within the confines of the water treatment facility. Chlorine is then fed to various stages of the treatment process through a chlorination system. The maximum amount of chlorine in storage at the water treatment plant is twelve (12) tons, in one ton containers. Only four containers are connected to the chlorination system at any one time. General accidental release prevention program and chemical-specific prevention steps: The City of Iowa City Water Division has in place a preventive maintenance program covering all components of the chlorination system. The preventive maintenance program ensures the integrity of chlorination process equipment and is designed to minimize the risk of a catastrophic chlorine release. This preventive maintenance program provides for regular inspection and testing of chlorination equipment. These tests and inspections are carried out by Water Division operations and maintenance personnel on a daily basis. The Water Division also has an employee education and training program which encompasses all necessary training in safe operations and maintenance of the water treatment process. All affected personnel receive training at the time of their initial assignment, an d whenever there is a process modification, alteration of operating procedures, or a change in individual job duties. It is the belief of the Water Division that compliance audits are needed to evaluate the effectiveness of the process safety and risk management programs. It is the policy of the Water Division that these audits should be conducted at regular intervals by an employee-management team, and that the team should review the Risk Management Plan in force at the time of the audit for its effectiveness and applicability, and make recommendations for changes and revisions, as necessary. Five-year accident history: There have been no chlorine releases from the Iowa City water treatment facility, during the five year period immediately proceeding the date of this report, which resulted in death or injury to Water Division personnel or the general public, or significant property or environmental damage on- and off-site. Worst-case release scenario and alternative release scenar io: In the worst-case scenario, a ton container of chlorine ruptures and releases 2000 pounds of Cl2 gas to the atmosphere. The contents of the chlorine tank are expected to be released within ten minutes over urban terrain. The distance to the toxic endpoint for the worst-case scenario was determined to cover an approximately 1.3 mile radius from the water treatment plant under conditions of category F (most stable conditions) atmospheric stability and wind speed of 1.5 meters per second, as determined by the RMP COMP modeling program. In the alternate case for a chlorine release, a rupture or breakage occurs in the chlorination system inside the . The release is assumed to have a duration of approximately ten minutes. Under this scenario, an estimated 3 pounds of chlorine would be released to the atmosphere, at a release rate of 0.33 pounds per minute. The reported amount of Cl2 released during the alternate case scenario is considering all active and passive mitigation device s available at the water treatment plant. These devices include the enclosure surrounding the chlorination system, which is designed to contain a minor release, all process monitoring equipment installed within the water treatment facility, and emergency shut-off valves and components. The distance to the toxic endpoint for the alternate-case scenario is 0.08 miles, using category D (neutral) atmospheric conditions, wind speed of 3 meters per second, and urban terrain. Emergency response program: The scope of the Water Divisions emergency response and action plan includes both minor chlorine releases controllable by Water Division staff and contained within the water treatment plant, and uncontrolled, major releases requiring assistance from local emergency responders. All Water Divsion personnel receive initial training in emergency response and evacuation procedures and undergo refresher training at least once every three years thereafter. Training topics include employee dut ies and responsibilities in the event of a toxic chemical release, procedures for the proper use and maintenance of emergency response and personal protective equipment, proper use of communications equipment, pertinent telephone numbers and points of contact for emergency responders, and evacuation routes and location of safe zones. Emergency response has been coordinated with the Iowa City Fire Department, and the University of Iowa Department of Public Safety. The Iowa City Fire Department has responsibility for emergency rescue and initial medical response during a chlorine emergency. The 24-hour emergency response telephone number is 9-911 for outside emergency responders; the emergency telephone number for the Water Division itself is 356-5166. Notification of residences and neighboring facilities following a severe chlorine release will be the responsibility of the University of Iowa Public Safety and Iowa City Police Departments. Decontamination and clean up efforts will b e coordinated with the Johnson County Hazardous Materials Response Team, and decontamination of the immediate leak area will be under the supervision of personnel from this Team. In the advent of a major chlorine release, Water Division personnel will only offer technical assistance to these emergency response agencies. Planned changes to improve safety: The Iowa City Water Division is committed to improving the quality of employee training and education programs, including training in the safe use of chlorine and in appropriate emergency response. These programs are to be evaluated at regular intervals and will be updated and revised as necessary. Employee training will be documented to the fullest extent possible. Water Division personnel will continue to participate in drills and cooperative training with emergency responders in the local area. The chlorination system preventive maintenance program will also be evaluated, and if unsatisfactory conditions are noted or recommendati ons for corrective action are made, these conditions or recommendations will be promptly addressed and any outstanding problems will be resolved in a timely manner. |